2026 Membership Book FINAL

Case 1:25-cv-12578-RGS Document 1 Filed 09/15/25 Page 24 of 28

205 C.M.R. § 218.00 (sports wagering application requirements and procedures, including the

factors the Massachusetts Gaming Commission considers when determining whether to exercise

its discretion to grant a license), it would be entirely impracticable for Robinhood to be subject to

the often conflicting regulations of each of the states in which it makes federally authorized

event contract trading available to its customers.

60.

If Robinhood were to cease offering sports-related event contract trading

in Massachusetts, Robinhood would forgo significant business in Massachusetts, resulting in loss

of revenue. These economic losses would be unrecoverable because sovereign immunity bars

Robinhood from obtaining monetary damages for this impact on Robinhood’s business. See

Alden v. Maine , 527 U.S. 706, 712-13 (1999). Damages that are unrecoverable due to sovereign

immunity constitute irreparable harm. See, e.g. , Liu v. Noem , 780 F. Supp. 3d 386, 403 (D.N.H.

2025) (holding that plaintiff established irreparable harm because of “the government’s

sovereign immunity with regard to a claim seeking money damages”); Concord Hosp., Inc. v.

NH Dep’t of Health & Hum. Servs. , 743 F. Supp. 3d 325, 363 (D.N.H. 2024) (holding that the

plaintiff showed irreparable harm because “sovereign immunity would bar plaintiff from

obtaining a damages award”).

61.

Abruptly discontinuing its Massachusetts customers’ ability to open new

sports-related event contract positions would also undermine customers’ confidence in

Robinhood and their reliance on its financial services, causing irreparable harm. KalshiEx

(D.N.J.) , 2025 WL 1218313, at *7; KalshiEx (D. Nev.) , 2025 WL 1073495, at *7; see also Ross-

Simons , 102 F.3d at 20.

62.

Further, taking a wait-and-see approach and defending any enforcement

action Massachusetts decides to file would leave Robinhood with uncertainty about the future of

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