Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 37 of 47
defined in 18 U.S.C. § 1964(3). 150. The Gaming Racket is in association as an “enterprise” as that term is defined in 18 U.S.C. § 1961(4). The Gaming Racket associated for the common purpose of profiting off the running of an illegal sports betting operation by offering sports betting in violation of IGRA as described above as well as in violation of the CEA and its enforcing regulations. 151. The Gaming Racket had an ongoing organization with an ascertainable structure and functioned as a continuing unit with separate roles and responsibilities. 152. The Gaming Racket was formed and functions with a common purpose: to design, market, distribute, and widely disseminate event contracts based on sports outcomes (“gaming contracts”), all the while consciously disregarding or actively circumventing prior regulatory concerns and even their own prior stated positions that such contracts constituted prohibited “gaming.” Kalshi and Robinhood decided to jointly enter and aggressively expand the market for gaming contracts with a mutual awareness of the ongoing regulatory scrutiny surrounding such products, resulting in shared liability and operational interdependence for this specific venture. 153. Through this Gaming Racket, Defendants Kalshi and Robinhood, along with their respective officers, directors, agents, and employees who knowingly participated in its affairs, directly and indirectly conducted and engaged in the enterprise's activities through a pattern of racketeering activity, as defined in 18 U.S.C. § 1961(1). Specifically, the Gaming Racket has: (1) engaged in wire fraud as prohibited by 18 U.S.C. § 1343; (2) transmitted wagering information as prohibited by 18 U.S.C. § 1084, and (3) operated an illegal gambling business as prohibited by 18 U.S.C. § 1955. 154. The Gaming Racket created a scheme to offer sports betting through the guise of events contracts, seeking to cloak their activity through the self-certification
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