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---
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created: 2026-10-13
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updated: 2026-10-13
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title: 1789 Capital
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aliases:
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- 1789 Capital
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- 1789 Capital LP
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- 1789 Capital Fund I
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- 1789 Capital Fund I, LP
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- 1789 Capital Management
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category: "Private Organization"
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tags:
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- Organization
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- 1789Capital
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- VentureCapital
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- Polymarket
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- DonaldTrumpJr
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- RebekahMercer
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- AntiESG
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- PrivateEquity
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- PredictionMarkets
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summary: "1789 Capital is a Palm Beach investment firm that listed Omeed Malik, Rebekah Mercer and Christopher Buskirk in 2023, added Donald Trump Jr. as a partner in November 2024 and invested in Polymarket in 2025."
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relations:
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- type: founded
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with: "[[Omeed Malik]]"
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reverse: true
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role: "co-founder and president"
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fn: 6
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- type: founded
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with: "[[Christopher Buskirk]]"
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reverse: true
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role: "co-founder and chief investment officer"
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fn: 5
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- type: director_of
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with: "[[Rebekah Mercer]]"
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reverse: true
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start: 2023-02-09
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role: "listed as executive officer, director, promoter and managing member of the general partner of 1789 Capital Fund I, LP (Form D, February 2023); listed as manager of 1789 Capital Fund I GP, LLC (Forms D, June 2024); not listed in the Forms D/A of October and December 2025"
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fn: 1
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- type: partner_of
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with: "[[Donald Trump Jr.]]"
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reverse: true
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start: 2024-11
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role: "partner"
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fn: 6
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- type: funded
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with: "[[Polymarket]]"
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start: 2025-08-26
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role: "strategic investment, terms undisclosed; Axios reported double-digit millions of dollars"
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fn: 8
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---
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1789 Capital is an investment firm based in Palm Beach, Florida, whose first fund notice with the Securities and Exchange Commission was filed in February 2023 and whose stated mission is "patriotic capitalism." [[Donald Trump Jr.]] became a partner in November 2024. The firm invested in [[Polymarket]] in August 2025.
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### Fund Filings and Related Persons
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[[1789 Capital Fund I, LP]] filed a Form D on February 9, 2023, reporting a first sale of securities on January 31, 2023, an offering of 100,000,000 dollars and 10,000,000 dollars sold to one investor. The form lists three related persons, [[Omeed Malik]], [[Rebekah Mercer]] and Christopher Buskirk ([[Christopher Buskirk]]), each as executive officer, director and promoter, and each with the clarification "Managing Member of the General Partner."[^1]
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Two Forms D filed on June 10, 2024, for 1789 Capital BH, LP (9,700,000 dollars sold) and 1789 Capital Co-Invest I, LP (2,162,000 dollars sold), list Malik, Buskirk and Mercer as executive officers, each with the clarification "Manager of 1789 Capital Fund I GP, LLC, its General Partner," together with two further executive officers.[^2]
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A Form D/A for Fund I filed on October 21, 2025 lists Malik and Buskirk as executive officers, each with the clarification that he is "a principal of the general partner of the issuer." Mercer is not listed. The offering amount is entered as "Indefinite," 270,514,000 dollars is reported sold to 71 investors, and the fund type has changed from "Private Equity Fund" to "Other Investment Fund." A second Form D/A filed on December 15, 2025 repeats the same two related persons and the same sales figures.[^3]
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Forty-one Form D filings by entities that include 1789 Capital BH, Co-Invest I, Odyssey, Matrix (I, II and III), Nirvana (I and II), Treehouse (I and II), Lakehouse (I, II and III), Inception (I to IV), Halo (I and II), Artemis, Dawn, Blaze, Oracle, Patriot, Valence, Starr, MYNT, CHPS (I and II), RO, SI, Fund II-A and Fund II-B, 1789 Parallel Fund I and 1789-Pacific Alliance US Growth Equity Fund are on file, dated from February 9, 2023 to October 13, 2026.[^4]
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### Origins and Principals
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Malik, a former investment banker in New York, and Buskirk, an Arizona businessman, formed the firm; Reuters described Buskirk as a confidant of [[Peter Thiel]] and of [[JD Vance]]. Thiel gave millions of dollars to a political committee that paid consulting fees to a Buskirk company, and Thiel introduced Vance to Buskirk, according to Reuters. Buskirk and Vance co-founded the [[Rockbridge Network]] donor organization in 2019.[^5] Fortune described Malik as the founder of the bank [[Farvahar Partners]], and described the firm in November 2024 as an "anti woke" equity firm funded modestly, with 150 million dollars to invest.[^6]
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On December 3, 2024 Malik resigned from the board of [[PSQ Holdings]], the parent of [[PublicSquare]], on the day that company's board appointed Trump Jr. as a director.[^7]
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### Donald Trump Jr. as Partner
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Trump Jr. announced on Sunday, November 10, 2024, before a crowd of donors, that he would join 1789 Capital as a partner, as the New York Times reported; Fortune added that the partnership meant he would not take a formal role in his father's administration.[^6] Reuters described [[Donald Trump]]'s election and the addition of Trump Jr. that month as the "two strokes of fortune" behind the firm's growth, and wrote that with him the fund "has gained extraordinary access to political power."[^5]
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Reuters reported that assets had passed 1 billion dollars, against about 150 million dollars under management the year before, and that investments typically ranged from 5 million to 50 million dollars. Two people with knowledge of the firm's deals told Reuters that the portfolio included [[SpaceX]], [[xAI]] and [[Neuralink]], that the deals came together after Malik met [[Elon Musk]] during the campaign, and that further stakes included [[Perplexity AI]], [[Juul Labs]] and the defense manufacturing startup [[Hadrian]]. The partners described a goal of a "parallel economy" of businesses, media outlets and political organizations serving the America First movement. A person close to Trump Jr. told Reuters that he does not discuss his business interests with his father or ask for government favors. A 1789 spokesperson said the fund "maximizes transparency and compliance."[^5]
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Fox Business reported that the 1789 Capital Growth Equity Fund grew from 200 million dollars at the start of 2025 to 2 billion dollars through December 31, 2025 and closed to new investors, and that a 1789 real estate fund drew 1 billion dollars within months.[^8]
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### Polymarket
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On August 26, 2025 Polymarket announced that 1789 Capital had made a strategic investment in the company and that Trump Jr. had joined its advisory board; the terms were not disclosed. Trump Jr. said: "I am pleased that 1789 Capital is investing in Polymarket and am honored to join the company's advisory board." [[Shayne Coplan]] said the investment "marks a milestone for Polymarket."[^9] Axios reported that the investment was in the double-digit millions of dollars.[^10] Trump Jr. had advised the rival exchange [[Kalshi]] since January 2025, and his spokesman said the Polymarket role "doesn't change anything regarding Don's role with Kalshi."[^10]
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In October 2025, after the [[Intercontinental Exchange]] investment announcement, Coplan disclosed a 150 million dollar round in 2025 led by [[Founders Fund]] at a 1.2 billion dollar valuation; the investors listed included Ribbit, Valor, Point72 Ventures, SV Angel, "1789" and 1confirmation.[^11] In September 2026 Covers reported, citing the Wall Street Journal, that 1789 Capital had invested about 200 million dollars in Polymarket in total and was investing 300 million dollars in a 1 billion dollar round.[^12]
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### Congressional Inquiry
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On August 26, 2026 Representative [[Jamie Raskin]], ranking member of the House Judiciary Committee, sent a letter to Trump Jr., Malik (as president) and Buskirk (as chief investment officer) asking how the firm's assets grew "from $150 million in assets under management to an astonishing $3 billion." The letter names four portfolio companies as examples of investments followed by federal contracts or decisions: Vulcan Elements, [[Anduril Industries]], Juul and Polymarket. On Polymarket the letter states that the Department of Justice closed its probe and the CFTC signed off on an acquisition, and that "a few short weeks later, it was revealed that 1789 Capital had already acquired a sizable stake." Raskin requested a list of investments, communications with federal officials and contractors, and documents on the hiring of Trump Jr., with answers due September 9. Counsel for the firm, AJ Merton, called the accusations "unsubstantiated talking points."[^13]
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### Footnotes
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[^1]: Form D, 1789 Capital Fund I, LP (CIK 0001965234), accession 0001965234-23-000001, filed February 9, 2023: year of incorporation 2022; first sale January 31, 2023; offering 100,000,000 dollars; sold 10,000,000 dollars to one investor; related persons Omeed Malik, Rebekah Mercer and Christopher Buskirk, each "Executive Officer, Director, Promoter," relationship clarification "Managing Member of the General Partner." https://www.sec.gov/Archives/edgar/data/1965234/000196523423000001/primary_doc.xml
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[^2]: Forms D filed June 10, 2024: 1789 Capital BH, LP (CIK 0002025959), accession 0002025959-24-000001, https://www.sec.gov/Archives/edgar/data/2025959/000202595924000001/primary_doc.xml ; 1789 Capital Co-Invest I, LP (CIK 0002026273), accession 0002026273-24-000001, https://www.sec.gov/Archives/edgar/data/2026273/000202627324000001/primary_doc.xml
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[^3]: Forms D/A, 1789 Capital Fund I, LP: accession 0001965234-25-000002, filed October 21, 2025, https://www.sec.gov/Archives/edgar/data/1965234/000196523425000002/primary_doc.xml ; accession 0001965234-25-000004, filed December 15, 2025, https://www.sec.gov/Archives/edgar/data/1965234/000196523425000004/primary_doc.xml Both list Omeed Malik and "Christoper" Buskirk (as spelled in the filings) as executive officers, "a principal of the general partner of the issuer"; total offering "Indefinite"; amount sold 270,514,000 dollars; 71 investors.
