Every allocator who looks at sports prediction markets reaches the same question first: is this allowed for us? There is no single answer. It depends on your investment policy, how you hold the position, where you and the venues operate, and law that federal courts are still deciding.1 This page sets out the public record so your counsel and your committee can start from the same facts.
Six short answers
Are sports prediction markets regulated in the United States?
Kalshi and Polymarket US operate exchanges that the Commodity Futures Trading Commission (CFTC) has designated as contract markets under the Commodity Exchange Act. Several states argue that their gambling laws also apply to sports contracts, and federal appeals courts have split on that question.1, 8, 9
Is participating allowed for my institution?
This page cannot answer that, and neither can BettorToken. The answer depends on your investment policy, your structure, where you operate, and law that is still being decided. Your counsel decides.
What have the courts decided so far?
As of November 4, 2026, the Third Circuit has ruled for Kalshi against New Jersey, while the Sixth and Ninth Circuits have ruled for Ohio, Tennessee and Nevada. Three petitions asking the U.S. Supreme Court to take up the question are pending, and the Court has not decided whether to hear any of them.2, 3, 4, 5, 6, 7
What is the CFTC doing about sports event contracts?
The CFTC has sued several states and has argued in court that its jurisdiction over these markets is exclusive. On October 19, 2026 it proposed a rule that would expressly define event contracts, including sports contracts, as swaps. Comments are due November 18, 2026.10, 11, 12
Does investing through a vehicle raise commodity pool questions?
It can. A vehicle that trades swaps or futures may be a commodity pool, and whoever operates or advises it may need to register with the CFTC or qualify for an exemption. The answer depends on the structure, so your counsel should review it.13, 14
How is the Prime Partnership set up?
It is a dedicated special purpose vehicle that your institution co-owns and governs, one institution at a time. The vehicle holds its own venue accounts in its own name, with a custodian named in the definitive documents. Definitive documents are negotiated with counsel on both sides.15
What a regulated prediction market is
A prediction market lists event contracts. Each one asks a yes-or-no question, such as whether a team wins a game. Many are structured like binary options: the YES side pays a fixed amount if the event happens and nothing if it does not, so the price trades between zero and that amount.12, 16
In the United States, the regulated version trades on exchanges that the CFTC has designated as contract markets, or DCMs, under the Commodity Exchange Act. The CFTC designated Kalshi’s exchange, KalshiEX LLC, in November 2020.8
- 01 · ListSelf-certifiedThe exchange certifies to the CFTC that the contract complies with the law.
- 02 · TradeOn the exchangeParticipants buy and sell under the exchange’s published rules.
- 03 · ClearThrough a DCOA clearinghouse stands between the two sides of each trade.
- 04 · SettleOn the rulesThe outcome is determined under the contract’s written terms.
Self-certification. A DCM can list a new contract by filing a written certification that it complies with the Act and CFTC rules. It can begin trading the next business day without prior approval. If the CFTC has concerns, it can stay the listing, or open a 90-day review of an event contract that may involve one of the activities the law singles out.16, 17, 18
The special rule for event contracts. The Act lets the CFTC find event contracts contrary to the public interest if they involve unlawful activity, terrorism, assassination, war, gaming, or similar activity it identifies by rule. A CFTC rule, 17 C.F.R. 40.11, bars exchanges from listing contracts that involve those activities. Whether a sports contract counts as “gaming” is one of the open questions below.3, 16, 17, 18
Kalshi self-certified its first sports event contracts in January 2025. According to the Ninth Circuit, the CFTC never opened a 90-day review of them or issued an order approving them.3
Clearing and collateral. A derivatives clearing organization, or DCO, is a clearinghouse that substitutes its own credit for the credit of the two parties and settles their obligations. Kalshi’s clearinghouse, Kalshi Klear LLC, is registered with the CFTC as a DCO.13, 19 Event contracts are often fully collateralized, which means the most a position can lose is posted when the trade is made.20, 21 Ask each venue which DCO clears its contracts.
