Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 28 of 47
be…’ dawg that’s called betting. You gambled.”; “This is literal distopia. Please don’t do this.” ( See Exhibit F ). 104. Kalshi’s promotional materials frequently utilize the term “odds” in its advertisements. Kalshi even sells merchandise, including hats that say “What are the odds.” 105. Kalshi’s deceptive promotional materials also pre-date its push into the sports gambling market. For instance, in close proximity to its advertisements of sports event contracts on various social media platforms, Kalshi marketed its platform as a betting app during the 2024 U.S. Presidential election. In one video posted on October 17, 2024, an interviewer is seen pulling a number of voters aside who are going to the polls to vote and asking, “How much money would you bet on Trump winning the election?” 106. On October 15, 2024, Kalshi posted a TikTok video on its official account, where its CEO and Co-founder, Tarek Mansour, explains in response to the question: “Hey my man, what do you do for a living”, that “I’m the founder of Kalshi […] its an app and website where you can bet on anything.” In the video, the man then asks, “anything?” and Tarek Mansour replies, “Anything. [...] We are the first platform that legalized betting on the U.S. election. Now, Americans can actually bet on whose going to win, Trump versus Kamala. You can bet on the weather tomorrow. You can bet on inflation. You can bet on whether Eric Adams is gonna get fired. Or when he’s gonna get fired.” 107. Additionally, on October 17, 2024, Kalshi posted a TikTok video on its official account, where its CEO and Co-founder, Tarek Mansour, explains that “I wanted to see our Billboard. So, these are live trades, live bets, of people actually betting on the exchange as we speak… If you bet on Kalshi right now, you’re gonna get streamed on this billboard.”
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