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[^4]: SEC EDGAR, Form D filings under the name "1789 Capital," as of October 13, 2026 (41 filings). https://efts.sec.gov/LATEST/search-index?q=%221789%20Capital%22&forms=D
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[^5]: Reuters, "Trump-linked venture fund 1789 Capital tops US$1 billion in assets," September 8, 2025, as carried by BNN Bloomberg. https://www.bnnbloomberg.ca/business/2025/09/08/trump-linked-venture-fund-1789-capital-tops-us1-billion-in-assets/
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[^6]: "Donald Trump Jr. is joining a venture capital firm that focuses on conservative audiences," *Fortune*, November 12, 2024, citing the *New York Times*. https://www.fortune.com/2024/11/12/donald-trump-jr-venture-capital-1789-capital
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[^7]: PSQ Holdings, Inc., Form 8-K filed December 4, 2024, Item 5.02 (accession 0001213900-24-105264): Malik's resignation from the board effective December 3, 2024; appointment of Willie Langston and Donald J. Trump, Jr. as directors the same day. https://www.sec.gov/Archives/edgar/data/1847064/000121390024105264/ea0223566-8k_psq.htm
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[^8]: "Patriotic Trump Jr.-backed firm sees assets soar, rolls out real estate fund," *Fox Business*. https://www-ak-ms.foxbusiness.com/markets/trump-jr-backed-investment-fund-explodes-200m-2b-single-year-closing-doors
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[^9]: Polymarket announcement of August 26, 2025, as reported in "Donald Trump Jr. invests in Polymarket and joins advisory board," *The Block*, August 26, 2025, https://www.theblock.co/post/368292/donald-trump-jr-invests-in-polymarket-and-joins-advisory-board ; and in "Donald Trump Jr joins Polymarket advisory board after his VC firm makes strategic investment," *CryptoSlate*, as carried by Yahoo Finance, https://finance.yahoo.com/news/donald-trump-jr-joins-polymarket-175527312.html
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[^10]: "Donald Trump Jr. announces role at Polymarket," *Front Office Sports*, August 2025, quoting Axios ("double-digit millions of dollars") and a spokesman for Trump Jr. https://frontofficesports.com/article/donald-trump-jr-kalshi-polymarket/
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[^11]: "Polymarket discloses past funding rounds totaling $205 million before $2 billion ICE investment," *The Block*, October 2025. https://www.theblock.co/post/373783/polymarket-discloses-past-funding-rounds-totaling-205-million-before-2-billion-ice-investment
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[^12]: "Trump Jr.'s Firm Invests $300 Million into Polymarket," *Covers*, September 1, 2026, citing the *Wall Street Journal*. https://www.covers.com/industry/trump-jrs-firm-invests-300-million-dollars-into-polymarket-sept-1-2026
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[^13]: Jessica Corbett, "Suspecting 'Insider' Dealings and 'Corruption,' Raskin Probes Donald Trump Jr.'s Venture Capital Firm," *Common Dreams*, August 27, 2026, reporting the letter sent August 26, 2026 and the statement of counsel to MS NOW. https://www.commondreams.org/news/don-jr-corrupt
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with: "[[Thinking Machines Lab]]"
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start: 2025-07
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role: "led the seed round"
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fn: 4
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fn: 9
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- type: funded
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with: "[[Safe Superintelligence]]"
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start: 2024-09
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fn: 5
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fn: 10
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- type: funded
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with: "[[Worldcoin]]"
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start: 2023-05
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role: "co-investor, Series C; co-lead, 2025 token sale"
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fn: 6
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fn: 11
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- type: funded
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with: "[[Nash (company)]]"
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start: 2021-09
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role: "seed investor, fall 2021; co-founders Mahmoud Ghulman and Aziz Alghunaim"
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fn: 13
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fn: 18
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- type: funded
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with: "[[Nash (company)]]"
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start: 2022-07
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role: "led Series A, announced July 26, 2022"
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fn: 13
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fn: 18
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- type: funded
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with: "[[Sanabil Investments]]"
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reverse: true
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start: 2026-01
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role: "Sanabil, the venture arm of the Public Investment Fund, lists the firm among its holdings, per TechCrunch January 2026"
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fn: 10
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fn: 15
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- type: funded
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with: "[[MGX]]"
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reverse: true
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start: 2026-03
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role: "co-lead, per Bloomberg, of a roughly 10 billion dollar OpenAI financing announced for close the following week; see OpenAI page"
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fn: 11
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fn: 16
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- type: employed_by
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with: "[[Brian Quintenz]]"
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reverse: true
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start: 2021-09-09
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role: "advisory partner at a16z crypto; head of policy from December 5, 2022"
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fn: 4
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- type: funded
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with: "[[Kalshi]]"
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start: 2025-10-10
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role: "co-led the 300 million dollar Series D with Sequoia Capital"
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fn: 7
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created: 2026-09-22
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updated: 2026-10-13
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---
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@ -68,40 +79,51 @@ Andreessen Horowitz, known as a16z, is a venture capital firm founded in 2009 by
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Andreessen and Horowitz endorsed [[Donald Trump]] in July 2024 on their podcast, presenting a "Little Tech" agenda. After the election Andreessen advised on personnel for the [[Department of Government Efficiency]], and the a16z partner Scott Kupor was named to lead the Office of Personnel Management.[^3]
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### Crypto Policy and Prediction Markets
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On September 9, 2021, nine days after his service as a [[Commodity Futures Trading Commission]] commissioner ended, [[Brian Quintenz]] joined [[a16z crypto]] as an advisory partner. On December 5, 2022 the unit announced that he had accepted the full-time position of head of policy.[^4] Quintenz had joined the board of [[Kalshi]] on November 16, 2021, and was still on it when Donald Trump named him in February 2025 to chair the CFTC. His ethics agreement of May 21, 2025 pledged resignation from AH Capital Management and from the Kalshi board, and recusal from matters involving Andreessen Horowitz for two years and Kalshi for one year; the White House withdrew the nomination on September 30, 2025.[^5] A company filing of January 2026 describes him as the former head of policy for a16z crypto.[^6]
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Kalshi's announcement of October 10, 2025 describes its 300 million dollar Series D at a 5 billion dollar valuation as "co-led by Andreessen Horowitz (a16z) and Sequoia Capital, with significant participation from Paradigm."[^7] Andreessen Horowitz is named among the participants in Kalshi's 1 billion dollar Series E at an 11 billion dollar valuation (announced December 2, 2025) and in the 1 billion dollar Series F at a 22 billion dollar valuation led by [[Coatue Management]], reported on May 7, 2026.[^8]
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### Artificial Intelligence
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The firm led the seed round of about 2 billion dollars, at a 12 billion dollar valuation, of [[Mira Murati]]'s [[Thinking Machines Lab]] in July 2025, alongside Nvidia, Accel, ServiceNow, Cisco, AMD and [[Jane Street Capital|Jane Street]].[^4] It invested in [[Ilya Sutskever]]'s [[Safe Superintelligence]] in its round of September 2024 at a 5 billion dollar valuation and in April 2025 at 32 billion.[^5] Its crypto fund joined the 115 million dollar Series C of [[Sam Altman]]'s [[Worldcoin]] in May 2023 and co-led its 135 million dollar token sale in May 2025.[^6] Andreessen's "Techno-Optimist Manifesto," published by the firm on October 16, 2023, listed "existential risk," "trust and safety" and "tech ethics" among its enemies and named the neoreactionary [[Nick Land]] among its "patron saints."[^7]
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The firm led the seed round of about 2 billion dollars, at a 12 billion dollar valuation, of [[Mira Murati]]'s [[Thinking Machines Lab]] in July 2025, alongside Nvidia, Accel, ServiceNow, Cisco, AMD and [[Jane Street Capital|Jane Street]].[^9] It invested in [[Ilya Sutskever]]'s [[Safe Superintelligence]] in its round of September 2024 at a 5 billion dollar valuation and in April 2025 at 32 billion.[^10] Its crypto fund joined the 115 million dollar Series C of [[Sam Altman]]'s [[Worldcoin]] in May 2023 and co-led its 135 million dollar token sale in May 2025.[^11] Andreessen's "Techno-Optimist Manifesto," published by the firm on October 16, 2023, listed "existential risk," "trust and safety" and "tech ethics" among its enemies and named the neoreactionary [[Nick Land]] among its "patron saints."[^12]
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### Saudi Arabia and the Gulf
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In 2016 the firm and Founders Fund sold shares in [[Lyft]] to Saudi Arabia's [[Alwaleed bin Talal]] and his [[Kingdom Holding]], according to TechCrunch.[^8] In 2017 Marc Andreessen agreed to join the advisory board of [[NEOM]], the project led by Crown Prince [[Mohammed bin Salman]].[^8]
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In 2016 the firm and Founders Fund sold shares in [[Lyft]] to Saudi Arabia's [[Alwaleed bin Talal]] and his [[Kingdom Holding]], according to TechCrunch.[^13] In 2017 Marc Andreessen agreed to join the advisory board of [[NEOM]], the project led by Crown Prince [[Mohammed bin Salman]].[^13]
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In October 2022 Ben Horowitz spoke at the "Davos in the Desert" investment conference in Saudi Arabia, and in 2023 the firm's 350 million dollar investment in [[Flow]] was discussed at a conference organized by a nonprofit backed by one of Saudi Arabia's largest sovereign funds.[^8] TechCrunch wrote in April 2023 that the firm "has never made public who its limited partners are," and that it had reached out to the firm with questions and had not received a reply.[^8]
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In October 2022 Ben Horowitz spoke at the "Davos in the Desert" investment conference in Saudi Arabia, and in 2023 the firm's 350 million dollar investment in [[Flow]] was discussed at a conference organized by a nonprofit backed by one of Saudi Arabia's largest sovereign funds.[^13] TechCrunch wrote in April 2023 that the firm "has never made public who its limited partners are," and that it had reached out to the firm with questions and had not received a reply.[^13]
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On March 20, 2024 CNBC reported that Saudi Arabia's sovereign wealth fund, the [[Public Investment Fund]], was in talks with the firm. Two people with knowledge of the matter told CNBC that the talks would see "a partnership formed between Saudi Arabia's $925 billion Public Investment Fund and Andreessen Horowitz," and that "talks have not yet been finalized." The reported vehicle was an AI fund of about 40 billion dollars.[^9]
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On March 20, 2024 CNBC reported that Saudi Arabia's sovereign wealth fund, the [[Public Investment Fund]], was in talks with the firm. Two people with knowledge of the matter told CNBC that the talks would see "a partnership formed between Saudi Arabia's $925 billion Public Investment Fund and Andreessen Horowitz," and that "talks have not yet been finalized." The reported vehicle was an AI fund of about 40 billion dollars.[^14]
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TechCrunch reported on January 9, 2026 that a16z had raised "a little more than $15 billion" in new funding, bringing its assets under management to more than $90 billion. The article states that "Sanabil Investments, the venture arm of Saudi Arabia's Public Investment Fund, lists Andreessen Horowitz among its portfolio holdings," and that the firm "appears to be very friendly with actual sovereign wealth funds, including at least one from Saudi Arabia."[^10]
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TechCrunch reported on January 9, 2026 that a16z had raised "a little more than $15 billion" in new funding, bringing its assets under management to more than $90 billion. The article states that "Sanabil Investments, the venture arm of Saudi Arabia's Public Investment Fund, lists Andreessen Horowitz among its portfolio holdings," and that the firm "appears to be very friendly with actual sovereign wealth funds, including at least one from Saudi Arabia."[^15]
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In March 2026 the company told Bloomberg that the firm would co-lead a roughly 10 billion dollar financing for [[OpenAI]], alongside [[MGX]], [[D.E. Shaw Ventures]], [[TPG]] and T. Rowe Price.[^11]
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In March 2026 the company told Bloomberg that the firm would co-lead a roughly 10 billion dollar financing for [[OpenAI]], alongside [[MGX]], [[D.E. Shaw Ventures]], [[TPG]] and T. Rowe Price.[^16]
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Dealroom's October 2026 item on the [[Echelon (company)]] round, which names Ben Horowitz among the early backers, describes the founder, [[Khalid bin Bader Al Saud]], as an adviser to Andreessen Horowitz.[^12]
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Dealroom's October 2026 item on the [[Echelon (company)]] round, which names Ben Horowitz among the early backers, describes the founder, [[Khalid bin Bader Al Saud]], as an adviser to Andreessen Horowitz.[^17]
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### Nash and Early Portfolio Ties
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In the fall of 2021 the firm made the seed investment in [[Nash (company)]], a company founded by [[Mahmoud Ghulman]] and [[Aziz Alghunaim]]. On July 26, 2022 the firm announced that it was leading Nash's Series A. The announcement reads: "We first partnered with Nash for their seed round in the fall of 2021," and "We're excited to announce that a16z is leading the Series A for Nash."[^13]
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In the fall of 2021 the firm made the seed investment in [[Nash (company)]], a company founded by [[Mahmoud Ghulman]] and [[Aziz Alghunaim]]. On July 26, 2022 the firm announced that it was leading Nash's Series A. The announcement reads: "We first partnered with Nash for their seed round in the fall of 2021," and "We're excited to announce that a16z is leading the Series A for Nash."[^18]
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### Footnotes
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[^1]: Andreessen Horowitz, firm history. https://a16z.com/
|
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[^2]: "Andreessen Horowitz says it will no longer be a venture capital firm." *CNBC,* April 2, 2019, https://www.cnbc.com/2019/04/02/andreessen-horowitz-goes-against-the-grain-and-becomes-financial-advisor.html ; "Andreessen Horowitz raises $7.2 billion across five funds." *CNBC,* April 16, 2024.
|
||||
[^3]: "Marc Andreessen and Ben Horowitz endorse Trump." *Axios* and *TechCrunch,* July 16-17, 2024; "Marc Andreessen advising the Trump transition and DOGE." *Fortune,* January 16, 2025.
|
||||
[^4]: "Mira Murati's Thinking Machines Lab is worth $12B in seed round." *TechCrunch,* July 15, 2025.
|
||||
[^5]: "AI's Big Day: Startup Safe Superintelligence Raises $1B At Reported $5B Valuation." *Crunchbase News,* September 4, 2024, https://news.crunchbase.com/ai/startup-safe-superintelligence-unicorn-raise/ ; "OpenAI co-founder Ilya Sutskever's Safe Superintelligence reportedly valued at $32B." *TechCrunch,* April 12, 2025.
