Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 18 of 47
contract” around sporting events such as the Super Bowl, the Kentucky Derby, and Masters Golf Tournament. These types of contracts would not serve any real commercial purpose. Rather, they would be used solely for gambling. 156 Cong. Rec. S5906-07, (daily ed. July 15, 2010)(emphasis added). 64. Kalshi’s operations quite clearly “construct an ‘event contract’ around sporting events such as the Super Bowl” and, therefore, serve no real commercial purpose. Rather, they are used solely for gambling, in direct violation of the CEA and its implementing regulations and as shown above the IGRA, and the Nation’s Compact, Ordinance, and TGC’s regulations. 65. Because Kalshi’s contracts are not futures contracts but instead simply gambling on sports, as defined by the Nation’s Compact, Ordinance, and state law, which only permits Tribes within the State to conduct sports betting, Kalshi’s offering of the contracts to the general public for play on the Nation’s Indian Lands violates the IGRA. 66. By making its sports wagering contracts available on the Nation’s Indian Lands, and offering for play to the general public the game of sports betting, Kalshi not only violates each of the Nation’s Compact, Ordinance, and TGC regulations, but it also directly interferes with and impairs the Nation’s sovereign right to regulate gaming on its Indian Lands. 67. Furthermore, by illegally offering its sports wagering contracts to persons located both on and off of the Indian Lands in Wisconsin, Kalshi draws business away from the Nation’s casinos by allowing patrons to participate in class III gaming from their homes. Loss of revenue has a direct impact on tribal governmental functions and has a tangible effect on the services and programs the tribal governments provide to their members and all persons who live, work, and visit the Nation’s Indian Lands. 68. On information and belief, Kalshi has offered and continues to offer its
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