Settlement on public rules. Contract terms, including how an outcome is determined, are set in rules the exchange files with the CFTC. Your counsel can read them before any trade.17, 22
Where each venue stands
BettorToken’s desk is live on two regulated venues, Polymarket and Kalshi. Integrations with Novig and Fanatics Markets are pending.15 Here is each venue’s regulatory footing as of November 4, 2026, from public records.
| Venue | Regulator and status | BettorToken | Sources |
|---|---|---|---|
| Kalshi | KalshiEX LLC is a CFTC-designated contract market, designated in November 2020. Its clearinghouse, Kalshi Klear LLC, has been a CFTC-registered DCO since August 2024. It has listed self-certified sports contracts since January 2025 and is a party to most of the cases below. | Live | 3, 8, 19 |
| Polymarket | QCX LLC, doing business as Polymarket US, is a CFTC-designated contract market, designated July 9, 2025. Polymarket acquired this already-registered exchange in July 2025. In November 2025 the CFTC approved an amended order of designation that allows access through intermediaries such as futures commission merchants. The U.S. app opened to waitlisted users in December 2025, starting with sports. | Live | 9, 23, 24 |
| Novig | Novig’s exchange, Ludlow Exchange, LLC, is a CFTC-designated contract market, designated June 16, 2026. Novig announced a nationwide launch on August 4, 2026. | Integration pending | 22, 25 |
| Fanatics Markets | Launched in December 2025. At launch, contracts were offered by Crypto.com | Derivatives North America, a CFTC-registered exchange and clearinghouse, and introduced by Fanatics Markets IB (Paragon Global Markets, LLC), a CFTC-registered introducing broker and NFA member. On July 27, 2026, Fanatics announced an agreement to acquire a DCM, Water Street Labs, LLC, and a DCO, CX Clearinghouse L.P., from BGC Group. | Integration pending | 26, 27 |
Venue status is not a legal opinion, and it is not the same as availability in every state. Courts and regulators have acted against specific venues in specific states. A Nevada state court has enjoined both Kalshi and Polymarket from offering event contracts in Nevada without a state gaming license.28 New York’s Attorney General sued Polymarket US in state court in September 2026, and Polymarket moved the case to federal court the same day.29
In October 2026, Reuters reported, citing unnamed sources, that the CFTC is examining whether Polymarket complied with a 2022 settlement about U.S. access to its offshore platform. A probe is an inquiry, not a finding.30, 31
The state and federal fight
The core question is who regulates a sports event contract listed on a federally designated exchange. Each side’s position, in brief:
- The venues, with the CFTCSports event contracts on a DCM are “swaps” under the Commodity Exchange Act. Congress gave the CFTC exclusive jurisdiction over swaps traded on DCMs, so state gambling laws cannot be applied to them, and a state-by-state patchwork would conflict with the federal scheme.11, 33
- The states and tribesThese contracts are sports wagering. Regulating gambling is a core state power, the Act does not clearly displace it, and venues can comply with state law by blocking users in states that prohibit the contracts.1, 3, 4, 32
Federal appeals courts have now reached different answers, and both sides have asked the U.S. Supreme Court to step in. Most rulings so far decide preliminary injunctions: early judgments about which side is likely to win, not final decisions on the merits.2, 5, 6 The table lists the matters that most affect the question today, most significant first.
