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Prediction Markets

Ohio Orders 10 Prediction Markets to Stop Sports Contracts a Week After Its Sixth Circuit Win

Antonina TupikovaBy Antonina Tupikova · Founder, iGaming Times3 min read
Ohio Orders 10 Prediction Markets to Stop Sports Contracts a Week After Its Sixth Circuit Win

The Ohio Casino Control Commission has told Polymarket, Robinhood, Coinbase and seven other platforms to stop offering sports event contracts to Ohioans and confirm it in writing within 14 days. Kalshi, the company that lost in the Sixth Circuit, did not get a letter: its $5 million penalty case is already under way.

  • The Ohio Casino Control Commission sent cease-and-desist letters dated Friday 2 October to Coinbase, Gemini Titan, Moomoo Financial, Novig, Plus500US, Polymarket, ProphetX, Robinhood Derivatives, Underdog and Webull Financial, ordering each to stop offering sports event contracts to people in Ohio
  • Each recipient must notify the commission in writing within 14 days that it has complied; the letters warn of "administrative, civil, nuisance, or criminal actions" and say unlicensed sports gaming is a felony under Ohio law
  • The letters rely on the Sixth Circuit's 25 September ruling that the Commodity Exchange Act "neither applies to these sports event contracts nor preempts Ohio's sports gaming law"
  • Robinhood's is its second letter: the commission first wrote on 31 March 2025, then held enforcement in abeyance while Kalshi's federal case ran its course
  • The letters are dated four days after Governor Mike DeWine promised to "enforce the law"; our report on his remarks said no new commission step had been announced, but the letters had gone out on 2 October; Kalshi, already facing a proposed $5 million penalty, was not among the recipients

Ohio's Regulator Turns the Sixth Circuit Ruling Into Ten Letters

The Ohio Casino Control Commission (OCCC) has ordered ten prediction-market platforms and brokers to stop offering sports event contracts in the state. The letters, each dated 2 October 2026 and signed by Interim Executive Director Andromeda Morrison, went to Coinbase, Gemini Titan, Moomoo Financial, Novig and its exchange Ludlow Exchange, Plus500US Financial Services, Polymarket (addressed to PM US Tech, QC Tech LLC), ProphetX, Robinhood Derivatives, Underdog Predict and Underdog Exchange DCM, and Webull Financial. InGame reported the letters on Monday and published them in full.

Nine of the letters follow the same template, concluding: "Plainly stated, [the company] is operating online sports gaming." Offering it without a commission licence, they say, "also constitutes bookmaking or facilitating bookmaking in violation of the Ohio Criminal Code".

The demand, set in bold in each letter, reaches beyond the exchanges themselves. Using Underdog's letter as the example, the commission "demands that Underdog cease and desist from offering, participating in offering, or facilitating those who offer sports event contracts in Ohio. This includes soliciting or accepting orders for sports event contracts listed on DCMs from persons located in Ohio, as well as operating an FCM or DCM that offers sports event contracts to persons located in Ohio." Each recipient must notify the commission in writing "no later than fourteen (14) days following the date of this letter", which falls on 16 October.

iGaming glossary: 430+ terms explained.

The letters say unlicensed sports gaming is a felony, that the companies' websites are "a nuisance under Ohio law that is subject to abatement", and that the commission can impose a civil penalty "including for an amount equal to the money or value of the property" each company "has unlawfully obtained or retained" in Ohio. It may also pursue each company's "officers, directors, and holding or parent companies, as applicable".

The legal basis is last month's appellate decision. "On September 25, 2026, the U.S. Court of Appeals for the Sixth Circuit held that the Commodity Exchange Act neither applies to these sports event contracts nor preempts Ohio's sports gaming law," the letters say, citing KalshiEX LLC v. Schuler, No. 26-3196. "This decision makes clear that Ohio's sports gaming laws apply to" each recipient's contracts.

