Case 2:26-cv-00151 Document 1 Filed 02/23/26 PageID.24 Page 24 of 27
73. Immediately following the filing of this complaint, Kalshi intends to inform the
Utah AG of its filing, and Kalshi’s intent to seek preliminary injunctive relief. Kalshi will also inform the Utah AG that, unless Defendants assure Kalshi it will not begin an enforcement proceeding while Kalshi’s motion for a preliminary injunction is pending, Kalshi will additionally seek a temporary restraining order barring such an action. 20 REQUISITES FOR RELIEF 74. As a result of Defendants’ threatened conduct described above, there is a strong likelihood that Defendants will take action, including, but not limited to, the enforcement of preempted state law threatened by Defendants’ statements, which will violate the Supremacy Clause of the U.S. Constitution, and will subject Kalshi and its customers to irreparable harm. 75. An actual and substantial controversy exists between Plaintiff and Defendants as to their respective legal rights and duties. Defendants’ conduct alleged herein, including online threats to Kalshi, has already resulted in, and will continue to result in, irreparable injury to Plaintiff, including but not limited to economic hardship and impairment of existing contractual relationships. 76. Plaintiff has no plain, speedy, or adequate remedy at law to address the wrongs described herein. Plaintiff therefore seeks declaratory and injunctive relief restraining Defendants from enforcing Utah law that interferes with the operation and function of Plaintiff’s futures market described herein.
20 Kalshi sought the same relief in Tennessee after the Tennessee Attorney General failed to provide any assurance that they would defer enforcement until the court reached a decision on Kalshi’s motion for preliminary injunction, and the Tennessee court granted the temporary restraining order. Orgel , 2026 WL 474869, at *1–2.
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