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[^6]: "Sam Altman's crypto project Worldcoin raises $115M led by Blockchain Capital." *CoinDesk,* May 25, 2023; "World raises $135M." World blog, May 21, 2025.
|
||||
[^7]: Andreessen, Marc. "The Techno-Optimist Manifesto." Andreessen Horowitz, October 16, 2023. https://a16z.com/the-techno-optimist-manifesto/
|
||||
[^8]: Loizos, Connie, "Andreessen Horowitz is now openly courting capital from Saudi Arabia, despite U.S. strains," *TechCrunch*, April 1, 2023: on the 2016 Lyft share sale to "Saudi Arabia's Prince al-Waleed bin Talal and his Kingdom Holding"; "In 2017, Andreessen also joined forces with the prince's first cousin, Saudi Crown Prince Mohammed bin Salman ('MBS'), agreeing to join the advisory board of MBS' ambitious project, Neom"; "Though the 14-year-old outfit has never made public who its limited partners are"; and the "We reached out to Andreessen Horowitz with related questions this morning and have yet to hear back." https://techcrunch.com/2023/04/01/andreessen-horowitz-is-now-openly-courting-capital-from-saudi-arabia-despite-u-s-strains/
|
||||
[^9]: Turak, Natasha, "Saudi Arabia reportedly in talks with VC firms like Andreessen Horowitz to create mammoth $40 billion AI fund," *CNBC*, March 20, 2024: "would see a partnership formed between Saudi Arabia's $925 billion Public Investment Fund and Andreessen Horowitz"; "The people stressed that talks have not yet been finalized." https://www.cnbc.com/2024/03/20/saudi-arabia-in-talks-with-andreessen-horowitz-to-create-ai-fund.html
|
||||
[^10]: Loizos, Connie, "The venture firm that ate Silicon Valley," *TechCrunch*, January 9, 2026: "a little more than $15 billion" in new funding and "more than $90 billion" in assets under management; "Sanabil Investments, the venture arm of Saudi Arabia's Public Investment Fund, lists Andreessen Horowitz among its portfolio holdings"; "a16z appears to be very friendly with actual sovereign wealth funds, including at least one from Saudi Arabia." https://techcrunch.com/2026/01/09/the-venture-firm-that-ate-silicon-valley
|
||||
[^11]: Bloomberg, "OpenAI Set to Raise $10 Billion From MGX, Coatue, Thrive," March 24, 2026, as reproduced by Bloomberg Government: "Andreessen Horowitz, Abu Dhabi's MGX, D.E. Shaw Ventures, TPG and T. Rowe Price will co-lead the financing, which is set to close next week, the company told Bloomberg Tuesday." https://news.bgov.com/california-brief/openai-set-to-raise-10-billion-from-mgx-coatue-thrive-2
|
||||
[^12]: Dealroom, news item on the Echelon launch, October 8, 2026: "Its early backers include East40, RAED Ventures, Avra, and Ben Horowitz"; the item lists the founder's roles as "a venture partner at RAED Ventures and an adviser to Andreessen Horowitz." https://dealroom.co/news/160932-saudi-ai-company-echelon-launches-with-backing-from-ben-horowitz-avra-an/
|
||||
[^13]: Andreessen Horowitz, "Investing in Nash," posted July 26, 2022: "We first partnered with Nash for their seed round in the fall of 2021"; "We're excited to announce that a16z is leading the Series A for Nash"; the post welcomes "Mahmoud, Aziz, and the Nash team." https://a16z.com/announcement/investing-in-nash/
|
||||
[^4]: "Fresh out of the CFTC, Brian Quintenz joins a16z Crypto's advisory team," The Block, September 9, 2021, https://www.theblock.co/amp/linked/117098/fresh-out-of-the-cftc-brian-quintenz-joins-a16z-cryptos-advisory-team ; "Brian Quintenz, a16z crypto's New Head of Policy," a16z crypto, December 5, 2022, https://a16zcrypto.com/brian-quintenz-new-head-of-policy/ ; CFTC, "Former Commissioners" (service to August 31, 2021). https://www.cftc.gov/About/Commissioners/FormerCommissioners/index.htm
|
||||
[^5]: "Brian Quintenz joins board of the first CFTC-regulated events market," The Block, November 16, 2021, https://www.theblock.co/post/124482/brian-quintenz-joins-board-of-the-first-cftc-regulated-events-market ; CasinoBeats, "Trump's CFTC Nomination Quintenz to Resign From Kalshi, Recuse Himself on Related Matters," May 29, 2025, reporting the ethics agreement submitted to the Office of Government Ethics on May 21, 2025, https://casinobeats.com/2025/05/29/trumps-cftc-nomination-quintenz-to-resign-from-kalshi-recuse-himself-on-related-matters/ ; "Trump admin withdraws Brian Quintenz as CFTC nominee," Cointelegraph, September 30, 2025. https://cointelegraph.com/news/white-house-pulls-brian-quintenz-cftc-nominee
|
||||
[^6]: SUI Group Holdings Ltd., Form 8-K filed January 9, 2026 (accession 0001654954-26-000203), Item 5.02. https://www.sec.gov/Archives/edgar/data/1425355/000165495426000203/suig_8k.htm
|
||||
[^7]: Kalshi, "Kalshi hits $5 billion valuation amid international expansion," October 10, 2025. https://news.kalshi.com/p/kalshi-hits-5-billion-valuation-amid-international-expansion
|
||||
[^8]: Kalshi, "Kalshi Reaches $11 Billion Valuation as App Takes over America," December 2, 2025, https://news.kalshi.com/p/kalshi-11-billion-valuation-series-e ; Brian Danga, "Kalshi hits $22 billion valuation after $1 billion raise led by Coatue," The Block, May 7, 2026. https://www.theblock.co/post/400413/kalshi-hits-22-billion-valuation-after-1-billion-raise-led-by-coatue
|
||||
[^9]: "Mira Murati's Thinking Machines Lab is worth $12B in seed round." *TechCrunch,* July 15, 2025.
|
||||
[^10]: "AI's Big Day: Startup Safe Superintelligence Raises $1B At Reported $5B Valuation." *Crunchbase News,* September 4, 2024, https://news.crunchbase.com/ai/startup-safe-superintelligence-unicorn-raise/ ; "OpenAI co-founder Ilya Sutskever's Safe Superintelligence reportedly valued at $32B." *TechCrunch,* April 12, 2025.
|
||||
[^11]: "Sam Altman's crypto project Worldcoin raises $115M led by Blockchain Capital." *CoinDesk,* May 25, 2023; "World raises $135M." World blog, May 21, 2025.
|
||||
[^12]: Andreessen, Marc. "The Techno-Optimist Manifesto." Andreessen Horowitz, October 16, 2023. https://a16z.com/the-techno-optimist-manifesto/
|
||||
[^13]: Loizos, Connie, "Andreessen Horowitz is now openly courting capital from Saudi Arabia, despite U.S. strains," *TechCrunch*, April 1, 2023: on the 2016 Lyft share sale to "Saudi Arabia's Prince al-Waleed bin Talal and his Kingdom Holding"; "In 2017, Andreessen also joined forces with the prince's first cousin, Saudi Crown Prince Mohammed bin Salman ('MBS'), agreeing to join the advisory board of MBS' ambitious project, Neom"; "Though the 14-year-old outfit has never made public who its limited partners are"; and the "We reached out to Andreessen Horowitz with related questions this morning and have yet to hear back." https://techcrunch.com/2023/04/01/andreessen-horowitz-is-now-openly-courting-capital-from-saudi-arabia-despite-u-s-strains/
|
||||
[^14]: Turak, Natasha, "Saudi Arabia reportedly in talks with VC firms like Andreessen Horowitz to create mammoth $40 billion AI fund," *CNBC*, March 20, 2024: "would see a partnership formed between Saudi Arabia's $925 billion Public Investment Fund and Andreessen Horowitz"; "The people stressed that talks have not yet been finalized." https://www.cnbc.com/2024/03/20/saudi-arabia-in-talks-with-andreessen-horowitz-to-create-ai-fund.html
|
||||
[^15]: Loizos, Connie, "The venture firm that ate Silicon Valley," *TechCrunch*, January 9, 2026: "a little more than $15 billion" in new funding and "more than $90 billion" in assets under management; "Sanabil Investments, the venture arm of Saudi Arabia's Public Investment Fund, lists Andreessen Horowitz among its portfolio holdings"; "a16z appears to be very friendly with actual sovereign wealth funds, including at least one from Saudi Arabia." https://techcrunch.com/2026/01/09/the-venture-firm-that-ate-silicon-valley
|
||||
[^16]: Bloomberg, "OpenAI Set to Raise $10 Billion From MGX, Coatue, Thrive," March 24, 2026, as reproduced by Bloomberg Government: "Andreessen Horowitz, Abu Dhabi's MGX, D.E. Shaw Ventures, TPG and T. Rowe Price will co-lead the financing, which is set to close next week, the company told Bloomberg Tuesday." https://news.bgov.com/california-brief/openai-set-to-raise-10-billion-from-mgx-coatue-thrive-2
|
||||
[^17]: Dealroom, news item on the Echelon launch, October 8, 2026: "Its early backers include East40, RAED Ventures, Avra, and Ben Horowitz"; the item lists the founder's roles as "a venture partner at RAED Ventures and an adviser to Andreessen Horowitz." https://dealroom.co/news/160932-saudi-ai-company-echelon-launches-with-backing-from-ben-horowitz-avra-an/
|
||||
[^18]: Andreessen Horowitz, "Investing in Nash," posted July 26, 2022: "We first partnered with Nash for their seed round in the fall of 2021"; "We're excited to announce that a16z is leading the Series A for Nash"; the post welcomes "Mahmoud, Aziz, and the Nash team." https://a16z.com/announcement/investing-in-nash/
|
||||
|
|
|
|||
|
|
@ -9,10 +9,21 @@ tags:
|
|||
- PeterThiel
|
||||
- PayPalMafia
|
||||
- SiliconValley
|
||||
summary: "Founders Fund is a San Francisco venture capital firm founded in 2005 by Peter Thiel, Ken Howery, and Luke Nosek, whose early investments in Facebook, SpaceX, Airbnb, Stripe, Palantir Technologies, and Anduril Industries made it the financial vehicle of the Thiel commercial network."
|
||||
summary: "Founders Fund is a San Francisco venture capital firm founded in 2005 by Peter Thiel, Ken Howery and Luke Nosek, an early investor in Facebook, SpaceX, Palantir, Anduril and Polymarket."
