Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 13 of 47
42. Pursuant to the IGRA and the Nation’s own inherent sovereign authority, the Nation has enacted a Gaming Ordinance that has been approved by the Chair of the NIGC, comprehensively regulating gaming activities on the Nation’s Indian Lands. 43. The Ordinance establishes a Tribal Gaming Commission (“TGC”) with the authority to adopt and enforce regulations that establish comprehensive minimum internal control standards for the playing of all games conducted on the Nation’s Indian Lands, including but not limited to the rules for the playing of the games and approval and testing of the equipment used in the playing of the games. 44. In addition, the Ordinance requires every person, organization, and entity involved in gaming activities on the Indian Lands to go through a detailed criminal history and background check and obtain gaming licenses issued by the TGC verifying that the licensee is not involved in or associated with any criminal activity. 45. Finally, the Ordinance and the Nation’s TGC regulations specify what games can be played on the Nation’s Indian Lands and prohibits the playing of any class III game that is not expressly authorized by the Nation’s Compact or Ordinance. KALSHI’S ILLEGAL SPORTS GAMBLING ON THE NATION’S INDIAN LANDS 46. Kalshi is engaging in illegal sports gambling on the Nation’s Indian Lands disguised as event contracts that allow people to speculate on the outcome of a sporting event. Event contracts usually pose a binary, yes-or-no question as to whether the underlying event will happen. Events contracts are governed by the Commodities Exchange Act, 7 U.S.C. 1, et. seq. (“CEA”). 47. Under the CEA, event contracts are a subset of futures contracts, which
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