| Where | What happened | Status |
|---|---|---|
| U.S. Supreme CourtFlaherty v. KalshiEX, No. 26-299 · Robinhood Derivatives v. Dreitzer, No. 26-338 · North American Derivatives Exchange (Crypto.com) v. Nevada, No. 26-344 | New Jersey asks the Court to review the Third Circuit. Robinhood and Crypto.com ask it to review the Ninth Circuit. Responses are due November 13 (No. 26-338), November 16 (No. 26-344) and December 7 (No. 26-299). None has been scheduled for conference.5, 6, 7 | Pending |
| New JerseyKalshiEX v. Flaherty · 3d Cir. No. 25-1922 | A district court granted Kalshi a preliminary injunction in April 2025. On April 6, 2026 the Third Circuit affirmed, 2 to 1: sports contracts on a DCM are likely swaps, and New Jersey’s gambling laws are likely preempted as applied to them.2, 32, 33 | Ruled for the venuePetition pending |
| NevadaKalshiEX v. Assad · 9th Cir. No. 25-7516 | A district court granted Kalshi a preliminary injunction in April 2025, then dissolved it. On August 28, 2026 the Ninth Circuit affirmed, 3 to 0: the contracts are likely not swaps, and Nevada’s gaming laws are likely not preempted. Related appeals by Crypto.com and Robinhood were decided the same day. On November 4, 2026, InGame reported that the court denied Kalshi’s rehearing request, with no judge calling for an en banc vote.3, 6, 7, 34 | Ruled for the state |
| Ohio and TennesseeKalshiEX v. Schuler; KalshiEX v. Orgel · 6th Cir. Nos. 26-3196, 26-5235 | On September 25, 2026 the Sixth Circuit affirmed the denial of Kalshi’s preliminary injunction in Ohio and vacated the one Kalshi had won in Tennessee. It held Kalshi had not shown the contracts are swaps and, in the alternative, that the Act does not preempt either state’s gambling laws. Kalshi asked the full court to rehear the case on October 9, 2026; the court ordered Ohio and Tennessee to respond by November 12.1, 4, 58 | Ruled for the stateRehearing petition pending |
| MarylandKalshiEX v. Martin · 4th Cir. No. 25-1892 | A district court denied Kalshi a preliminary injunction on August 1, 2025. The Fourth Circuit heard argument on May 7, 2026. No decision had been reported as of November 4, 2026.1, 32, 35, 36 | Ruled for the stateOn appeal |
| MassachusettsCommonwealth v. KalshiEX · Mass. SJC No. SJC-13906 | In January 2026 a Superior Court judge ruled for the state and said he would bar Kalshi’s unlicensed sports contracts. Reports differ on whether that order is in force during the appeal: InGame reported in May 2026 that it was not in effect, and Gambling.com reported in August 2026 that it is and that a stay was denied. The Supreme Judicial Court heard argument on May 4, 2026, and the CFTC filed a brief supporting federal jurisdiction. No decision had been reported as of November 4, 2026.11, 21, 37, 38, 59 | Ruled for the stateOn appeal |
| New York and ConnecticutKalshi and Coinbase appeals · 2d Cir. | Federal judges in both states denied Kalshi preliminary injunctions, in New York on July 7, 2026. On November 3, 2026 the Second Circuit denied Kalshi’s and Coinbase’s requests for injunctions while their appeals proceed; the appeals themselves continue. New York’s Attorney General has also sued Kalshi (July 2026) and Polymarket US (September 2026).29, 39, 40, 41 | Ruled for the stateOn appeal |
| UtahKalshiEX v. Cox · D. Utah; 10th Cir. No. 26-4100 | In August 2026 a federal judge ruled for Utah in Kalshi’s suit, and Kalshi appealed. In September 2026 the Tenth Circuit was reported to have denied Kalshi an injunction pending appeal. In late October 2026 Utah’s Attorney General filed criminal charges against Kalshi and its two co-founders; charges are allegations, not findings. The CFTC sued Utah on October 27, 2026.36, 42, 43, 44, 45 | Ruled for the stateOn appeal |
| ArizonaThe CFTC’s suit against Arizona · D. Ariz. | Arizona’s Attorney General filed criminal charges against Kalshi in March 2026. The same federal court denied Kalshi’s own request for a preliminary injunction, then, at the CFTC’s request, issued a temporary restraining order on April 10, 2026. In May 2026 it blocked Arizona from prosecuting Kalshi.46, 47, 48 | Ruled for the CFTC |
| IllinoisKalshi and Coinbase v. Illinois officials · N.D. Ill.; 7th Cir. | In October 2026 a federal judge granted Kalshi and Coinbase a partial preliminary injunction, finding some Illinois law likely preempted. It took effect October 30, 2026, and Illinois appealed to the Seventh Circuit the same day.49 | Ruled for the venue, in partOn appeal |
| Tribal lands, CaliforniaBlue Lake Rancheria v. Kalshi · 9th Cir. No. 25-7504 | On September 16, 2026 the Ninth Circuit held that two tribes are likely to succeed on their claim that Kalshi’s sports contracts on tribal lands are class III gaming under the Indian Gaming Regulatory Act, and sent the case back to the district court.50 | Ruled for the tribes |
Other states have sued venues or sent cease-and-desist letters, and the CFTC has answered with suits of its own. It sued Arizona, Connecticut and Illinois on April 2, 2026. The Block reported that its October 27 suit against Utah was its tenth against a state.10, 45, 47
- Whether the Supreme Court agrees to hear any of the three petitions.
