Complaint for Permanent Injunction and Declaratory Relief Against All Defendants (Receipt # AWAWDC-9579367) Attorney Kenneth E Payson Added to Party Robinhood Derivatives, LLC Filed by Robinhood Derivatives, LLC. (Attachments: # 1 Exhibits A-H, # 2 Civil Cover Sheet, # 3 Summons Tina Griffin, # 4 Summons Alicia Levy, # 5 Summons Sarah Lawson, # 6 Summons Noah Skartvedt, # 7 Summons Michael Charles, # 8 Summons Nicholas W. Brown)(Payson, Kenneth)

Exhibit A Exhibit B COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF - 1 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000 Seattle, WA 98104-3188 206-464-7744 STATE OF WASHINGTON KING COUNTY SUPERIOR COURT STATE OF WASHINGTON, Plaintiff,

v.

1.1

KalshiEx, LLC (“Kalshi”) claims to have “cracked the code on legal betting in

all 50 states” through its online betting platform. Kalshi offers and advertises a continuous and captivating stream of opportunities to bet money online on thousands of topics ranging from sports and elections to the total number of “measles cases this year,” “what will the witnesses say during the Child Trafficking hearing,” and whether Ali Khamenei will be “out as Supreme Leader” of Iran, all while Kalshi takes a cut of the action. Under longstanding, well-established, and unambiguous Washington state law, Kalshi’s gambling operation is illegal.

1.2

Washington has some of the most restrictive gambling laws in the United States.

The Washington Constitution of 1889 explicitly prohibited all gambling activities on state lands, and Washington continues to tightly regulate gambling to this day. In 2006, the Washington State Legislature expressly banned online gambling, finding that “with the advent of the internet and other technologies . . . it is appropriate for this legislature to reaffirm the policy prohibiting gambling that exploits such new technologies.” Laws of 2006, ch. 290, § 1. That prohibition

COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF - 2 ATTORNEY GENERAL OF WASHINGTON Consumer Protection Division 800 Fifth Avenue, Suite 2000 Seattle, WA 98104-3188 206-464-7744

remains in effect, with the sole exception of sports wagers placed and accepted on tribal lands.

1.3

In direct violation of this prohibition and public policy, Kalshi operates its online

betting market nationwide, including in Washington and other states that prohibit online gambling. In its advertising and marketing, Kalshi specifically promotes illegal online sports gambling in Washington state.

1.4

Kalshi’s platform extends well beyond sports gambling, however, to include

betting on politics, news, entertainment and cultural topics, so-called ‘mention markets’ that urge bettors to wager on what will be said during public broadcasts, and thousands upon thousands of niche issues—all available online 24/7. Indeed, Kalshi boasts that it has made it possible to “bet on anything” by restructuring and rebranding traditional gambling models as “predictive markets.” In so doing, Kalshi is driving an explosion of online gambling activity, while openly violating Washington law, and turning a profit in the process.

1.5

Kalshi’s gambling operations violate numerous provisions of Washington’s

Gambling Act, as well as the Consumer Protection Act and the Recovery of Money Lost at