Case 1:25-cv-12578-RGS Document 1 Filed 09/15/25 Page 26 of 28
68.
Congress preempted the regulation of commodity futures and swaps
trading on CFTC-designated markets, leaving no room for parallel state regulation. Through the
CEA, Congress granted the CFTC “exclusive jurisdiction” to regulate “accounts,” “agreements,”
and “transactions involving swaps or contracts of sale of a commodity for future delivery”
“traded or executed on a contract market” designated by the CFTC. 7 U.S.C. § 2(a)(1)(A). This
exclusive grant of jurisdiction includes transactions involving sports-related event contracts.
69.
Because federal law occupies the entire field of commodity futures and
swaps trading on CFTC-designated markets and/or conflicts with state law, Defendants’
threatened enforcement of Massachusetts sports-wagering laws is preempted by the CEA and the
CFTC’s regulations pursuant to the Supremacy Clause. By threatening to enforce Mass. Gen.
Laws ch. 23N against Robinhood for its involvement in transactions involving sports-related
event contracts traded on a DCM, Defendants are intruding on the CFTC’s exclusive jurisdiction
to regulate those transactions.
70.
Robinhood has suffered and continues to suffer irreparable harm as a
result of the Defendants’ actions and has no remedy at law to address the conduct complained of
herein. The equities and public interest tilt strongly in Robinhood’s favor because without relief,
the harm to Robinhood will be significant, and by contrast, the Commonwealth and the public
would suffer little to no harm if the requested relief is granted.
71.
To prevent further harm to Robinhood, the Court should enjoin
Defendants from enforcing preempted Massachusetts law against Robinhood in contravention of
the United States Constitution.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Robinhood respectfully requests that the Court enter
judgment in favor of Robinhood and against Defendants:
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