Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 5 of 47
9. The Ho-Chunk Nation, formerly known as the Wisconsin Winnebago, is a federally recognized Indian tribe. The Nation is the beneficial owner of and exercises jurisdiction over land held in trust for it by the United States of America, which is located throughout a 14-county area of the State of Wisconsin. The Nation engages in a variety of class III gaming activities at three gaming facilities located on the Nation’s trust land, pursuant to a Tribal-State gaming compact with the State of Wisconsin. 10. Defendant Kalshi Inc. is a Delaware corporation headquartered at 594 Broadway, Rm 407, New York City, New York 10012. On information and belief, it is the parent company of all other Kalshi entities. 11. Defendant KalshiEX LLC is a Delaware corporation headquartered at 594 Broadway Rm 407, New York City, New York 10012. On information and belief, it is a wholly owned subsidiary of Kalshi Inc. that operates as a commodities exchange. 12. Defendant Robinhood Markets, Inc. is a Delaware corporation headquartered at 85 Willow Road, Menlo Park, California 94025. On information and belief, it is the parent company of all other Robinhood entities (collectively, “Robinhood”). Robinhood is an investment platform that permits trading on stocks, ETFs, and other commodities. As relevant here, Robinhood has partnered with Kalshi to open—on the Robinhood investment platform—a prediction market hub, allowing persons located both on and off the Nation’s Indian Lands to place illegal, unregulated wagers in the form of event contracts. 13. Defendant Robinhood Derivatives LLC is a Delaware corporation headquartered at 85 Willow Road, Menlo Park, California 94025. On information and belief, it is the wholly owned subsidiary of Robinhood Markets, Inc. It is a futures commission merchant and provides options on futures trading. As relevant
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