Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 3 of 47
regulated exclusively by the Commodities Futures Trading Commission (“CFTC”), and is merely operating a “prediction market” that permits the buying and selling of “commodities contracts,” or swaps on sporting events. While masquerading as novel commodities and futures products, these event contracts are, substantively, nothing more than illegal, unregulated wagers on the outcomes of sporting events:
5. Contrary to Kalshi’s assertions, Kalshi is engaging in sport gambling as defined by the IGRA and the Nation’s Compact and Ordinance. Therefore, the Nation seeks an order from the Court enjoining Kalshi from conducting its illegal sports gambling operation. 6. In addition, the Nation seeks a permanent injunction enjoining Kalshi’s illegal gambling on its Indian Lands because such gaming is currently unregulated, violates the State’s Constitution and criminal law, and directly interferes with the ability of the Nation to govern itself under its own laws on its Indian Lands—lands owned by the United States of America in trust for the Nation. JURISDICTION 7. This Court’s jurisdiction over the Tribe’s claims is based upon the following: a) 28 U.S.C. § 1331, in that this action arises under the Constitution
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