Case: 3:25-cv-00698 Document #: 1 Filed: 08/20/25 Page 46 of 47
self-regulating the products offered on its DCM, is impermissibly regulating an area of Indian commerce, within the field of class III gaming activity in Indian country, outside the permissible scope of the CEA, where IGRA occupies the field of regulation and grants Tribes the exclusive right to regulate class III gaming activity on Indian lands; 4. That the Court declare that Kalshi’s gambling activities on the Nation’s Indian Lands violates the Nation’s Ordinance and constitutes an impermissible interference with the ability of the Nation to govern itself on its Indian Lands under its own laws; 5. That the Court preliminarily and permanently enjoin Kalshi and Robinhood from offering sports events contracts on or near the Nation’s Indian Lands; 6. That the Court declare that Kalshi’s and Robinhood’s joint conduct demonstrate systematic engagement in a pattern of racketeering activity in violation of RICO, 18 U.S.C. § 1962(c); 7. That the Nation be awarded treble damages, costs, and attorneys’ fees pursuant to 18 U.S.C. § 1962(c) and the Nation’s own attorney fee ordinance; 8. That the Court order injunctive relief as permitted by 15 U.S.C. § 1116(a), and award damages, including disgorgement of ill-gotten gains, lost profits, costs, and attorneys’ fees, as permitted by 15 U.S.C. § 1117(a); and 9. That the Court grants such other and further relief as may be deemed appropriate.
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QB\168080.00083\98102991.1
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