|
||||
location: "San Francisco, California"
|
||||
created: 2026-06-17
|
||||
updated: 2026-06-17
|
||||
relations:
|
||||
- type: funded
|
||||
with: "[[Polymarket]]"
|
||||
start: 2024-05
|
||||
role: "led the 45 million dollar Series B"
|
||||
fn: 5
|
||||
- type: funded
|
||||
with: "[[Polymarket]]"
|
||||
start: 2025
|
||||
role: "led a 2025 round of 150 million dollars at a 1.2 billion dollar valuation, disclosed October 2025; Bloomberg reported a lead of more than 200 million dollars in June 2025"
|
||||
fn: 8
|
||||
updated: 2026-10-13
|
||||
---
|
||||
|
||||
Founders Fund is a [[San Francisco]] venture capital firm founded in 2005 by [[Peter Thiel]], [[Ken Howery]], and [[Luke Nosek]], all of them [[PayPal Mafia]] principals. The firm's early investments included [[Facebook]] (Thiel's 2004 angel investment of 500,000 dollars was the firm's first major deal and produced a roughly two billion dollar return), [[SpaceX]], [[Palantir Technologies]], [[Airbnb]], [[Stripe]], and [[Anduril Industries]]. The firm has functioned as the financial vehicle of the Thiel commercial network: it concentrates capital in firms pursuing monopoly positions in domains (payments, defense, space, biotechnology, sovereign-grade infrastructure) the firm judges foundational.[^1][^2]
|
||||
|
|
@ -35,6 +46,10 @@ The Facebook investment is the firm's best-known outcome. Thiel's 2004 angel inv
|
|||
|
||||
The defense and frontier-tech portfolio is the more recent concentration. Anduril Industries, backed by Founders Fund from 2017 and led by partner Stephens, reached a 30.5 billion dollar valuation in the 2025 Series G that Founders Fund led with a reported one billion dollar check. Clearview AI, the facial-recognition firm, took Thiel-network investment. The firm has also built positions in [[Epic Games]], [[Affirm]], and in [[bitcoin]] (the firm took an early institutional position and disclosed holdings in 2020).[^1][^4]
|
||||
|
||||
### Polymarket and Prediction Markets
|
||||
|
||||
In May 2024 Founders Fund led the 45 million dollar Series B of [[Polymarket]], with the existing investors 1confirmation and [[ParaFi]] and with [[Vitalik Buterin]], [[Dragonfly]] and [[Kevin Hartz]] among the other investors; the round was announced together with a previously unannounced 25 million dollar Series A led by [[General Catalyst]], for 70 million dollars across the two rounds.[^5] [[Joey Krug]], a Founders Fund partner, said in the announcement that the firm had "developed a habit of checking Polymarket at times of breaking news" and that "It became clear to us that Polymarket was the winner in this market."[^5] New York magazine reported that Krug, who had founded the earlier prediction market [[Augur]], first turned down [[Shayne Coplan]]'s repeated pitches ("prediction markets are one of the hardest types of start-ups to build"), then set a target of 5 million dollars in weekly volume, was told in late 2023 that Coplan had reached it, and led the round after joining Founders Fund.[^6] The announcement also named the former CFTC chairman [[J. Christopher Giancarlo]] as chairman of Polymarket's advisory board.[^5] Bloomberg reported on June 24, 2025 that Founders Fund was leading an investment of more than 200 million dollars in Polymarket at a 1 billion dollar valuation.[^7] In October 2025 Coplan disclosed a 150 million dollar round in 2025, led by Founders Fund at a 1.2 billion dollar valuation, whose investors included Ribbit, Valor, Point72 Ventures, SV Angel, "1789" ([[1789 Capital]]), 1confirmation, Coinbase and Dragonfly.[^8]
|
||||
|
||||
### The Defense-Tech and Sovereign-Infrastructure Concentration
|
||||
|
||||
Founders Fund's portfolio has shifted toward defense, sovereign-grade infrastructure, and firms whose products are procured by or substitute for state functions. The concentration includes Palantir Technologies (intelligence and law-enforcement data fusion), Anduril Industries (autonomous defense systems), Clearview AI (facial recognition), and adjacent positions in surveillance, identity, and payments infrastructure. The firm's published investment theses, including the 2014 [[Founders Fund Manifesto]] that criticized the consumer-internet focus of the prior venture generation, frame the shift as a return to the "atoms not bits" argument that capital should flow into physical and infrastructure technology rather than into consumer software.[^1][^2]
|
||||
|
|
@ -47,3 +62,7 @@ The portfolio concentration aligns the firm's commercial interests with the [[Di
|
|||
[^2]: Thiel, Peter, and Blake Masters. *Zero to One: Notes on Startups, or How to Build the Future.* Crown Business, 2014. The "competition is for losers" formulation and the monopoly thesis are set out in Chapter 3.
|
||||
[^3]: Cameron, Dell, and Yulia Almazova. "Leak Exposes Members of Peter Thiel's Secretive 'Dialog' Society." *WIRED,* June 16, 2026. https://www.wired.com/story/leak-exposes-members-of-peter-thiels-secretive-dialog-society/
|
||||
[^4]: "Anduril raises funding at $30.5 billion valuation in round led by Founders Fund." *NBC New York* (via Bloomberg), 2025. https://www.nbcnewyork.com/news/business/money-report/anduril-raises-funding-at-30-5-billion-valuation-in-round-led-by-founders-fund-chairman-says/6291304/
|
||||
[^5]: Business Wire, "Polymarket Raises $70m From Thiel's Founders Fund, General Catalyst, Vitalik Buterin to Scale Global Prediction Market," May 13, 2024, https://www.businesswire.com/news/home/20240513090515/en/Polymarket-Raises-%2470m-From-Thiels-Founders-Fund-General-Catalyst-Vitalik-Buterin-to-Scale-Global-Prediction-Market ; "Polymarket raises $45 million from Peter Thiel's Founders Fund, Vitalik Buterin and others," The Block, May 14, 2024. https://www.theblock.co/post/294367/polymarket-raises-45-million-from-peter-thiels-founders-fund-vitalik-buterin-and-others
|
||||
[^6]: Jen Wieczner, "Is Polymarket Legal? How Shayne Coplan's Bet Is Paying Off," New York magazine, Intelligencer, March 11, 2025. https://nymag.com/intelligencer/article/is-polymarket-legal-politics-betting-shayne-coplan.html
|
||||
[^7]: Bloomberg, "Polymarket Is Set to Raise Funding at $1 Billion Valuation," June 24, 2025, as reported in "Donald Trump Jr. announces role at Polymarket," Front Office Sports, August 2025. https://frontofficesports.com/article/donald-trump-jr-kalshi-polymarket/
|
||||
[^8]: Naga Avan-Nomayo, "Polymarket discloses past funding rounds totaling $205 million before $2 billion ICE investment," The Block, October 8, 2025. https://www.theblock.co/post/373783/polymarket-discloses-past-funding-rounds-totaling-205-million-before-2-billion-ice-investment
|
||||
|
|
|
|||
397
20 - ORGANIZATIONS/PRIVATE/Kalshi.md
Normal file
397
20 - ORGANIZATIONS/PRIVATE/Kalshi.md
Normal file
|
|
@ -0,0 +1,397 @@
|
|||
---
|
||||
aliases:
|
||||
- Kalshi
|
||||
- Kalshi Inc
|
||||
- Kalshi Inc.
|
||||
- KalshiEX
|
||||
- KalshiEX LLC
|
||||
- Kalshi, Inc.
|
||||
category: "Private Organization"
|
||||
tags:
|
||||
- Organization
|
||||
- Kalshi
|
||||
- PredictionMarkets
|
||||
- EventContracts
|
||||
- CFTC
|
||||
- SportsBetting
|
||||
- VentureCapital
|
||||
- Lobbying
|
||||
- RevolvingDoor
|
||||
- PoliticalDonor
|
||||
- InsiderTrading
|
||||
summary: "Event-contract exchange designated by the CFTC in November 2020, backed by Sequoia, Paradigm and Andreessen Horowitz, with a former CFTC commissioner on its board and Donald Trump Jr. as a strategic adviser."
|
||||
location: "New York, New York"
|
||||
created: 2026-10-13
|
||||
updated: 2026-10-13
|
||||
relations:
|
||||
- type: founded
|
||||
with: "[[Tarek Mansour]]"
|
||||
reverse: true
|
||||
start: 2018
|
||||
role: "co-founder and chief executive"
|
||||
fn: 2
|
||||
- type: founded
|
||||
with: "[[Luana Lopes Lara]]"
|
||||
reverse: true
|
||||
start: 2018
|
||||
role: "co-founder and chief operating officer"
|
||||
fn: 2
|
||||
- type: funded
|
||||
with: "[[Y Combinator]]"
|
||||
reverse: true
|
||||
start: 2019
|
||||
role: "accelerator, Winter 2019 batch; YC Continuity in the Series A; Y Combinator among the Series E participants"
|
||||
fn: 1
|
||||
- type: funded
|
||||
with: "[[Sequoia Capital]]"
|
||||
reverse: true
|
||||
start: 2021-02-17
|
||||
role: "led the 30 million dollar Series A"
|
||||
fn: 2
|
||||
- type: funded
|
||||
with: "[[Charles Schwab]]"
|
||||
reverse: true
|
||||
start: 2021-02-17
|
||||
role: "participant in the Series A"
|
||||
fn: 2
|
||||
- type: funded
|
||||
with: "[[Henry Kravis]]"
|
||||
reverse: true
|
||||
start: 2021-02-17
|
||||
role: "participant in the Series A"
|
||||
fn: 2
|
||||
- type: funded
|
||||
with: "[[Paradigm (investment firm)]]"
|
||||
reverse: true
|
||||
start: 2025-06-25
|
||||
role: "led the 185 million dollar Series C"
|
||||
fn: 15
|
||||
- type: funded
|
||||
with: "[[Andreessen Horowitz]]"
|
||||
reverse: true
|
||||
start: 2025-10-10
|
||||
role: "co-led the 300 million dollar Series D with Sequoia Capital"
|
||||
fn: 17
|
||||
- type: funded
|
||||
with: "[[Paradigm (investment firm)]]"
|
||||
reverse: true
|
||||
start: 2025-12-02
|
||||
role: "led the 1 billion dollar Series E at an 11 billion dollar valuation"
|
||||
fn: 20
|
||||
- type: funded
|
||||
with: "[[Coatue Management]]"
|
||||
reverse: true
|
||||
start: 2026-05-07
|
||||
role: "led the 1 billion dollar Series F at a 22 billion dollar valuation"
|
||||
fn: 22
|
||||
- type: director_of
|
||||
with: "[[Brian Quintenz]]"
|
||||
reverse: true
|
||||
start: 2021-11-16
|
||||
role: "board member; pledged in May 2025 to resign the seat if confirmed as CFTC chairman; listed as a current board member in July 2026"
|
||||
fn: 14
|
||||
- type: director_of
|
||||
with: "[[Alfred Lin]]"
|
||||
reverse: true
|
||||
start: 2021-02-17
|
||||
role: "director; partner at Sequoia Capital"
|
||||
fn: 2
|
||||
- type: director_of
|
||||
with: "[[Matt Huang]]"
|
||||
reverse: true
|
||||
start: 2025-10-23
|
||||
role: "director per Form D filed October 23, 2025; co-founder of Paradigm"
|
||||
fn: 18
|
||||
- type: director_of
|
||||
with: "[[Michael Seibel]]"
|
||||
reverse: true
|
||||
start: 2025-10-23
|
||||
role: "director per Form D filed October 23, 2025"
|
||||
fn: 18
|
||||
- type: employed_by
|
||||
with: "[[Elie Mishory]]"
|
||||
reverse: true
|
||||
start: 2022
|
||||
end: 2025-03
|
||||
role: "attorney, then chief regulatory officer and general counsel"
|
||||
fn: 63
|
||||
- type: appointed
|
||||
with: "[[Donald Trump Jr.]]"
