2026 Membership Book FINAL

Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 2 of 47

2. By way of background, for the majority of this Country’s history, gambling on sports has been illegal under federal law and the laws of most states for both moral reasons and to ensure that sporting events were fair and free from gambling-related corruption. In 1992, Congress enacted the Professional and Amateur Sports Protection Act, 28 U.S. Code § 3701 et seq ., which purported to bar the States (other than Nevada and New Jersey) from authorizing sports betting. In 2018, however, the Supreme Court struck down that Act, recognizing that “Americans have never been of one mind about gambling[,]” and holding that Congress could not lawfully impose such a barrier on state lawmakers. Murphy v. NCAA , 584 U.S. 453, 458 (2018). Since then, most states have legalized sports gambling through licensing and registration regimes that generate much needed tax dollars for states and, typically, require bettors to be 21 years old to place sports bets. Indian tribes, too, have begun to offer sports gambling on their reservations in those states where, consistent with the IGRA, the state permits such gambling under state law. 3. In 2025, the gaming industry shifted significantly. Currently, 18-year- old high school students across the United States—including some that are located on Indian reservations—are on their phones placing bets on the outcome of virtually every sporting event occurring across the globe, without any regulation of that betting by states or Indian tribes and the protective measures related to corruption and problem gambling imbedded in such regulatory schemes, in contravention of federal, state, and tribal law. And they are placing those illegal bets using defendants Kalshi Inc. and KalshiEX LLC, (“Kalshi”), and Robinhood Markets, Inc. and Robinhood Derivatives LLC (“Robinhood”). 4. Kalshi, no surprise, does not call its sports betting offerings sports gambling. Rather, Kalshi will tell the Court that it is a Designated Contract Market,

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