"Developing [geolocation] capability would, at minimum, take months and cost tens of millions of dollars. Kalshi’s only option to comply during the appeal would be to terminate trading for its 17,000-plus users in Maryland, many of whom have open investments on the platform."

Blanche Lincoln, a lobbyist for Kalshi, has filed a CA3 amicus brief in support of Kalshi purporting to explain the legislative history of the 2010 CEA amendment. Nice try. Not contemporaneous. Post-enactment statements are meaningless, especially when they are tainted as here.