Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 42 of 47
(Infringement of the Nation’s Sovereignty and Interference with Tribal Self- Governance) 170. The Ho-Chunk Nation realleges each of the allegations set forth in the proceeding paragraphs of this complaint and by this reference incorporates each allegation as if set forth herein in full. 171. Kalshi’s sports gambling activities are being conducted in direct violation of the Nation’s duly enacted Ordinance, which strictly regulates sports gambling and mandates that the Nation have the sole proprietary interest in, and responsibility for, the conduct of any gaming activity conducted on the Nation’s Indian lands. 172. By engaging in illegal sports gambling in violation of the Nation’s Ordinance, Kalshi is interfering with and will continue to interfere with the Nation’s ability to govern itself, its members, and all persons who work, live, and visit the Nation by preventing it from determining to what extent and under what conditions, if any, persons, organizations, and entities can engage in class III gaming on its Indian Lands. 173. An actual controversy exists between the Nation and Kalshi, in that the Nation contends that it has the authority to enforce its Ordinance against Kalshi and prohibit it from engaging in sports gambling on its Indian Lands, while Kalshi asserts that the Nation has no such authority. 174. Kalshi’s past and future actions of violating the Nation’s Ordinance by engaging in sports gambling on its Indian Lands impermissibly interferes with the ability of the Nation to govern itself on its Indian Lands under its own laws. Williams v. Lee , 358 U.S. 217 (1959). 175. The Nation has been irreparably injured by Kalshi’s unlawful sports gambling on its Indian Lands and unless Kalshi is provisionally and permanently
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