Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 12 of 47
Nation is the primary beneficiary of the gaming activities, and to promote tribal economic development and self-sufficiency. To achieve these objectives, the Compact promotes ethical practices in conjunction with class III gaming through the licensing and control of persons and entities employed in, or providing goods and services to, the tribal gaming operations, protects against the presence or participation of persons whose criminal backgrounds, reputations, character, or associations make them unsuitable for participation in gaming, thereby maintaining a high level of integrity in tribal governmental gaming, and protects the patrons and employees of their gaming facilities. 39. The Compact thus regulates class III gaming on the Nation’s Indian Lands to ensure compliance with IGRA, its tribal Gaming Ordinance, and the NIGC and Tribal Gaming Commissions’ minimum internal control standards. Through that regulated class III gaming, the Compact enables the Nation to develop self- sufficiency, promote tribal economic development, and create jobs and generate revenues to support the Nation’s government and its governmental services and programs. Relevant to the Nation, tribal governmental gaming is the primary source of revenue funding the Nation’s government and its governmental services and programs. 40. Under its Compact, the Nation is authorized to operate slot machines, lottery games, banked and percentage card games, and sports gambling at its casinos. 41. By making its sports wagering contracts available on the Nation’s Indian Lands and offering for play to the general public the class III game of sports wagering, Kalshi violates the Nation’s Compact, Ordinance, and Gaming Commission regulations, and directly interferes with and impairs the Nation’s sovereign right to regulate gaming on its Indian Lands. B. The Nation’s Regulation of Gaming Under its Gaming Ordinance.
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