Four Prediction Exchanges Seek Federal Restraints After Missouri Cease-and-Desists

Underdog Exchange DCM, Inc. filed suit in the Western District of Missouri on 8 November 2026 and that same evening submitted a docket entry described as a "Preliminary Injunction." Crypto.com's North American Derivatives Exchange, Novig's Ludlow Exchange and KalshiEX also asked federal courts for interim relief between 6 and 8 November, after Missouri Attorney General Catherine Hanaway in mid-September told six prediction markets to stop offering sports event contracts in Missouri or obtain licensing and pay Missouri's 10% tax on adjusted gross revenue.

Who has sued and what they have asked for

Underdog filed Underdog Exchange DCM, Inc. v. Hanaway (No. 2:26-cv-04300) in the Central Division of the Western District of Missouri, which sits in Jefferson City, on 8 November. The case is assigned to Judge Beth Phillips; the docket shows three pro hac vice entries for lawyers and a fourth entry on Sunday evening labelled "Preliminary Injunction." The complaint and that filing were not publicly available on 9 November, so the record does not yet show the full list of defendants beyond Attorney General Hanaway, the specific claims or the precise relief sought in the preliminary-injunction entry.

North American Derivatives Exchange, Inc., which trades as OG.com Prediction Markets and is referred to in filings as Crypto.com's exchange, filed its original complaint on 16 October and added a motion for a preliminary injunction and supporting documents on 8 November in case No. 4:26-cv-00969 before Judge Greg Kays in the Western District of Missouri at Kansas City. The October complaint asked for a declaratory judgment and a permanent injunction barring Hanaway and the Missouri Gaming Commission's executive director and commissioners from enforcing Missouri gambling laws against it. Attachments listed on the docket include a declaration from its lawyer Robert A. Fumerton, a declaration from Scott Kallback, the exchange's 30 January 2025 certification of the contract category it says covers its sports contracts, and Hanaway's 16 September letter. Missouri's opposition to the motion is due on 23 November; the state's answer to the complaint is due 21 December.

Novig's Ludlow Exchange, LLC filed a motion for a preliminary injunction and a memorandum in support on 8 November in Ludlow Exchange, LLC v. Hanaway (No. 4:26-cv-01780) in the Eastern District of Missouri, St. Louis. KalshiEX filed a motion for a temporary restraining order and preliminary injunction on 6 November in KalshiEX v. Hanaway (No. 4:26-cv-01860) in the Eastern District; that motion asked District Judge Maria A. Lanahan for a hearing within 14 days. Kalshi's defendants include Attorney General Hanaway, the Missouri Gaming Commission and six commission officials.

All four exchanges received cease-and-desist letters from Hanaway's office on 16 and 17 September instructing them to stop offering sports event contracts in Missouri or obtain a Missouri Gaming Commission licence, pay a 10% tax on adjusted gross revenue and stop serving under-21s.

Litigation context and timing

Missouri moved on 5 November to consolidate Novig's case with Kalshi's in St. Louis. Folding Ludlow into Kalshi in the Eastern District would place two of the St. Louis suits before one judge. Crypto.com's case sits in Kansas City and Underdog's sits in Jefferson City, both in the Western District of Missouri but in different divisions, leaving potential for conflicting district-court rulings within the state.

Each Missouri case will be decided against the backdrop of KalshiEX v. Bird, Kalshi's appeal in its Iowa matter before the United States Court of Appeals for the Eighth Circuit. Kalshi asked the Eighth Circuit on 28 October for an extension to file its brief until 7 December, which puts a decision months away. The exchanges have signalled they do not want to wait for the Eighth Circuit because of the risk of state enforcement actions in the interim; interim relief from district judges is the only practical protection at present, which explains the cluster of preliminary-injunction and temporary-restraining-order filings in the first week of November.

Where Polymarket and Robinhood stand

Polymarket and Robinhood were also recipients of Hanaway's September letters but, as of 9 November, neither had a federal suit on the Missouri dockets. The Commodity Futures Trading Commission's guidance of 5 November on state geofencing complicates the legal calculus for exchanges considering withdrawing from a single state. That guidance makes a defence based on remaining accessible elsewhere harder under federal rules, narrowing realistic options for exchanges to either sue or wait.

What the courts will decide next

Missouri must respond to Crypto.com's preliminary-injunction motion by 23 November. Kalshi asked for an expedited hearing within 14 days of its 6 November filing. The first district-court ruling on interim relief will set an early precedent for whether a district judge in the Eighth Circuit will block state enforcement while appeals continue. Given the split of filings across the Western and Eastern Districts, consolidation motions and the pending Eighth Circuit timetable, the federal docket in Missouri is likely to determine near-term commercial and regulatory exposure for prediction markets operating in the state.

"An exchange that waits for [the Eighth Circuit] carries the risk of a state enforcement action in the meantime," the reporting in the filings and docket notes says.

The docket citations referenced in filings include CourtListener records for Underdog Exchange DCM v. Hanaway (No. 2:26-cv-04300), North American Derivatives Exchange, Inc. v. Hanaway (No. 4:26-cv-00969), Ludlow Exchange v. Hanaway (No. 4:26-cv-01780) and KalshiEX v. Hanaway (No. 4:26-cv-01860), and the Eighth Circuit KalshiEX v. Bird appeal (No. 26-2874).