Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 24 of 47
continues to grow, so too does the need to replicate the integrity and consumer protections that exist at the state level. Currently, those protections are lacking.” 14 87. On March 17, 2025, Robinhood announced that it partnered with Kalshi to offer March Madness sports event contracts. Kalshi’s CEO, Tarek Mansour stated: “[we] couldn’t ask for a better partner in Robinhood to bring our vision to every American.” Tom Nightingale, Robinhood launches Kalshi-powered sports markets, starting with March Madness , SBC Americas (March 17, 2025). 15 88. On May 16, 2025, interim Chairman of the CFTC, Caroline Pham signaled her intent to leave the CFTC once Quintenz is confirmed to the appointment of the CFTC Chairman, leaving only Quintenz and commissioner Kristin Johnson on the Commission. Jesse Hamilton, CFTC’s Pham Said to Plot Exit, Agency May Be Left Without a Party Majority , Coin Desk (May 16, 2025). 16 89. On May 21, 2025, Quintenz submitted an ethics statement to the CFTC, confirming that Quintenz was employed by Kalshi and held stock and unvested stock options in Kalshi. Brian Quintenz, Ethics Statement to CFTC at 2 (May 21, 2025). 17 90. On May 28, 2025, CFTC Commissioner Kristin Johnson signaled her intent to leave the CFTC “later this year,” leaving Quintenz as the sole commissioner. Julia Shapero, CFTC leaders exit as Trump pick prepares to take helm , The Hill (May 28, 2025). 18 91. On information and belief, Kalshi has been prolific in offering sports event contracts with the knowledge that the legality of their sports event contracts is highly questionable and widely criticized as an impermissible form of sports gaming 14 https://www.cftc.gov/media/11941/MLB030725/download (last visited June 24, 2025). 15 https://sbcamericas.com/2025/03/17/robinhood-kalshi-sports-event-contracts/. 16 https://www.coindesk.com/policy/2025/05/14/cftc-s-pham-said-to-plot-exit-agency-may-be-left-without-a-party- majority. 17 https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/009D247776338CD385258C95002C929F/$FILE/Quintenz%2C %20Brian%20D.%20%20finalEA.pdf. 18 https://thehill.com/newsletters/technology/5322818-cftc-leaders-exit-as-trump-pick-prepares-to-take-helm/.
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