Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 38 of 47
process of the CFTC, even though registered entities are prohibited from offering event contracts that even contain a reference to gaming. The Gaming Racket charges for sports betting through use of electronic payments, using wires in furtherance of their scheme. 155. The Gaming Racket engages in the business of betting or wagering on sports events and knowingly uses wire communicates in interstate and Indian commerce to transmit bets, wagers, or information assisting in placing bets or wagers. 156. In Wisconsin, sports betting is exclusively legal when conducted by federally recognized Indian tribes under tribal-state gaming compacts, which are authorized by Wis. Stat. § 14.035. This limited authorization represents a general prohibition to gambling as established by the Wisconsin Constitution Article IV, § 24. 157. To the extent that 18 U.S.C. §1084(b) would apply to the Gaming Racket’s transmission of information for use in news reporting of sporting events or contests, or for the transmission of information assisting in the placing of bets or wagers on a sporting event or contest in Wisconsin, the Gaming Racket still actively transmits bets or wagers not excepted under Section 1084(b). 158. Kalshi and Robinhood, by and through the Gaming Racket described herein, have knowingly conducted, financed, managed, supervised, directed, or owned all or part of an illegal gambling business, as defined by 18 U.S.C. § 1955, and which violates Wis. Stat. § 945.03, prohibiting commercial gambling. 159. Wisconsin Statute § 945.03(1m) states that whoever intentionally does any of the following is engaged in commercial gambling: a. Participates in the earnings of or for gain operates or
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