|
||||
start: 2025-01-13
|
||||
role: "strategic adviser"
|
||||
fn: 53
|
||||
- type: appointed
|
||||
with: "[[Stephanie Cutter]]"
|
||||
start: 2026-04-02
|
||||
role: "policy adviser"
|
||||
fn: 56
|
||||
- type: appointed
|
||||
with: "[[Brian Nelson]]"
|
||||
start: 2026-02-05
|
||||
role: "adviser on market integrity, trading surveillance and compliance"
|
||||
fn: 3
|
||||
- type: member_of
|
||||
with: "[[Coalition for Prediction Markets]]"
|
||||
start: 2025-12
|
||||
role: "member; Head of Corporate Development Sara Slane an executive board member"
|
||||
fn: 52
|
||||
- type: partner_of
|
||||
with: "[[Robinhood]]"
|
||||
start: 2025-02
|
||||
role: "event contracts offered through the brokerage; Super Bowl contracts suspended after a CFTC request"
|
||||
fn: 65
|
||||
- type: partner_of
|
||||
with: "[[Webull]]"
|
||||
start: 2025-02-12
|
||||
role: "event contracts offered through the brokerage"
|
||||
fn: 65
|
||||
- type: partner_of
|
||||
with: "[[Coinbase]]"
|
||||
start: 2026-01-28
|
||||
role: "nationwide rollout of Kalshi-supplied prediction markets"
|
||||
fn: 66
|
||||
- type: partner_of
|
||||
with: "[[CNN]]"
|
||||
start: 2025-12-02
|
||||
role: "official prediction markets partner"
|
||||
fn: 67
|
||||
- type: partner_of
|
||||
with: "[[CNBC]]"
|
||||
start: 2025-12
|
||||
role: "event-odds data partner, with a minority investment by CNBC"
|
||||
fn: 68
|
||||
- type: prosecuted
|
||||
with: "[[Kris Mayes]]"
|
||||
reverse: true
|
||||
start: 2026-03-17
|
||||
role: "twenty misdemeanor counts filed by the Arizona attorney general in Maricopa County Superior Court"
|
||||
fn: 39
|
||||
- type: represented
|
||||
with: "[[Rich Feuer Anderson]]"
|
||||
reverse: true
|
||||
start: 2021-12
|
||||
end: 2024-06
|
||||
role: "federal lobbying firm"
|
||||
fn: 60
|
||||
- type: represented
|
||||
with: "[[Capitol Counsel LLC]]"
|
||||
reverse: true
|
||||
start: 2022-11
|
||||
end: 2024-10
|
||||
role: "federal lobbying firm; De'Ana Dow lobbyist"
|
||||
fn: 60
|
||||
- type: represented
|
||||
with: "[[Miller Strategies]]"
|
||||
reverse: true
|
||||
start: 2024-05
|
||||
role: "federal lobbying firm"
|
||||
fn: 60
|
||||
- type: represented
|
||||
with: "[[Lincoln Policy Group]]"
|
||||
reverse: true
|
||||
start: 2024-06
|
||||
role: "federal lobbying firm; Blanche Lincoln lobbyist"
|
||||
fn: 60
|
||||
- type: represented
|
||||
with: "[[Squire Patton Boggs]]"
|
||||
reverse: true
|
||||
start: 2026-03
|
||||
role: "federal lobbying firm"
|
||||
fn: 60
|
||||
- type: represented
|
||||
with: "[[Milbank LLP]]"
|
||||
reverse: true
|
||||
role: "litigation counsel; Joshua Sterling and Neal Katyal on the Sixth Circuit briefs"
|
||||
fn: 35
|
||||
- type: represented
|
||||
with: "[[Jones Day]]"
|
||||
reverse: true
|
||||
role: "outside counsel in the D.C. Circuit appeal of KalshiEX v. CFTC, per Protos; Yaakov Roth argued"
|
||||
fn: 29
|
||||
---
|
||||
|
||||
Kalshi is a New York exchange for event contracts, operated through KalshiEX LLC, that the [[Commodity Futures Trading Commission]] designated as a contract market on November 3, 2020. [[Tarek Mansour]] and [[Luana Lopes Lara]] founded the company, which [[Y Combinator]] lists in its Winter 2019 batch.[^1] Form D filings with the [[Securities and Exchange Commission]] report about 2.47 billion dollars sold in seven offerings between 2020 and 2026, and the sports and election contracts have drawn state enforcement, private class actions, a criminal information in [[Arizona]] and rulings from three federal circuits.
|
||||
|
||||
### Origins
|
||||
|
||||
Kalshi's own account states that Mansour and Lopes Lara founded the company in 2018 after exploring event-driven hedging and investment products at [[Goldman Sachs]] and [[Citadel]], and that the founders spent the first years obtaining federal registration before launching a product.[^2][^3] The Y Combinator profile gives 2019 as the founding year and calls the company the "1st federally regulated exchange where people can trade on events."[^1] Kalshi Inc., a Delaware corporation, filed its first Form D on March 19, 2020, reporting a first sale on March 4, 2020 of 6,094,999 dollars to 28 investors and entering 2018 as the year of incorporation.[^4] The 2023 petition to modify the designation order, filed for KalshiEX LLC over the signature of Mansour as chief executive and transmitted by [[Elie Mishory]] as chief regulatory officer, gives December 10, 2019 as the date of formation.[^5]
|
||||
|
||||
The CFTC announced on November 4, 2020 that it had issued an order of designation to KalshiEX LLC, "granting it status as a designated contract market (DCM)," and described the company as located in San Francisco.[^6] The order, dated November 3, 2020, recites submissions from December 30, 2019 through September 17, 2020.[^7] As first issued it provided that Kalshi "may not permit any futures commission merchant to intermediate any transactions or carry accounts for customers" until the order was amended. Kalshi requested removal of that provision in submissions from November 27, 2023 through December 9, 2024, and the Commission superseded the order on January 17, 2025.[^8] The CFTC release of 2020 does not use the word "first" for the designation. Kalshi's February 2021 announcement called the exchange "the first federally regulated exchange dedicated to trading on event outcomes" and "one of just 16 DCMs in the U.S."[^2]
|
||||
|
||||
On August 29, 2024 the CFTC announced that it had granted [[Kalshi Klear LLC]] registration as a derivatives clearing organization.[^9]
|
||||
|
||||
### Funding
|
||||
|
||||
The Form D for the March 2020 sale is the earliest of seven filed by Kalshi Inc.[^4] The second reports a first sale on December 18, 2020 of 29,999,999 dollars to 10 investors, was filed February 23, 2021, and lists Mansour, Lopes Lara and [[Alfred Lin]] as directors.[^10] On February 17, 2021 the company announced a 30 million dollar Series A led by [[Sequoia Capital]], with participation from [[Charles Schwab]], chairman of [[Charles Schwab Corporation]], [[Henry Kravis]], co-chairman and co-chief executive of [[KKR]], [[SV Angel]] and previous investors including [[Neo]] and [[YC Continuity]]. The release quotes Lin as "partner at Sequoia and Kalshi board member."[^2] [[Ali Partovi]] of Neo wrote on February 19, 2021 that his fund "doubled down in this round and are Kalshi's largest investor after Sequoia."[^11]
|
||||
|
||||
A Form D with a first sale on November 3, 2021 for 69,999,989 dollars to 14 investors was filed on November 6, 2025.[^12] A market data aggregator labels the round a Series B at a 749.83 million dollar valuation.[^13] On November 16, 2021 the company announced that [[Brian Quintenz]], a former CFTC commissioner, had joined its board.[^14]
|
||||
|
||||
On June 25, 2025 Kalshi announced a 185 million dollar Series C at a 2 billion dollar valuation led by [[Paradigm (investment firm)]]. Mansour listed Sequoia Capital, [[Multicoin Capital]], [[Peng Zhao]] (chief executive of [[Citadel Securities]]), Neo and [[Bond Capital]] as participants, and The Block reported that the round brought total funding to 415 million dollars and that Kalshi had also taken "tens of millions" in short-term loans from venture firms the year before, citing TechCrunch.[^15] Decrypt reported, citing PitchBook, a 787 million dollar post-money valuation in late 2024 around the time of a 50 million dollar private round.[^15] The Form D with a first sale of June 24, 2025 reports 124,999,957 dollars sold to 14 investors.[^16]
|
||||
|
||||
On October 10, 2025 Kalshi announced a 300 million dollar Series D at a 5 billion dollar valuation, "co-led by Andreessen Horowitz (a16z) and Sequoia Capital, with significant participation from Paradigm," with [[Coinbase Ventures]], [[General Catalyst]], [[Spark Capital]] and [[CapitalG]] as additional backers.[^17] The Form D with a first sale of October 8, 2025 reports 294,500,203 dollars sold of a 389,999,943 dollar offering to 20 investors and lists Mansour, Lopes Lara, Lin, [[Michael Seibel]] and [[Matt Huang]] as directors.[^18] A Fortune report reproduced on Yahoo Finance describes Huang as the Paradigm cofounder and managing partner who sits on Kalshi's board.[^19]
|
||||
|
||||
On November 20, 2025 The Block, relaying TechCrunch, reported a 1 billion dollar round at an 11 billion dollar valuation led by Sequoia and CapitalG, with [[Andreessen Horowitz]], Paradigm, [[Anthos Capital]] and Neo participating. Kalshi's announcement of December 2, 2025 describes a 1 billion dollar Series E at 11 billion dollars "led by Paradigm, with participation from Sequoia, Andreessen Horowitz, Meritech Capital, IVP, ARK Invest, Anthos Capital, CapitalG, and Y Combinator."[^20] The Form D with a first sale of November 19, 2025 reports 820,819,303 dollars sold of a 999,996,557 dollar offering to 31 investors.[^21]
|
||||
|
||||
On May 7, 2026 Kalshi announced a 1 billion dollar Series F at a 22 billion dollar valuation, led by [[Coatue Management]] with participation from Sequoia, Andreessen Horowitz, [[IVP]], Paradigm, [[Morgan Stanley]] and [[ARK Invest]], the company's third round in seven months.[^22] The Form D with a first sale of April 3, 2026 reports 1,120,010,122 dollars sold of a 1,499,997,894 dollar offering to 71 investors.[^23]
|
||||
|
||||
Two feeder vehicles filed their own Form Ds. Soma Capital Kalshi SPV, LP reports a first sale on January 14, 2022 of 2.5 million dollars to one investor, was filed April 13, 2022, and lists Aneel Ranadive as a director and [[Soma Capital Management]] as promoter. SC Kalshi SPV II LLC reports a first sale on April 17, 2025, was filed May 1, 2025, and lists [[Zanbato Capital LLC]] and Zanbato Advisors LLC as executive officers and Soma Capital Management as promoter.[^24] Further Form Ds in 2026 name Kalshi in vehicle titles, including HII Kalshi, Latitude Ventures Kalshi, Dominari Master SPV LLC Series XXIX Kalshi and DMM Kalshi I, LLC.[^25]
|
||||
|
||||
### Securities Filings
|
||||
|
||||
Rule 503 of Regulation D requires a notice of sales on Form D no later than 15 calendar days after the first sale of securities in the offering.[^26] The seven Kalshi Inc. filings, by date of first sale and date filed, are: March 4, 2020 and March 19, 2020 (15 days); December 18, 2020 and February 23, 2021 (67 days); November 3, 2021 and November 6, 2025 (four years and three days); June 24, 2025 and October 30, 2025 (128 days); October 8, 2025 and October 23, 2025 (15 days); November 19, 2025 and December 4, 2025 (15 days); April 3, 2026 and August 25, 2026 (144 days).[^4][^10][^12][^16][^18][^21][^23]
|
||||
|
||||
The filing made on November 6, 2025 for the November 2021 sale lists as related persons Mansour and Lopes Lara as executive officers and directors and Lin, Seibel and Huang as directors, the same five persons listed on the filings of October 23, October 30 and December 4, 2025 and August 25, 2026.[^12] None of the seven Kalshi Inc. filings, dated March 19, 2020 through August 25, 2026, lists Quintenz as a related person.[^4][^10][^12][^16][^18][^21][^23]
|
||||
|
||||
