Missouri's 30-day deadline for six prediction markets has passed. Two of them sued the state the day before; the other four have said nothing in public.
What the letters asked for, and what Missouri got
The letters were short on legal citation and long on the state's own framework. Missouri voters approved Amendment 2 in November 2024, sports betting went live on December 1, 2025, and the attorney general's position is that a sports event contract is a sports bet by another name, which means unlicensed sports wagering under Missouri law. The office said five of the six recipients either let people under 21 trade or lacked adequate safeguards against it; Novig, whose rulebook sets a 21-and-over floor, was the exception. Hanaway's quote, repeated in every report since, was that companies "cannot repackage sports bets as 'event contracts' to avoid Missouri law." The remedy offered was a licence from the Missouri Gaming Commission, the 10 percent tax on gross receipts that licensed books pay, and age verification at 21.
Thirty days later the state has two lawsuits and no announced compliance. That is roughly the pattern Ohio produced a day earlier, when its own deadline for ten platforms passed with one documented exit, and it is the pattern every cease-and-desist letter has produced since Nevada's in March 2025: brokers that route to someone else's exchange sometimes geofence, exchanges that run their own order books sue. Novig and OG are both exchanges. Robinhood is a broker that has already agreed to geofence Michigan and routes some football contracts through Crypto.com's exchange, which is now suing Missouri on its own account. Kalshi has geofenced only where a court ordered it to.
| Recipient | Letter date | Position at the deadline | Source |
|---|---|---|---|
| Novig (Ludlow Exchange LLC) | Sep 17 | Sued Hanaway, MGC executive director Michael Lear and chair Jan Zimmerman, E.D. Mo. No. 4:26-cv-01780, Oct 16 | Law360, Covers, DeFi Rate docket check |
| Crypto.com / OG.com (North American Derivatives Exchange) | Sep 16 or 17 | Sued the same officials, W.D. Mo. No. 4:26-cv-00969, Oct 16 | Prediction News, Covers, DeFi Rate docket check |
| Kalshi | Sep 16 or 17 | First to respond; AG's office said Oct 2 it was in "ongoing discussions"; no public change | Spectrum News |
| Polymarket, Robinhood, Underdog | Sep 16 or 17 | No public response found | Searches through Oct 18 |
Two suits, two districts, one judge avoided
Novig's complaint is the more detailed of the two in public reporting. It argues that its sports event contracts are "quintessential swaps" within the Commodity Exchange Act's definition, that the CFTC's jurisdiction over swaps traded on a designated contract market is exclusive, and that Missouri's gambling and sports wagering laws are preempted as applied. It adds a point specific to its business model: because Novig matches users against each other and takes no side of any trade, a Missouri licence that confined its order book to Missouri residents would destroy the thing being licensed. It asks for preliminary and permanent injunctions against enforcement and a declaration of preemption, and it says Missouri's threats expose it to criminal liability and to penalties under the state's consumer protection and public nuisance statutes. Novig, which launched its sports exchange in August 2026 and reported $125 million of volume in its first week, has not sued any other state.
The Crypto.com case is filed by North American Derivatives Exchange, Inc., the entity behind the CFTC-designated exchange Crypto.com bought in 2022 and now operates as Crypto.com Derivatives North America, doing business as OG.com Prediction Markets. OG launched on February 3, 2026 as Crypto.com's prediction brand with Nick Lundgren, Crypto.com's chief legal officer, as its chief executive. The first public record of the Missouri case was a pro hac vice motion on October 16; the complaint, per DeFi Rate's review of the docket, seeks declaratory and injunctive relief against enforcement of the state's gambling laws against sports prediction markets. Daniel Wallach, who first flagged both filings, noted that the two plaintiffs chose different districts, Novig the Eastern in St. Louis and OG the Western in Kansas City, so that the cases would not be assigned to the same judge. That is a hedge, not a coincidence: two district judges give two chances at a preliminary injunction and two possible appeals to the Eighth Circuit.