- How the Fourth Circuit, the Massachusetts Supreme Judicial Court, and the Second, Seventh and Tenth Circuits rule, and whether the full Sixth Circuit rehears its case.
- Whether the CFTC finalizes its proposal to define event contracts as swaps, and what weight courts give it.
- How the state criminal cases proceed.
What the CFTC is doing
The CFTC’s position since early 2026 has been that it alone regulates these markets. Its main actions, in order:11, 52
- Sep 30, 2025
CFTC staff issued an advisory on sports-related event contracts, Staff Letter 25-36.3, 51
- Feb 4, 2026
The CFTC withdrew its 2024 proposal to restrict event contracts, and staff withdrew the 2025 sports advisory. Chairman Michael Selig said the agency would advance a new event contracts rulemaking.51
- Mar 12, 2026
The CFTC asked for public comment on prediction markets in an advance notice of proposed rulemaking.52
- Apr 2026
The CFTC sued Arizona, Connecticut and Illinois (April 2), asked a federal court to stop Arizona’s prosecution of Kalshi (April 9), and filed a brief in the Massachusetts Supreme Judicial Court (April 24).10, 11, 47
- Jun 12, 2026
Proposed rule, “Prediction Markets; Public Interest Determinations.” It would set contract-specific factors for deciding when an event contract is contrary to the public interest, including factors for sports contracts, and would define “gaming.” Comments closed July 27, 2026. We found no final rule as of November 4, 2026.1, 16
- Oct 19, 2026
Two rules published. A proposed rule would expressly include in the definition of “swap” event contracts “including those based on sports-, politics-, cultural-, and weather-related events.” An interim final rule, effective the same day, excludes certain casino-style gambling products offered by state- or tribally licensed operators from that definition. Comments on both are due November 18, 2026.1, 12, 53, 54
- Oct 27, 2026
The CFTC sued Utah in federal court.45
The CFTC has said that if the swap proposal is finalized, “there would no longer be a valid basis to interpret CFTC regulations to conclude that event contracts are not swaps.”1, 54
Questions your counsel and committee will ask
Use these as a starting checklist. They are general and educational. The answers depend on your institution, and your counsel decides.
Mandate and policy
- Does your investment policy statement permit derivatives? Does it address event contracts or sports-linked exposure specifically?
- Does any board, trustee, donor or sponsor policy restrict gaming-related investments?
- Who must approve a new strategy or asset type, and in what order?
Commodity pool, CPO and CTA questions
Under the Commodity Exchange Act, a commodity pool is an enterprise operated to trade commodity interests, which include futures and swaps. A commodity pool operator (CPO) runs that kind of business and solicits or receives funds for it. A commodity trading advisor (CTA) advises others on trading those interests for compensation or profit.13 A CPO must register with the CFTC, through the National Futures Association, unless it qualifies for an exemption; the NFA points to CFTC Regulations 4.5 and 4.13.14
Whether any of this applies to a vehicle that trades event contracts depends on how the vehicle is organized, who operates it, who advises it, and who invests in it. The CFTC’s October 2026 proposal to define event contracts as swaps bears on the same analysis.12
- Is the vehicle a commodity pool? If so, who is its operator?
- Is that operator registered, exempt or excluded, and what notices or filings follow?
- Is anyone acting as a commodity trading advisor to the vehicle?
- How do the definitive documents allocate these responsibilities?
BettorToken’s own disclosure: BettorToken Holdings LLC is not registered with the SEC or CFTC in any capacity and is not a broker-dealer or investment adviser.
Venue onboarding and KYC
- Will each venue open an account for an entity, and what know-your-customer and anti-money-laundering documents does it require?
- Is access direct, or through an intermediary such as a futures commission merchant?
- Which states does each venue restrict, and how does it verify location?
- What position limits and account rules apply?
Custody and collateral
- Which clearinghouse clears each venue’s contracts, and where is the collateral held?
- Is the account in the vehicle’s own name, and is it segregated?
- In what form is collateral posted, and how quickly can it be withdrawn?
- What happens if a venue suspends trading, restricts an account or delays withdrawals? Venues and their custodians may do these things under their terms.55
Tax and accounting
The IRS has not issued guidance on how gains from event contracts are taxed. Commentators have named several possible treatments, including section 1256 contracts, ordinary capital gains, and gambling income.56, 57
- How will your tax advisers characterize gains and losses?