### Litigation and Regulation
|
||||
|
||||
On June 12, 2023 Kalshi self-certified a contract on which chamber of Congress a party would control. On June 23 the CFTC opened a 90-day review, asked Kalshi to suspend listing during the review, and opened a public comment period. Two of the five commissioners dissented from the decision to open the review. On September 22, 2023, at the close of the review, the CFTC issued an order prohibiting the listing, with Commissioner Mersinger dissenting and Commissioner [[Caroline Pham]] abstaining, according to the court's account of the Commission's statements.[^27]
|
||||
|
||||
Kalshi sued in the District of Columbia. In a memorandum opinion of September 12, 2024, Judge [[Jia M. Cobb]] granted summary judgment to Kalshi and held that the contracts "do not involve activity that is unlawful under any Federal or State law, nor do they involve gaming."[^27] The CFTC appealed to the [[D.C. Circuit]] as No. 24-5205. On May 5, 2025, after a 3 to 0 commission vote, the agency moved to dismiss the appeal voluntarily, each side bearing its own costs.[^28] Protos reported that [[Yaakov Roth]] of [[Jones Day]] argued the appeal for Kalshi in January 2025 and joined the Justice Department in February 2025.[^29]
|
||||
|
||||
Sports contracts followed in January 2025. The [[Third Circuit]] opinion in the New Jersey case records that a competitor began offering sports event contracts in December 2024, Kalshi did so a month later, and New Jersey sent a cease-and-desist letter two months after that.[^30] In [[Nevada]], a federal judge, [[Andrew Gordon]], granted Kalshi a preliminary injunction in April 2025 against the [[Nevada Gaming Control Board]], dissolved it on November 24, 2025, and in December refused a stay.[^31] The [[Ninth Circuit]] opinion of August 28, 2026 in KalshiEX, LLC v. Assad (No. 25-7516), written by Judge Ryan Nelson with a concurrence by Judge Kenneth Lee, affirmed the dissolution as to sports contracts and remanded for the district court to consider Nevada's challenges to the election contracts.[^32]
|
||||
|
||||
In [[New Jersey]], the Third Circuit decided KalshiEX, LLC v. Flaherty (No. 25-1922, 172 F.4th 220) on April 6, 2026, after argument on September 10, 2025, affirming the preliminary injunction granted by District Judge Edward Kiel. Judge David Porter wrote the opinion, joined by Chief Judge Michael Chagares. Judge Jane Roth dissented, writing that "if it looks like gambling, talks like gambling, and calls itself gambling, it's gambling."[^30] New Jersey filed a petition for certiorari on September 2, 2026, docketed as No. 26-299 on September 8, and the Supreme Court extended the response deadline to November 9, 2026.[^33]
|
||||
|
||||
In [[Maryland]], Judge [[Adam Abelson]] denied a preliminary injunction on August 1, 2025. Kalshi's appeal to the [[Fourth Circuit]] was docketed on August 6, 2025 as No. 25-1892, and on August 12 Maryland gave written assurance that it would forgo enforcement against Kalshi pending the outcome. The Ninth Circuit's opinion of August 28, 2026 records the Fourth Circuit appeal as pending.[^34]
|
||||
|
||||
In [[Ohio]], the [[Ohio Casino Control Commission]] sent cease-and-desist letters to prediction markets in 2025, and the Southern District of Ohio (Chief Judge Sarah Morrison) denied Kalshi a preliminary injunction on March 9, 2026. In [[Tennessee]], Judge Aleta Trauger had granted one on February 19, 2026. On September 25, 2026 a Sixth Circuit panel of Judges Clay, Gibbons and Bloomekatz, in an opinion by Judge Julia Gibbons after argument on July 30, 2026, affirmed the Ohio denial and vacated the Tennessee injunction, holding that Kalshi had not shown that sports event contracts are swaps and, alternatively, that the Commodity Exchange Act neither expressly nor impliedly preempts the states' gambling laws.[^35] Briefs for Kalshi were signed by [[Neal Katyal]] and Joshua Sterling of [[Milbank LLP]]. The opinion lists [[Elizabeth Prelogar]] of [[Cooley LLP]] and CFTC counsel Henry Dickman and M. Jordan Minot among counsel for amici, and cites the amicus brief of the Coalition for Prediction Markets "in support of Kalshi."[^35] Ohio's commission dated cease-and-desist notices October 2, 2026 to ten operators including Coinbase, Polymarket and Robinhood and did not include Kalshi; Covers reported that Ohio fined Kalshi 5 million dollars in April.[^36]
|
||||
|
||||
On January 20, 2026 [[Suffolk Superior Court]] Judge [[Christopher Barry-Smith]] ruled in Commonwealth v. KalshiEX LLC (No. 2584CV02525) that Kalshi could not offer sports wagering in [[Massachusetts]] without a license and said he would issue a preliminary injunction. Attorney General [[Andrea Campbell]] called the ruling "a major step toward fortifying Massachusetts' gambling laws."[^37] The matter is before the Supreme Judicial Court as No. SJC-13906 (Appeals Court No. 2026-P-244), where the CFTC filed an amicus brief on April 24, 2026 in support of Kalshi and of reversal.[^38]
|
||||
|
||||
On March 12, 2026 Kalshi sued Arizona officials in federal court. Five days later Attorney General [[Kris Mayes]] filed twenty misdemeanor counts against KalshiEX LLC in [[Maricopa County Superior Court]], sixteen for unlawful betting and four for election wagering, covering sports and political contracts.[^39] [[Morgan Lewis]] describes the filing as the first criminal prosecution of a CFTC-registered prediction market operator. The Ninth Circuit's August 2026 opinion records that the District of Arizona granted Kalshi a preliminary injunction against enforcement of Arizona's gambling laws on May 5, 2026 (appeal No. 26-2978) and that the Southern District of New York denied one on July 13, 2026.[^32]
|
||||
|
||||
Two California tribes, the [[Blue Lake Rancheria]] and the [[Chicken Ranch Rancheria]] of Me-Wuk Indians, sued Kalshi and [[Robinhood]] in the Northern District of California. Judge [[Jacqueline Scott Corley]] denied a preliminary injunction. On September 16, 2026 the Ninth Circuit held in Blue Lake Rancheria v. Kalshi, Inc., No. 25-7504, that the tribes were likely to succeed on their claim that the sports contracts violate the [[Indian Gaming Regulatory Act]], and returned the case to Judge Corley on the remaining injunction factors.[^40]
|
||||
|
||||
A putative class action filed January 8, 2026 in the Northern District of [[Illinois]] alleges that the sports contracts are unlicensed wagering. A federal judge transferred it to New York in April 2026, where similar suits are consolidated, and a Massachusetts bettor filed a class action in April 2026.[^41] On June 27, 2026 Kalshi sued Illinois officials in federal court over SB 3019, scheduled to take effect July 1, 2026.[^41]
|
||||
|
||||
The CFTC under Chairman [[Michael Selig]] has argued for its own exclusive jurisdiction in the state cases. Morgan Lewis records a CFTC amicus brief in the Ninth Circuit on February 17, 2026.[^39] Protos reported that Roth's name appears on federal complaints filed by the Justice Department against Illinois, Arizona and Connecticut.[^29] A law-firm summary records that the CFTC sent a proposed rule to the White House on September 28, 2026 that would define prediction market event contracts as swaps.[^42] Selig was confirmed by the Senate on December 18, 2025 and sworn in on December 22.[^43] The CFTC's Innovation Advisory Committee, announced February 12, 2026 with 35 members, lists Mansour and [[Shayne Coplan]] of [[Polymarket]] among them.[^44]
|
||||
|
||||
### Quintenz
|
||||
|
||||
Brian Quintenz served as a CFTC commissioner from August 2017 to September 2021.[^45] Kalshi's post of November 16, 2021 announcing that he had joined its board states: "It's been an honor to engage with Brian from the very early days of Kalshi when we were just starting the process of becoming a regulated exchange," and says he "authored a tour de force analysis of prediction markets and their treatment within the CFTC's regulatory ecosystem."[^14] The Block reported that shortly after leaving the commission Quintenz also joined the advisory board of Andreessen Horowitz; he later held the title head of crypto policy there.[^14][^46]
|
||||
|
||||
[[Donald Trump]]'s nomination of Quintenz to chair the CFTC was first reported by Bloomberg on the night of February 11, 2025.[^47] His ethics agreement, submitted to the Office of Government Ethics on May 21, 2025, pledged to resign from the boards of Kalshi, AH Capital Management (Andreessen Horowitz) and Next Level Derivatives, to divest equity within 90 days of confirmation, and to recuse from matters involving Kalshi for one year and Andreessen Horowitz for two.[^48] The Senate Agriculture Committee held his hearing on June 11, 2025.[^46] The committee's scheduled July 28, 2025 vote did not take place; Chairman [[John Boozman]] told Bloomberg the White House had asked him to delay it.[^46] The newsletter Closing Line reported that a Quintenz associate had emailed current CFTC officials in what appeared to be a request for non-public information about Kalshi's competitors, and Protos reported that FOIA documents showed his incoming staff seeking CFTC information about Kalshi's competitors and about the Winklevoss twins' lobbying against him.[^46][^49]
|
||||
|
||||
[[Tyler Winklevoss]] and [[Cameron Winklevoss]] of [[Gemini]] urged Trump in July 2025 to reconsider the pick, and in September 2025 Quintenz released private texts from Tyler Winklevoss. Politico reported late on September 30, 2025 that the White House had withdrawn the nomination, and Decrypt wrote that crypto lobbying, the dispute with the Winklevoss twins and opposition to Quintenz's Kalshi links "may have played a role."[^50] Quintenz joined the board of SUI Group Holdings on January 5, 2026, and The Block noted that his public LinkedIn profile still listed a Kalshi board seat.[^51] On July 9, 2026 he joined the [[Coalition for Prediction Markets]] as a senior advisor, and Global Gaming Insider wrote that he "currently maintains a position on Kalshi's Board of Directors."[^52]
|
||||
|
||||
### Political Ties
|
||||
|
||||
On January 13, 2025 Mansour announced on Kalshi's news site that [[Donald Trump Jr.]] had joined as a strategic advisor. The post quotes Trump Jr.: "On Election night at Mar-a-Lago, while biased outlets called the race a coin toss, my family and close friends used the prediction market Kalshi to know we won hours ahead of the fake news media. I immediately knew I had to contribute to their mission."[^53] Mansour told CNBC that the company is "not a political company in any way, shape or form."[^54] On August 26, 2025 Trump Jr.'s firm [[1789 Capital]] was reported to be investing "double-digit millions" in Polymarket, with Trump Jr. joining its advisory board.[^55]
|
||||
|
||||
In April 2026 Kalshi announced [[Stephanie Cutter]], co-founder of Precision Strategies and a former deputy campaign manager for Barack Obama's 2012 campaign, as a policy advisor.[^56] The Revolving Door Project, writing in the American Prospect, listed Cutter, Curtis Doster (formerly deputy chief of staff in the Biden White House, now an outside lobbyist) and [[John Bivona]] among former Democratic officials working for Kalshi, alongside [[Sean Patrick Maloney]] as head of the Coalition for Prediction Markets.[^57]