Why the Eighth Circuit is the point
Every cease-and-desist fight so far has been decided, in practice, by which appeals court sits above the state. The Third Circuit ruled for Kalshi against New Jersey in April; the Ninth ruled for Nevada in August and for two California tribes in September; the Sixth ruled for Ohio and Tennessee on September 25. Missouri is in none of them. The Eighth Circuit, which also covers Minnesota, Iowa, Nebraska, the Dakotas and Arkansas, has one prediction market matter in its district courts that matters: Judge Katherine Menendez's July 27 injunction against Minnesota's felony ban, won by the United States, Kalshi and Polymarket US, which Minnesota has not publicly appealed. There is no circuit precedent either way. A district judge in St. Louis or Kansas City can read the Third Circuit's reasoning or the Sixth's and is bound by neither.
That is why Novig and OG filed where they did rather than waiting to be sued in state court. Kalshi's experience in Kentucky, where a federal magistrate recommended on October 14 that the state's enforcement suit be sent back to Franklin Circuit Court, shows what happens when the state files first in a circuit that has already ruled against the platforms. Missouri's attorney general can still sue in state court, and a Missouri judge would not be bound by anything a federal district court says about preemption until the Eighth Circuit speaks. But the platforms have now put the question in front of two federal judges first, with the Minnesota ruling as the only in-circuit authority. For a company whose national business depends on the preemption argument, a circuit with no bad precedent is the best venue left.
What the silence from the other four means
Kalshi is the recipient with the most at stake and the least to say. The attorney general's office described itself as in "ongoing discussions" with the company on October 2, and Kalshi's head of research, Nicole Kagan, spent the following week telling Missouri media that the exchange is "not the house" and does not profit when users lose. That is the argument Kalshi has made in every state; what it has not done in Missouri is sue, which it did pre-emptively in Nevada, New Jersey, Maryland, Ohio and Tennessee in 2025, or geofence, which it has done only under court order. A company that is negotiating does not file on the deadline. A company that expects to be sued in state court and sent to the Eighth Circuit may prefer to let Novig and OG test the water in federal court first.
Polymarket's position is harder to read because Missouri's letter went to QCX LLC, its CFTC-designated US exchange, which is already a defendant in New York and Kentucky and a plaintiff against Massachusetts. Robinhood has settled with Michigan and said nothing about Missouri. Underdog, which has sued seven states including Tennessee on October 13, has not added Missouri to the list. None of the four has announced a geofence, and Missouri has not published any responses it received. The state's leverage is limited by its own letters, which threatened "enforcement action" rather than a quantified penalty, and by the fact that its licensed sportsbooks had paid $11 million in tax by September against a first-year target of $25 million, a gap the state would rather fill with licence applications than with a lawsuit that could take two years to reach the Eighth Circuit.
The scoreboard after two deadlines in two days
| State | Deadline | Recipients | Suits filed by platforms | Announced exits |
|---|---|---|---|---|
| Ohio | Oct 16 | 10 | 0 | 1 (Plus500US) |
| Missouri | Oct 16 and 17 | 6 | 2 (Novig, Crypto.com/OG) | 0 |
| Tennessee | Immediate (Oct 9 letter) | 1 (Underdog) | 1 | 0 |
Three states used the Sixth Circuit's September 25 ruling, or the general climate it created, to write letters this autumn, and the three sets of letters produced one exit, three lawsuits and a great deal of silence. The difference between Ohio and Missouri is the court above them. Ohio's letters are backed by a circuit decision in its favour, so the platforms that stayed are betting on the Supreme Court or on a rehearing. Missouri's are backed by nothing yet, so the platforms that moved went to federal court to try to create the precedent before the state could. The next dates to watch are the preliminary injunction motions in St. Louis and Kansas City, Kalshi's Supreme Court brief on November 9, and whatever Missouri files, if anything, against the four companies that let the clock run out.
Method and limits
Compliance status is from public reporting through the morning of October 18, 2026; we have not tested any platform from a Missouri IP address and the attorney general's office has not published the responses it received. Case numbers and district assignments are from DeFi Rate's docket review of October 16 and from Prediction News' report of the Pacermonitor entry; we have not read either complaint in full, and Novig's claims are summarised from Crypto Times and Covers, both of which relied on the filing and on Daniel Wallach's posts. The identification of the Western District plaintiff as Crypto.com's exchange rests on Covers' report that Crypto.com filed there and on the entity's own history as the exchange Crypto.com acquired in 2022; the complaint's caption uses the legal name North American Derivatives Exchange, Inc. The 10 percent tax, the under-21 claim and the Hanaway quotations are from the attorney general's press release. Tax figures are from the Missouri Gaming Commission's executive director as reported by KFVS on September 9. Nothing here is legal, financial or betting advice.