- For a tax-exempt investor, could any income be unrelated business taxable income?
- Will a venue withhold tax, and on what basis?
- How will positions be valued in your financial statements, and who audits that?
Reputation and mandate fit
- How will beneficiaries, trustees, members or the public view sports-linked exposure?
- Are your institution or your stakeholders in a state that is actively litigating these contracts?
- If a court or regulator changes the rules, who decides to stop trading, and how quickly can positions be closed?
- What reporting will your committee see, and how often?
How the Prime Partnership is set up
The Prime Partnership is BettorToken’s program for institutions. These are its structural facts.15 None of them answers the questions above for your institution. They give your counsel a specific structure to examine.
- A dedicated vehicleA special purpose vehicle that your institution co-owns and governs.
- One institution at a timeThe program runs with one institution at a time.
- Accounts in the vehicle’s nameThe vehicle holds its own venue accounts in its own name, with a custodian named in the definitive documents.
- Limits enforced in softwareBETTOR, BettorToken’s AI desk of eight agents, trades inside hard written limits enforced in software.
- Reconciled to the venueEvery fill is reconciled to the venue’s own ledger.
- ReportingMonthly statements and a read-only dashboard.
- A shadow run firstBefore any capital funds, a simulated shadow run that you review.
- Counsel on both sidesDefinitive documents are negotiated with counsel on both sides.
- VenuesLive on Polymarket and Kalshi. Novig and Fanatics Markets: integration pending.
BettorToken Holdings LLC is a New Jersey limited liability company with its principal place of business in Ponte Vedra Beach, Florida. BettorToken Holdings LLC is not registered with the SEC or CFTC in any capacity and is not a broker-dealer or investment adviser. BettorToken does not operate a prediction-market venue. Financial records are maintained internally and are not audited or attested by an independent accountant.
Bring your counsel to the call.
Book 30 minutes with Tim Hastings and Dan Reynaud, and bring your counsel and your committee lead. The mutual NDA is signed with the booking, so the call can cover the structure and the documents.
Sources
Dates are publication or decision dates. Court dockets and CFTC registry entries were checked on November 4, 2026. News reports are cited where a primary record was not available to us; your counsel should confirm them against the court’s own docket.
- Foley & Lardner, “Prediction Markets Overview: Regulation, Litigation, and the Road to the Supreme Court”, Nov. 2, 2026.
- Holland & Knight, “Federal Appeals Court: CFTC Jurisdiction Over Sports Event Contracts Likely Exclusive”, Apr. 7, 2026 (Third Circuit decision of Apr. 6, 2026).
- U.S. Court of Appeals for the Ninth Circuit, “KalshiEX, LLC v. Assad, No. 25-7516”, published opinion, Aug. 28, 2026, via Justia.
- U.S. Court of Appeals for the Sixth Circuit, “KalshiEX LLC v. Schuler; KalshiEX LLC v. Orgel, Nos. 26-3196/5235”, opinion, Sept. 25, 2026, via GovInfo.
- Supreme Court of the United States, “Docket No. 26-299, Flaherty v. KalshiEX, LLC”, petition filed Sept. 2, 2026; response extended to Dec. 7, 2026 (Oct. 30, 2026); checked Nov. 4, 2026.
- Supreme Court of the United States, “Docket No. 26-338, Robinhood Derivatives, LLC v. Dreitzer”, petition filed Sept. 10, 2026; response extended to Nov. 13, 2026; checked Nov. 4, 2026.
- Supreme Court of the United States, “Docket No. 26-344, North American Derivatives Exchange, Inc. v. Nevada”, petition filed Sept. 11, 2026; response extended to Nov. 16, 2026; checked Nov. 4, 2026.
- Commodity Futures Trading Commission, “CFTC Designates KalshiEX LLC as a Contract Market”, Release No. 8302-20, Nov. 4, 2020.
- Commodity Futures Trading Commission, “Designated Contract Markets: QCX LLC d/b/a Polymarket US”, registry entry, designated July 9, 2025; checked Nov. 4, 2026.
- Commodity Futures Trading Commission, “CFTC Sues Trio of States to Reaffirm its Exclusive Jurisdiction Over Prediction Markets”, Release No. 9206-26, Apr. 2, 2026.