|
||||
|
||||
The Coalition for Prediction Markets was formed in December 2025 with Kalshi's Head of Corporate Development [[Sara Slane]] and Crypto.com's Matt David as executive board members. It named Maloney president and [[Patrick McHenry]] its first senior advisor on January 13, 2026, and its members include Kalshi, Crypto.com, Coinbase, Robinhood and Underdog.[^52] Prelogar of Cooley filed a Sixth Circuit amicus brief in Kalshi v. Orgel on behalf of the coalition, according to the Revolving Door Project.[^57]
|
||||
|
||||
On September 23, 2026 Democratic members of the [[Senate Banking Committee]], led by Ranking Member [[Elizabeth Warren]], wrote to Chairman [[Tim Scott]] requesting a public hearing on prediction markets. The letter states that, according to reports, Scott planned a roundtable that week with only Republican members, that "executives from Kalshi will be in attendance," and that Congress should examine prediction markets in a public hearing, "not behind closed doors in a Republican-only, industry-friendly roundtable." It cites a Punchbowl News report of September 18, 2026 and states that in December 2025 individuals traded nearly 12 billion dollars on Kalshi and Polymarket, citing the New York Times. The other signers were [[Catherine Cortez Masto]], [[Jack Reed]], [[Mark Warner]], [[Chris Van Hollen]], [[Tina Smith]], [[Raphael Warnock]], [[Andy Kim]], [[Ruben Gallego]], [[Lisa Blunt Rochester]] and [[Angela Alsobrooks]].[^58]
|
||||
|
||||
### Political Contributions
|
||||
|
||||
Federal Election Commission Schedule A data list contributions from Mansour, Lopes Lara and Mishory to both parties. Totals below exclude memo and transfer duplicates of joint fundraising committees and ActBlue conduit rows, and party is the committee's registered party or the party of its candidate or sponsor.[^59]
|
||||
|
||||
Mansour's contributions from 2020 through July 2026 total about 747,000 dollars: about 466,000 dollars to Republican candidates and committees, about 278,000 dollars to Democratic ones and 3,300 dollars to the Kennedy presidential committee. He gave 25 dollars through ActBlue to a Biden fund on August 28, 2020. In 2022 he gave 2,900 dollars each to Booker Victory Fund and Gillibrand for Senate on April 8, to Stabenow for US Senate on June 28 (two entries), and to Friends of John Thune on July 12, gave Boozman for Arkansas 5,800 dollars on July 23 (the record notes later refunds), and gave 5,800 dollars to the Maloney Victory Fund on October 27, 2022. On November 13, 2023 he gave 3,300 dollars to Team Kennedy, the Kennedy presidential committee. In 2025 he gave Ken Paxton for Senate 7,000 dollars on June 13, Lummis for Wyoming 5,000 dollars on June 23, the Cotton Majority Committee 5,000 dollars each on August 29 and September 25, the Sheehy Victory Committee 3,300 dollars on September 25, the Whatley Victory Committee 5,000 dollars on September 29 and Angie Craig for Minnesota 7,000 dollars across July 8 and September 2, and gave the California Democratic Party 9,800 dollars on October 22. In 2026 he gave the DSCC 44,300 dollars on January 21, the New York Majority Fund 19,000 dollars on January 20, the Blue Dog Victory Fund 26,000 dollars on March 25, the Steil Victory Fund 22,000 dollars on March 31, and 250,000 dollars to NRSC Victory on April 28. Smaller 2026 contributions went to House candidates of both parties on February 4, May 25 and June 2 to 16.[^59]
|
||||
|
||||
Lopes Lara gave 291 dollars to the Trump National Committee JFC on July 17, 2024. Her 2025 contributions were 5,000 dollars to Lummis for Wyoming on June 23 and 7,000 dollars to Angie Craig for Minnesota on September 2. On March 3, 2026 she gave the Republican National Committee 100,000 dollars (55,700 dollars to its legal proceedings account and 44,300 dollars), and on March 30 and 31 she gave 3,500 dollars twice each to the committees of Darren Soto, Lori Trahan, Emily Randall, Andrea Salinas and Vargas, and 5,000 dollars to the Willamette Valley PAC. On April 29, 2026 she gave 250,000 dollars to NRSC Victory. In late May 2026 she gave 3,500 dollars each to the committees of Republican House candidates including Andy Ogles, Scott DesJarlais, Andy Harris, Mark Harris, Nick Begich, Brandon Gill, Mary Miller and Davidson, and in June to Vindman for Congress and Mannion for New York. Her contributions total about 487,000 dollars: about 419,000 dollars to Republican committees and candidates and about 68,000 dollars to Democratic ones.[^59]
|
||||
|
||||
Mishory, listed in the records as Eliezer or Elie Mishory with the occupations "Kalshi attorney," "Kalshi CRO and counsel" and "Kalshi executive," gave to Cory Booker (April 12, 2022, 2,900 dollars), Kirsten Gillibrand (April 13, 2022, 2,900 dollars), John Boozman (May 5, 2022, 2,000 dollars, and July 22, 2022, 2,900 dollars), Debbie Stabenow (July 11, 2022, 2,900 dollars), John Thune (July 18, 2022, 2,900 dollars) and Torres for Congress (November 19, 2023, 6,000 dollars).[^59]
|
||||
|
||||
### Lobbying
|
||||
|
||||
Kalshi Inc. registered as its own lobbyist on July 31, 2025 under LDA registrant ID 401109813. Its in-house reports show 190,000 dollars in expenses for the third quarter of 2025, 175,000 dollars for the fourth, 430,000 dollars for the first quarter of 2026 (amended to 490,000 dollars on April 21, 2026) and 500,000 dollars for the second quarter.[^60] The in-house lobbyists include Sara Slane, John Bivona (a White House liaison at the [[Department of Homeland Security]] in 2021 and chief of staff to Representative [[Antonio Delgado]] from December 2018 to August 2020), [[Tony Hanagan]] (Republican cloakroom and floor staff, Senate, 2014 to 2026, who stated he will not contact the Senate until his post-employment restriction ends), and, in an August 2026 amendment, Chelsea Brossard (chief of staff to Representative Josh Gottheimer, 2023 to 2024) and Jamie Gillespie (Congress and White House legislative staff, 2015 to 2026).[^60]
|
||||
|
||||
Outside firms filed for Kalshi from December 2021. [[Rich Feuer Anderson]] reported 20,000 to 40,000 dollars a quarter until a termination effective June 1, 2024; its lobbyists included [[Jared Sawyer]] (deputy assistant secretary at the Treasury Department, senior counsel to the Senate Banking Committee) and Rashawn Mitchell (deputy chief of staff to Representative Joe Cunningham and adviser at the Office of Management and Budget). [[Capitol Counsel LLC]] registered in November 2022, reported 30,000 to 50,000 dollars a quarter, and terminated effective October 31, 2024 with a final 20,000 dollar report posted January 14, 2025. Its lobbyist [[De'Ana Dow]] lists service as counsel to CFTC Chairman [[William Rainer]] and as special adviser to CFTC Chairman [[James Newsome]], and is the only Kalshi lobbyist whose covered positions are at the CFTC. Dow Solutions Inc., which also lists Dow, registered in December 2025 and reported 10,000 to 20,000 dollars a quarter through the second quarter of 2026.[^60]
|
||||
|
||||
[[Miller Strategies]] registered in May 2024 and reported 50,000 to 120,000 dollars a quarter; its filings name [[Jeffrey Miller]], [[Jessica Mandel]] and, from 2026, Lucas Wallwork, Natalie McIntyre and James Grimm, whose covered positions include chief counsel to Representative [[Jim Jordan]], legislative director to Senator Bill Hagerty and a White House legislative affairs post. [[Lincoln Policy Group]] registered in June 2024 with former Senator [[Blanche Lincoln]] and reported 60,000 dollars a quarter. Tower 19 and Alva Elliott Partners, 2024 registrants that terminated effective October 2024, listed [[Jed Bhuta]] and [[Robert Russell]], the latter a former chief of staff to Senator [[Mark Pryor]]. Intersection reported 30,000, 45,000 and 45,000 dollars for the fourth quarter of 2025 and the first two quarters of 2026; its lobbyists include Curtis Doster (chief of staff to Representative Brenda Lawrence, senior counsel to Delgado) and Matthew McNally (chief of staff to Representative Sean Patrick Maloney). [[Squire Patton Boggs]] registered in March 2026 and reported 70,000 and 110,000 dollars for the first two quarters, with [[Thomas Andrews]] (staff to Speakers [[John Boehner]] and [[Paul Ryan]], White House legislative affairs 2018 to 2021) and [[Caren Street]] (staff to Senator [[Harry Reid]] 2008 to 2017, chief of staff to Representative [[Karen Bass]]). Resolution Public Affairs registered in April 2026 and reported 60,000 dollars for each of the first two quarters, with lobbyists formerly legislative directors to Senator [[Chuck Schumer]]. Forbes-Tate registered in July 2026. The second-quarter 2026 reports sum to 915,000 dollars across the in-house registrant and six outside firms.[^60]
|
||||
|
||||
Resolution Public Affairs' July 2026 report lists as issues S. 4469, the Prediction Markets Act of 2026, S. 4784, the Senate fiscal 2027 defense authorization bill, S. 4668, the Protect College Sports Act, and the purchase of event contracts by government employees.[^61] The Coalition for Prediction Markets has its own LDA filings: a registration by Invariant LLC posted May 15, 2026 (terminated in the second quarter) and a registration by Determinant LLC posted August 6, 2026.[^62]
|
||||
|
||||
### Revolving Door
|
||||
|
||||
Elie Mishory held leadership roles in the CFTC's Division of Market Oversight and served as counsel to Commissioner Quintenz before joining Kalshi, where he was chief regulatory officer and general counsel from before the exchange's launch. Protos reported that he stepped down in March 2025 for a role connected to the Department of Government Efficiency at the Securities and Exchange Commission with the title senior advisor to the chairman. On June 23, 2026 [[Novig]] announced him as chief regulatory and legal affairs officer.[^63]
|
||||
|
||||
Joshua Sterling, a Milbank partner on Kalshi's Sixth Circuit briefs, was Director of the CFTC's Market Participants Division under Chairman [[Heath Tarbert]].[^35][^64] [[Brian Nelson]], a former Under Secretary of the Treasury for Terrorism and Financial Intelligence and a Cooley partner, was engaged by Kalshi in February 2026 to advise on market integrity, trading surveillance and financial compliance.[^3] Protos reported that Roth moved from Jones Day to the Justice Department's Civil Division in February 2025, with the title Principal Deputy Assistant Attorney General.[^29]
|
||||
|
||||
### Media and Brokerage Partnerships
|
||||
|
||||
Robinhood introduced Super Bowl event contracts through Kalshi in early February 2025 and, by February 5, 2025, had suspended the offering a day after listing it, following a CFTC request, according to Finance Magnates, which also reported a CFTC review of Super Bowl contracts offered by Crypto.com and Kalshi. [[Webull]] announced its Kalshi partnership on February 12, 2025.[^65] [[Coinbase]] announced on January 28, 2026 that prediction markets were live in all 50 states with all contracts supplied by Kalshi, after Coinbase first announced its prediction-market plans in December 2025.[^66]