Frequently asked questions
Did the prediction markets comply with Missouri's deadline?
Not in any public way. The thirty-day windows in the attorney general's September 16 and 17 letters closed on October 16 and 17. Novig and Crypto.com's OG exchange sued Missouri in federal court on October 16 rather than comply. Kalshi, Polymarket, Robinhood and Underdog have not announced a geofence, a licence application or a lawsuit, and the attorney general's office has not published their responses.
Who did Novig sue and where?
Ludlow Exchange LLC, which operates Novig, sued Attorney General Catherine Hanaway, Missouri Gaming Commission executive director Michael Lear and chair Jan Zimmerman in their official capacities in the U.S. District Court for the Eastern District of Missouri, case 4:26-cv-01780, on October 16, 2026. It seeks preliminary and permanent injunctions and a declaration that Missouri's gambling laws are preempted as applied to its sports event contracts.
What is the Crypto.com lawsuit?
North American Derivatives Exchange, Inc., the CFTC-designated exchange Crypto.com acquired in 2022 and now runs as OG.com Prediction Markets, sued the same Missouri officials in the Western District of Missouri, case 4:26-cv-00969, also on October 16. It asks for declaratory and injunctive relief against enforcement of Missouri gambling law against sports prediction markets. Filing in a different district from Novig means the two cases will have different judges.
Why does the Eighth Circuit matter here?
Missouri's federal appeals court has not ruled on whether sports event contracts are swaps or whether the Commodity Exchange Act preempts state gambling law, unlike the Third Circuit (for Kalshi), the Ninth Circuit (for Nevada) and the Sixth Circuit (for Ohio and Tennessee). The only decision in the circuit is a July 2026 Minnesota district court injunction that went the platforms' way. A Missouri district judge is bound by none of the other circuits.
What penalty did Missouri threaten?
The attorney general's letters and press release said failure to comply would bring "enforcement action by the State of Missouri" and demanded that operators either stop or obtain a Missouri Gaming Commission licence, pay the 10 percent tax on sports betting gross receipts and verify that no one under 21 can wager. Unlike Ohio, Missouri did not quantify a civil penalty in its public statements.
Related
- Is Kalshi legal in Missouri?
- Ohio's October 16 deadline passed: who complied, who did not
- Is Kalshi legal in your state? The 50-state tracker
- Prediction market court calendar: every deadline ahead
- Odds converter: cent prices, American odds and the vig
Sources
- Covers, Novig, Crypto.com sue Missouri after cease-and-desist order, 16 October 2026.
- Law360, Novig sues Missouri to shield sports contracts, 16 October 2026.
- Prediction News, Nadex subsidiary OG.Com Prediction Markets sues Hanaway et al in Missouri federal court, 16 October 2026, for the Western District case number.
- The Crypto Times, Novig sues Missouri officials ahead of prediction market deadline, 17 October 2026, for the defendants, claims and relief sought.
- DeFi Rate, Prediction market lawsuit tracker, docket entries of 16 October 2026, for both case captions and numbers.
- Missouri Attorney General, Hanaway orders unlicensed prediction markets to cease and desist unlawful sports wagering, September 2026, for the six recipients, the under-21 claim, the 10 percent tax and the quotations.
- Spectrum News, Kalshi first prediction market firm to respond to Missouri order, 2 October 2026, for the "ongoing discussions" statement.
- St. Louis Public Radio, As Missouri steps up prediction market scrutiny, Kalshi says it is different from sportsbooks, 5 October 2026.
- KFVS, Missouri is entering its first full NFL season with legal sports betting, 9 September 2026, for the $11 million collected against a $25 million target.
- Covers, Crypto.com unveils prediction platform experience OG, 3 February 2026, for OG's launch and leadership.
18+ only. This page reports published regulatory letters, court filings and public statements. It is not legal, financial or betting advice. If gambling stops being fun, help is available at 1-800-GAMBLER.