- Commodity Futures Trading Commission, “CFTC Reaffirms Exclusive Jurisdiction Over Prediction Markets in Massachusetts Supreme Judicial Court Filing”, Release No. 9219-26, Apr. 24, 2026.
- Commodity Futures Trading Commission, “Further Definition of “Swap”-Inclusions”, proposed rule, 91 Fed. Reg. 66022, Oct. 19, 2026.
- 7 U.S.C. § 1a (Commodity Exchange Act definitions), “Commodity pool, commodity pool operator, commodity trading advisor, derivatives clearing organization”, via Cornell Legal Information Institute; checked Nov. 4, 2026.
- National Futures Association, “Commodity Pool Operator (CPO) Registration”, checked Nov. 4, 2026.
- BettorToken, “The Prime Partnership: For Institutions”, company information on venue status and structure, Nov. 4, 2026.
- Commodity Futures Trading Commission, “Prediction Markets; Public Interest Determinations”, proposed rule, 91 Fed. Reg. 35806, June 12, 2026.
- 7 U.S.C. § 7a-2 (Commodity Exchange Act § 5c), “Rule review; self-certification; special rule for event contracts”, via Cornell Legal Information Institute; checked Nov. 4, 2026.
- 17 C.F.R. § 40.11, “Review of event contracts based upon certain excluded commodities”, eCFR, current as of Oct. 20, 2026.
- Commodity Futures Trading Commission, “CFTC Grants Kalshi Klear LLC DCO Registration”, Release No. 8957-24, Aug. 29, 2024.
- Commodity Futures Trading Commission, “CFTC Staff Issues Supplemental Letter Regarding No-Action Position on Reporting, Recordkeeping Requirements”, Release No. 9226-26, May 4, 2026 (refers to “fully collateralized event contract transactions”).
- InGame, “Skeptical Supreme Court Could Favor State In Kalshi-Massachusetts Case”, May 4, 2026.
- Commodity Futures Trading Commission, “Designated Contract Markets: Ludlow Exchange, LLC”, registry entry, designated June 16, 2026; checked Nov. 4, 2026.
- Bitcoin Magazine, “Polymarket Rolls Out US App Today To Select Users”, Dec. 3, 2025.
- CoinDesk, “Polymarket Secures CFTC Approval for Regulated U.S. Return”, Nov. 25, 2025.
- Novig (PR Newswire), “Novig Launches Nationwide, Bringing the Leading Sports Trading Platform to Fans Across the Country”, Aug. 4, 2026.
- Fanatics, “Fanatics Launches Fanatics Markets, the First Prediction Market at the Intersection of Sports, Finance and Culture”, press release, Dec. 3, 2025.
- Fanatics Holdings, Inc., “Fanatics to Acquire Exchange and Clearinghouse from BGC; Parties to Partner on Prediction Markets”, July 27, 2026.
- CDC Gaming Reports, “Nevada regulators celebrate state court victory over Polymarket”, June 2, 2026.
- DeFi Rate, “New York Sues Polymarket US Over Sports, Election and Culture Contracts”, Sept. 25, 2026.
- CNBC, “Polymarket faces renewed CFTC probe over U.S. access to offshore platform”, Oct. 27, 2026.
- Bitcoin Magazine, “CFTC Reopens Questions About Polymarket’s Promise To Keep Americans Out”, Oct. 27, 2026 (summarizing Reuters).
- Katten, in National Law Review, “Place Your Bets: US District Courts are Split on Whether the Commodity Exchange Act Preempts State Gaming Laws with Respect to Sports Event Contracts”, Aug. 15, 2025.
- Skadden, Arps, Slate, Meagher & Flom, “Third Circuit Affirms Kalshi’s Preliminary Injunction”, Apr. 9, 2026.
- InGame, “Ninth Circuit Denies Kalshi Rehearing Request”, Nov. 4, 2026.
- InGame, “Fourth Circuit Judges Wary Of Kalshi’s Sports Contracts, But May Not Be Convinced They’re Illegal”, May 7, 2026.
- DeFi Rate, “Prediction Market Lawsuit Tracker”, checked Nov. 4, 2026.
- Insurance Journal, “Kalshi Cannot Operate Sports-Prediction Market in Massachusetts, Judge Rules”, Jan. 21, 2026.
