Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 4 of 47
and laws of the United States, specifically, the IGRA, the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. § 1961 et seq. (“RICO”), the Lanham Act, 15 U.S.C. § 1051 et seq. , and the federal common law; b) 28 U.S.C. § 1362, in that the district courts have original jurisdiction of all civil actions, brought by any Indian tribe or band with a governing body duly recognized by the Secretary of the Interior (“Secretary”), wherein the matter in controversy arises under the Constitution, laws, or treaties of the United States; c) 25 U.S.C. § 2710(d)(7)(A)(ii), in that this is an action initiated by a federally recognized Indian tribe to enjoin a class III gaming activity located on Indian lands and conducted in violation of a Tribal-State compact that is in effect; d) 18 U.S.C. § 1964(c), in that this is an action initiated by the Tribe for injuries to its business caused by defendants’ violation of the Racketeer Influenced and Corrupt Organizations Act (“RICO”) through a pattern of racketeering activity. e) 15 U.S.C. § 1125(a)(1)(B), in that this action seeks to redress false and misleading statements of fact made in commercial advertising or promotion that misrepresent the nature, characteristics, or qualities of defendant Kalshi’s activities. VENUE 8. Venue is proper in this Court, pursuant to 28 U.S.C. § 1391, in that: a) The defendants conduct business within this District; and b) A substantial part of the events or omissions giving rise to the Tribe’s claims occurred in this District. PARTIES
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