Robinhood has filed its opposition to a motion for preliminary injunction against KalshiEx LLC and Kalshi Inc in a lawsuit brought by the Ho-Chunk Nation.

On January 20, 2026, Robinhood Derivatives, LLC and Robinhood Markets, Inc. (together, “Robinhood”) submitted the relevant documents at the Wisconsin Western District Court.

Robinhood’s main argument against the motion by the plaintiff is that the company would likely suffer substantial and irreparable harm to its federally authorized event contract business if this Court were to enjoin Kalshi from offering sports-related event contracts on Indian lands.

Robinhood says that an injunction against Kalshi would disrupt Robinhood’s business, which uses Kalshi’s exchange to facilitate customer event contract orders, and would undermine the federal regulatory scheme.

Robinhood claims that a preliminary injunction prohibiting Kalshi from offering sports gambling contracts on Indian lands would cause substantial harm to both Kalshi and Robinhood.

First, Robinhood says, if such an injunction issued, Kalshi would likely need to halt offering sports-related event contracts on its exchange nationwide for months while it determined whether it could develop a geofencing solution. Second, once that is resolved, Kalshi may nevertheless have difficulty offering sports-related event contracts in parts of Wisconsin outside of Plaintiff’s lands, since geofencing around small parcels of Indian land may not be “feasible.”

Both scenarios would directly harm Robinhood. As an FCM, Robinhood cannot facilitate customer orders for event contracts without access to a DCM, and Kalshi is one of only two DCMs with which Robinhood has a relationship for sports-related event contract trading.

Without access to Kalshi’s DCM while it halted offering sports-related event contracts nationwide, Robinhood would be required to terminate users’ orders, liquidate positions and indefinitely pause trading through Kalshi’s DCM.

This loss of access would cause severe disruption to Robinhood’s business, including loss of both customers and goodwill. The same would be true specifically for customers in parts of Wisconsin near Indian lands, should Kalshi be unable to geofence around those lands with precision.

Robinhood argues that without access to Kalshi’s DCM, harm to Robinhood would be especially severe because of the volume of Robinhood customers’ sports-related events contracts trading.

In Wisconsin, Robinhood has more than 10,000 customers who have traded over 100 million sports-related event contracts, and most of that volume comes from orders placed on Kalshi’s exchange. The nationwide figures are even larger.

The impact would also go beyond sports-related event contracts, as Robinhood’s sports-related event contracts customers also frequently trade other products, such as stocks, options and crypto.

Robinhood notes that it is also not currently possible for Robinhood to restrict trading on Indian lands simply by “geofencing,” as Plaintiff suggests. Robinhood users may reside, place event contracts orders, travel with open contracts and hold contracts to resolution, all in different locations.Robinhood’s existing technology cannot reliably identify whether a person is on Plaintiff’s Indian Lands.

Presently, Robinhood can restrict trading only by looking at a customer’s home address or approximate location using the customer’s IP address. Home addresses are self-reported, and locating individuals by IP address relies on cell tower and other network communications data, which is only accurate within a radius of a few miles at best.

IP address location is unreliable for geolocating individuals on some Indian lands, given some of their relatively small size, irregular borders and proximity to other towns not on Indian lands. For

example, Ho-Chunk Nation operates casinos on Indian lands in six cities across Wisconsin. As a result, Robinhood cannot currently use IP location to block customers on many Indian lands without forfeiting customers in or passing through surrounding areas.

Robinhood does not currently have the capability to geofence using more precise GPS technology tied to an individual user’s device. Developing such capability (i) would likely take months to implement, at significant cost and (ii) would force Robinhood to start requiring users to affirmatively consent to share their location data.

Featured image credit: Ho-Chunk Nation’s official website.