- CBS Sports, “Are sports prediction markets legal? Status of Kalshi and Polymarket in all 50 states”, Nov. 3, 2026.
- Covers, “Federal Judge Denies Kalshi’s Emergency Injunction Request in NY”, July 28, 2026.
- InGame, “Second Circuit Denies Kalshi Injunction After Judges Doubt Sports Contracts Are Swaps”, Nov. 3, 2026.
- Gambling.com, “Second Circuit Refuses Kalshi And Coinbase Injunction In New York And Connecticut”, Nov. 4, 2026.
- The Salt Lake Tribune, “Kalshi loses in court to Utah. Can Utahns still bet on prediction markets?”, Aug. 5, 2026.
- DeFi Rate, “Tenth Circuit Backs Utah in New Blow to Kalshi’s Sports Prediction Markets”, Sept. 8, 2026.
- KUER, “Utah ups the ante in Kalshi gambling fight with felony charges”, Oct. 28, 2026.
- The Block, “CFTC sues Utah as battle over prediction market regulation intensifies”, Oct. 27, 2026.
- CoinDesk, “Federal judge blocks Arizona from bringing criminal charges against Kalshi”, Apr. 10, 2026.
- Commodity Futures Trading Commission, “CFTC Seeks to Enjoin Arizona Criminal and Civil Enforcement Against Prediction Markets”, Release No. 9208-26, Apr. 9, 2026.
- KJZZ, “Federal judge blocks Arizona from prosecuting prediction market operator Kalshi”, May 6, 2026.
- Sports Betting Dime, “Illinois Prediction Market Law Injunction Now In Effect, but State Appeals to Seventh Circuit”, Nov. 3, 2026.
- Buchalter, “Ninth Circuit: Kalshi’s Sports Contracts Are Class III Gaming on Tribal Land, and Tribes Can Sue to Stop Them”, Sept. 21, 2026 (decision of Sept. 16, 2026).
- Commodity Futures Trading Commission, “CFTC Withdraws Event Contracts Rule Proposal and Staff Sports Event Contracts Advisory”, Release No. 9179-26, Feb. 4, 2026.
- Commodity Futures Trading Commission, “CFTC Seeks Public Comment on Advanced Notice of Proposed Rulemaking Relating to Prediction Markets”, Release No. 9194-26, Mar. 12, 2026.
- Commodity Futures Trading Commission, “Further Definition of “Swap” To Exclude Casino-Style Gambling Products”, interim final rule, 91 Fed. Reg. 65969, Oct. 19, 2026.
- Brownstein Hyatt Farber Schreck, “Commodity Futures Trading Commission Issues Two Rulemakings in Response to the Sixth and Ninth Circuit Courts of Appeals”, client alert, Oct. 28, 2026.
- BettorToken, “Risk Disclosures”, effective April 2026.
- Thomson Reuters Checkpoint, “IRS silence on prediction market winnings to cause confusion as World Cup begins”, June 16, 2026.
- White & Case, “Tax implications of predictions markets transactions: things to consider”, Mar. 16, 2026.
- DeFi Rate, “Prediction Market Lawsuit Tracker”, captured Nov. 4, 2026.
- Gambling.com, “Red Sox Promote Kalshi As Massachusetts Ban Stays In Force”, Aug. 25, 2026.
Your counsel decides. This page is educational and is not legal advice.
It summarizes public sources as of November 4, 2026, may contain errors or omissions, and may not reflect developments after that date. It does not say or imply that participation is permitted for any institution or in any state. The regulatory treatment of sports-related event contracts is unsettled. It is the subject of ongoing rulemaking, administrative proceedings, litigation, and state-level challenge, and the outcome of those matters cannot be predicted.
The Prime Partnership describes a proposed commercial partnership and is presented for discussion purposes only. It is not an offer to sell or a solicitation to buy securities or any other instrument. Structure, legal characterization, tax and securities treatment are subject in all respects to definitive documents and review by counsel for both parties, which control in all respects. Prediction-market trading involves substantial risk, including the risk of total loss. Nothing on this page describes or projects returns.
BettorToken Holdings LLC is not registered with the SEC or CFTC in any capacity and is not a broker-dealer or investment adviser. Financial records are maintained internally and are not audited or attested by an independent accountant.