Robinhood Gets Its Second Letter, and Kalshi None

The tenth letter, addressed to Robinhood's lawyer Kevin J. Orsini of Cravath, "is hereby reasserting" a notice first sent on 31 March 2025, when the commission wrote to Kalshi, Robinhood and Crypto.com. According to the new letter, Robinhood replied at the time that it was a futures commission merchant (FCM) offering contracts traded on Kalshi, and "maintained that the sports event contracts were swaps and that the Commodity Exchange Act ('CEA') preempted Ohio's sports gaming laws". When Kalshi sued the commission on the same grounds, the commission "held in abeyance its enforcement efforts to provide an opportunity for the federal courts for the Southern District of Ohio and the Sixth Circuit to rule".

The letter quotes Robinhood's website as offering sports contracts "through either KalshiEX LLC, ForecastEX, LLC or Rothera Exchange and Clearing LLC", and says "it appears that Robinhood and Susquehanna International Group ('SIG') jointly operate" Rothera, a designated contract market (DCM). The demand therefore covers Robinhood "either as an FCM or joint owner of a DCM".

Kalshi received no letter. InGame noted that, having sued the state and lost, it did not appear to need one. The commission issued a notice of intent to impose a $5 million civil penalty on Kalshi in April, and Kalshi is contesting that in the Franklin County Court of Common Pleas. Crypto.com, the third recipient of the March 2025 letters, is not among the ten either.

Exchanges and Brokers Alike

The list mixes federally registered exchanges with the brokers that route customers to them. CFTC records show Gemini Titan, Ludlow Exchange, ProphetX, Polymarket US's exchange QCX and the former Aristotle Exchange DCM, which Underdog bought in March 2026, as designated contract markets. Coinbase, Plus500US, Moomoo and Webull offer Kalshi-listed contracts through brokerage arms, according to the companies' announcements and press reports. Underdog had already sued Ohio pre-emptively in September, one of five states it took to court before any order arrived. iGaming Times found no public response to the letters from any of the ten by Monday afternoon.

iGaming glossary: 430+ terms explained.

Ohio Is Pursuing Kalshi's Distribution Even Without Writing to Kalshi

Half of the recipients reach customers wholly or partly through Kalshi's order book: Coinbase, Plus500US, Moomoo, Webull and Robinhood. The demand to stop "soliciting or accepting orders for sports event contracts listed on DCMs" is aimed squarely at that model. Ohio cannot easily shut an exchange that answers to a federal regulator, but it can make every broker serving Ohio residents choose between geofencing the state and litigating. Robinhood stopped offering sports contracts in Michigan while the Sixth Circuit decided, and Ohio, by its own account, paused enforcement against it on the same logic. With the ruling in hand, the pause is over.

The Sixth Circuit Ruling Is Preliminary, and the Letters Treat It as Settled

The appellate decision affirmed the denial of a preliminary injunction; it found Kalshi unlikely to succeed, not that Ohio has won. Kalshi has until 9 October to seek rehearing, its response to New Jersey's Supreme Court petition is due on 9 November, and a federal judge in Chicago ruled the other way for Kalshi, Coinbase and the CFTC on the same day the letters went out, finding that championship contracts are likely swaps and that Illinois' licensing rules are likely preempted. That ruling binds no court in the Sixth Circuit, but shows the question is far from closed. Recipients that comply now concede the market; those that do not are betting that Ohio will not prosecute a federally registered exchange before the Supreme Court speaks.

The Commission's Fight Is Also About Its Licensees

Ohio has been among the most direct of the states on sports contracts. It left the national problem gambling council over Kalshi's donation, and in August 2025 warned its licensed sportsbooks that relationships with unlicensed providers could call their licences into question, according to InGame. Those sportsbooks pay a 20% tax and may serve only over-21s; none of the ten holds an Ohio licence. The responses due on 16 October will show whether the ruling has changed behaviour, or only the tone of the correspondence.

Ohio has turned an appellate win into ten letters in a week, one more than Connecticut sent in September. Whether the letters work depends less on their wording than on whether the commission follows them with the penalties they describe.

Sources

Citations and primary documents this article references. Captured at the time of writing.

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