Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 29 of 47
108. Likewise, a TikTok post on Kalshi’s page from October 19, 2024, states: “For the first time in 100 years, you can legally bet on U.S. elections.” The post interviews different individuals, including one person who says, “If I could mortgage my house to bet on Trump, I would.” 109. Similarly, sponsored social media posts promote Kalshi as “legalized sports trading in all 50 U.S. states,” “Legal in all 50 states,” or “Sports Betting legal in all 50 States? It’s Happened!”. ( See Exhibit G ). 110. The above examples are just a few of the many misleading and false statements by Kalshi that its platform, websites(s), software, and/or application(s) permit users to legally place sports bets and/or wages in all 50 States. GENERAL ALLEGATIONS AS TO THE GAMING ENTERPRISE 111. Having reversed course on its ability to offer “trades” on the outcomes of sports events, right after making the incoming president’s son a Kalshi “Strategic Advisor” at the start of a new presidency, Kalshi quickly partnered with at least one other entity to establish a nationwide online sports betting racket, bypassing the safeguards put in place by applicable state regulations. As described in more detail below, this group of entities (the “Gaming Racket”), worked together to offer online class III gaming, as defined by the IGRA, across the country, regardless of the fact that doing so violated federal and state laws. 112. The Gaming Racket consisted of Kalshi and Robinhood, and various individual officers, directors, agents, and/or employees of these entities who knowingly participated in the Gaming Racket’s affairs. 113. The Gaming Racket knew that the CFTC prohibited offering sports as derivative contracts because it was “contrary to the public interest” as the contracts involved, “gaming.” 7 U.S.C. § 7a-2(c)(5)(C)(i)(v); 17 C.F.R. § 40.11. 114. In fact, just months before the Gaming Racket began offering online
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