In the Market for Judicial Review: Circuit Split on CFTC Preemption Makes SCOTUS a Predictable Destination

In the Market for Judicial Review: Circuit Split on CFTC Preemption Makes SCOTUS a Predictable Destination

September 1, 2026

In the Market for Judicial Review: Circuit Split on CFTC Preemption Makes SCOTUS a Predictable Destination

By: John Mikuta

The ongoing legal battle over whether the federal Commodity Futures Trading Commission (“CFTC”) or state regulators have the authority to regulate sports-related prediction markets is heating up. Last week, the U.S. Court of Appeals for the Ninth Circuit turned away a challenge by Kalshi, the largest prediction market in the United States, to the Nevada Gaming Control Board’s letter ordering it to cease and desist operations in the state of Nevada.[1]  The Ninth Circuit held that the lower court did not abuse its discretion in concluding that Kalshi was not entitled to a preliminary injunction because it did not establish a likelihood that the federal Commodity Exchange Act (“CEA”) preempts state gaming regulations. The Ninth Circuit’s ruling stands in direct…

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A Ticket to Win: Are Travel Points a Thing of Value?

August 21, 2026

A Ticket to Win: Are Travel Points a Thing of Value?

By: Abbey Block

With the end of summer drawing near, many American families may be hoping to book a last-minute getaway. Some of those travelers may be hoping to take advantage of credit card points to book their trips on the cheap. Credit card points have become a ubiquitous part of American capitalism – particularly those offered by airlines, often referred to as “travel points.” According to the…

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Advertising Prediction Markets? The CFTC Just Sent a Clear Message to Affiliates.

August 17, 2026

Advertising Prediction Markets? The CFTC Just Sent a Clear Message to Affiliates.

By: Kyra Pulliam

The Commodity Futures Trading Commission (CFTC) recently issued guidance directed to designated contract markets (DCMs) concerning the marketing and offering of event contracts. The guidance was addressed to DCMs because no swap execution facilities (SEFs) currently list event contracts. However, the CFTC’s analysis is equally applicable to futures commission merchants (FCMs) and introducing brokers (IBs), as well as the advertising affiliates and marketing partners that…

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A Bank is a Bank

August 15, 2016

A Bank is a Bank

By: Steven Eichorn

Do you remember when I wrote about how a federal district court had ruled that an online poker account was akin to a bank account and should therefore be subject to FBAR reporting? It seemed nonsense to me at the time—and I also worried about whether the court’s expanded definition of a “financial institution” would be applied to other types of escrow accounts beyond gaming….

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Pokémon Go Craze: Battle, Train, Win – But No Betting

July 19, 2016

Pokémon Go Craze: Battle, Train, Win – But No Betting

By: Jeff Ifrah

We are living in a virtual (or perhaps “augmented”) Pokémon explosion. You can’t get away from news of public craze over Pokémon Go. Players young and youngish have made the game today’s most popular app, outpacing Twitter and Tinder download rates. In less than ten days from its release, estimates are that almost 26 million Americans are playing the game. What’s more, SurveyMonkey intelligence predicts…

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New Concerns Over Esports Betting; Jeff Ifrah Responds

July 14, 2016

New Concerns Over Esports Betting; Jeff Ifrah Responds

By: Ifrah Law

*photo obtained from https://gameora.tumblr.com/ In light of unprecedented controversy over the legality of “skin betting” and eSports gambling, Jeff Ifrah and two other attorneys took to Reddit to answer questions from players, fans, and professionals. Together with Bryce Blum and Ryan Morrison, Ifrah participated in an AUA (“Ask Us Anything”) thread on July 5, 2016—just after the news about Trevor “TmarTn” Martin, Thomas “Syndicate” Cassell,…

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Eric Schneiderman’s Losing Lineup

June 27, 2016

Eric Schneiderman’s Losing Lineup

By: Jeff Ifrah

Defenders of DFS like to point out that it is skill-predominant. If the same can be said for public prosecution, then New York Attorney General Eric Schneiderman has been fielding one hell of a losing lineup. Between the two of them, DraftKings and FanDuel dominated the DFS space, and they still did after Schneiderman dumped near-identical complaints at their doorsteps. But now their well-being was…

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How the Gray Bill Tries to Keep Out Bad Actors

May 24, 2016

How the Gray Bill Tries to Keep Out Bad Actors

By: Steven Eichorn

The iGaming world is excited about Assembly Bill 2863—better known as the Gray bill because of lead sponsor Adam Gray—which would legalize and regulate intrastate online poker in California. A few weeks ago, the bill unanimously cleared the Assembly’s Governmental Organization Committee; now it looks set to clear the Appropriations Committee as well. Those are promising signs—but we’ve seen this before. Last year, a similar…

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Articles and Presentations by Our Firm Attorneys

In the Market for Judicial Review: Circuit Split on CFTC Preemption Makes SCOTUS a Predictable Destination

In the Market for Judicial Review: Circuit Split on CFTC Preemption Makes SCOTUS a Predictable Destination
By: John Mikuta

A Ticket to Win: Are Travel Points a Thing of Value?

A Ticket to Win: Are Travel Points a Thing of Value?
By: Abbey Block

Advertising Prediction Markets? The CFTC Just Sent a Clear Message to Affiliates.

Advertising Prediction Markets? The CFTC Just Sent a Clear Message to Affiliates.
By: Kyra Pulliam

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