|
||||
|
||||
On December 2, 2025 [[CNN]] named Kalshi its official prediction markets partner, with Chief Data Analyst [[Harry Enten]] to lead use of the data and a Kalshi-powered ticker on air.[^67] [[CNBC]] announced a similar arrangement days later covering its television, digital and subscription products. Popular Information reported on July 6, 2026 that the CNN arrangement is exclusive, so that CNN cannot mention Polymarket odds, and that CNBC invested in Kalshi and receives a fee for referring new users; CNBC's disclosure on some articles reads "CNBC and Kalshi have a commercial relationship that includes customer acquisition and a minority investment."[^68]
|
||||
|
||||
### Integrity
|
||||
|
||||
On February 5, 2026 Kalshi announced an independent Surveillance Advisory Committee (Lisa Pinheiro of Analysis Group and Daniel Taylor of the Wharton Forensic Analytics Lab), a surveillance partnership with Solidus Labs, and the engagement of Brian Nelson.[^3] On February 25, 2026 Kalshi said it had opened 200 investigations over the past year. It reported a two-year suspension and a penalty of five times the trade size, over 20,000 dollars, against Artem Kaptur, an editor who worked for MrBeast, and a five-year ban and a penalty of ten times the trade size against Kyle Langford, a California gubernatorial candidate who had bet about 200 dollars on his own race, and said it had reported both cases to the CFTC.[^69]
|
||||
|
||||
On April 22, 2026 Kalshi announced five-year suspensions and fines for three congressional candidates who had traded on their own races, Mark Moran of Virginia, Matt Klein of Minnesota and Ezekiel Enriquez of Texas, and fined Moran 6,229.30 dollars after he refused to settle.[^70] Kalshi reported more than 150 insider-trading investigations opened in the first quarter of 2026, more than 100 potential trades blocked and at least 20 referrals to law enforcement, together with a risk-scoring framework and employment verification for traders on high-risk markets.[^71]
|
||||
|
||||
### Footnotes
|
||||
|
||||
[^1]: Y Combinator, "Kalshi," company profile (Winter 2019 batch, founded 2019, founders Luana Lopes Lara and Tarek Mansour, tagline "1st federally regulated exchange where people can trade on events"). https://www.ycombinator.com/companies/kalshi
|
||||
[^2]: Kalshi, "Kalshi Raises $30 Million in Series A Funding Led by Sequoia," February 17, 2021. https://news.kalshi.com/p/kalshi-raises-30-million-in-series-a-funding-led-by-sequoia
|
||||
[^3]: Kalshi, "Kalshi announces independent surveillance audit committee, partnerships with director of Wharton Forensic Analytics Lab and Solidus Labs, and new head of enforcement," February 5, 2026 ("Founded in 2018... Its founders spent the first few years of the company's inception getting regulatory approval from the CFTC, before they launched a single product"; engagement of Brian Nelson; Surveillance Advisory Committee; Solidus Labs). https://news.kalshi.com/p/kalshi-surveillance-insider-trading-prevention
|
||||
[^4]: SEC Form D, Kalshi Inc. (CIK 1806928), accession 0001806928-20-000001, date of first sale March 4, 2020, filed March 19, 2020; sold $6,094,999 to 28 investors; year of incorporation 2018; related persons Tarek Mansour and Luana Lopes Lara. https://www.sec.gov/Archives/edgar/data/1806928/000180692820000001/primary_doc.xml
|
||||
[^5]: KalshiEX LLC, Form DCM petition for modification of order of designation, submitted November 29, 2023 (transmittal by Elie Mishory, chief regulatory officer; item 7 date of formation December 10, 2019; item 8 Delaware; signed by Tarek Mansour, chief executive officer). https://www.cftc.gov/filings/documents/2023/orgkexkalshipetition231130.pdf
|
||||
[^6]: Commodity Futures Trading Commission, Release Number 8302-20, "CFTC Designates KalshiEX LLC as a Contract Market," November 4, 2020. https://www.cftc.gov/PressRoom/PressReleases/8302-20
|
||||
[^7]: Commodity Futures Trading Commission, Order of Designation, KalshiEX LLC, November 3, 2020. https://www.cftc.gov/filings/documents/2020/orgkexkalshidesignation201103.pdf
|
||||
[^8]: Commodity Futures Trading Commission, Amended Order of Designation, KalshiEX LLC, January 17, 2025, quoting the provision of the original order and reciting submissions dated November 27, 2023 through December 9, 2024. https://www.cftc.gov/filings/documents/2025/orgdcmkexkalshiamord250117.pdf
|
||||
[^9]: Commodity Futures Trading Commission, Release Number 8957-24, "CFTC Grants Kalshi Klear LLC DCO Registration," August 29, 2024. https://www.cftc.gov/PressRoom/PressReleases/8957-24
|
||||
[^10]: SEC Form D, Kalshi Inc., accession 0001806928-21-000001, date of first sale December 18, 2020, filed February 23, 2021; sold $29,999,999 to 10 investors; related persons Tarek Mansour, Luana Lopes Lara and Alfred Lin. https://www.sec.gov/Archives/edgar/data/1806928/000180692821000001/primary_doc.xml
|
||||
[^11]: Ali Partovi, "Kalshi raises $30M from Sequoia and Wall St titans," Neo newsletter, February 19, 2021. https://neo.substack.com/p/kalshi-raises-30m-from-sequoia-and
|
||||
[^12]: SEC Form D, Kalshi Inc., accession 0001231919-25-000437, date of first sale November 3, 2021, signature and filing date November 6, 2025; sold $69,999,989 to 14 investors; related persons Tarek Mansour, Luana Lopes Lara, Alfred Lin, Michael Seibel and Matt Huang. https://www.sec.gov/Archives/edgar/data/1806928/000123191925000437/primary_doc.xml
|
||||
[^13]: DefiLlama, Kalshi pre-IPO valuation table (entry dated November 3, 2021, labeled Series B, $749.83M). https://defillama.com/pre-ipo/kalshi
|
||||
[^14]: Kalshi, "Former CFTC Commissioner Brian Quintenz Joins Our Board," November 16, 2021. https://news.kalshi.com/p/former-cftc-commissioner-brian-quintenz-joins-our-board ; Kollen Post, "Brian Quintenz joins board of the first CFTC-regulated 'events market,'" The Block, November 16, 2021 (Quintenz "stepped down as commissioner of the CFTC this summer"; joined the a16z advisory board). https://www.theblock.co/post/124482/brian-quintenz-joins-board-of-the-first-cftc-regulated-events-market
|
||||
[^15]: Daniel Kuhn, "Kalshi raising $185 million at $2 billion valuation in a Series C round led by Paradigm," The Block, June 25, 2025. https://www.theblock.co/post/359661/kalshi-raising-100-million-at-1-billion-valuation-with-backing-from-paradigm-report ; Decrypt, "Prediction Market Kalshi Notches $2 Billion Valuation With $185 Million Raise," June 25, 2025, reproducing Mansour's post. https://decrypt.co/327074/prediction-market-kalshi-2-billion-valuation-185-million-raise
|
||||
[^16]: SEC Form D, Kalshi Inc., accession 0001231919-25-000391, date of first sale June 24, 2025, filed October 30, 2025; sold $124,999,957 to 14 investors. https://www.sec.gov/Archives/edgar/data/1806928/000123191925000391/primary_doc.xml
|
||||
[^17]: Kalshi, "Kalshi hits $5 billion valuation amid international expansion," October 10, 2025. https://news.kalshi.com/p/kalshi-hits-5-billion-valuation-amid-international-expansion
|
||||
[^18]: SEC Form D, Kalshi Inc., accession 0001231919-25-000344, date of first sale October 8, 2025, filed October 23, 2025; offering $389,999,943, sold $294,500,203 to 20 investors; related persons Tarek Mansour, Luana Lopes Lara, Alfred Lin, Michael Seibel and Matt Huang. https://www.sec.gov/Archives/edgar/data/1806928/000123191925000344/primary_doc.xml
|
||||
[^19]: Fortune, "Exclusive: Paradigm, a major investor in Kalshi, is building its own prediction markets trading terminal, sources say," as reproduced on Yahoo Finance. https://finance.yahoo.com/markets/crypto/articles/exclusive-paradigm-major-investor-kalshi-145657335.html
|
||||
[^20]: Kalshi, "Kalshi Reaches $11 Billion Valuation as App Takes over America," December 2, 2025. https://news.kalshi.com/p/kalshi-11-billion-valuation-series-e ; Timmy Shen, "Kalshi secures $1 billion in latest funding at $11 billion valuation: report," The Block, November 20, 2025, relaying TechCrunch. https://www.theblock.co/post/379851/kalshi-1-billion-funding
|
||||
[^21]: SEC Form D, Kalshi Inc., accession 0001231919-25-000572, date of first sale November 19, 2025, filed December 4, 2025; offering $999,996,557, sold $820,819,303 to 31 investors. https://www.sec.gov/Archives/edgar/data/1806928/000123191925000572/primary_doc.xml
|
||||
[^22]: Brian Danga, "Kalshi hits $22 billion valuation after $1 billion raise led by Coatue," The Block, May 7, 2026, reporting Kalshi's statement. https://www.theblock.co/post/400413/kalshi-hits-22-billion-valuation-after-1-billion-raise-led-by-coatue ; Quartz, "Kalshi raises $1 billion Series F at $22 billion valuation," May 8, 2026. https://qz.com/kalshi-series-f-billion-valuation-prediction-markets-050826
|
||||
[^23]: SEC Form D, Kalshi Inc., accession 0001231919-26-001066, date of first sale April 3, 2026, filed August 25, 2026; offering $1,499,997,894, sold $1,120,010,122 to 71 investors. https://www.sec.gov/Archives/edgar/data/1806928/000123191926001066/primary_doc.xml
|
||||
[^24]: SEC Form D, Soma Capital Kalshi SPV, LP (CIK 1901470), accession 0001901470-22-000001, first sale January 14, 2022, signed April 13, 2022, sold $2,500,000 to one investor; SEC Form D, SC Kalshi SPV II LLC (CIK 2033504), accession 0002033504-25-000001, first sale April 17, 2025, signed May 1, 2025.
|
||||
[^25]: SEC EDGAR full-text search for "Kalshi," Form D results (HII Kalshi-01 through HII Kalshi-06, filed 2026; Latitude Ventures Kalshi, filed December 16, 2025 and May 26, 2026; Dominari Master SPV LLC Series XXIX Kalshi, filed February 19, 2026; DMM Kalshi I, LLC, filed March 13, 2026; Kalshi SPV, LLC and Kalshi SPV1 EVP 0626, filed July 2026). https://efts.sec.gov/LATEST/search-index?q=%22Kalshi%22&forms=D
|
||||
[^26]: 17 C.F.R. 230.503(a)(1), Filing of notice of sales. https://www.law.cornell.edu/cfr/text/17/230.503
|
||||
[^27]: KalshiEX LLC v. Commodity Futures Trading Commission, No. 1:23-cv-03257 (JMC) (D.D.C.), Memorandum Opinion, September 12, 2024 (ECF 51), pp. 8 to 9 and 26 to 27. https://www.govinfo.gov/content/pkg/USCOURTS-dcd-1_23-cv-03257/pdf/USCOURTS-dcd-1_23-cv-03257-0.pdf
|
||||
[^28]: Finance Magnates, "CFTC Folds Its Hand in Election Betting Showdown with Kalshi," May 5, 2025 (voluntary dismissal of the appeal after a 3 to 0 commission vote, each party bearing its own costs). https://www.financemagnates.com/forex/cftc-folds-its-hand-in-election-betting-showdown-with-kalshi
|
||||
[^29]: Protos, "The revolving door for lawyers between Kalshi and DOJ" (Yaakov Roth argued the full appeal in January 2025 for Jones Day, joined the Department of Justice in February 2025; his name appears on federal complaints against Illinois, Arizona and Connecticut). https://protos.com/the-revolving-door-for-lawyers-between-kalshi-and-doj/
|
||||
[^30]: KalshiEX, LLC v. Flaherty, No. 25-1922 (3d Cir. April 6, 2026) (Chagares, Chief Judge, Porter and Roth, Circuit Judges; opinion of the court by Porter; Roth dissenting; argued September 10, 2025; appeal from D.N.J. No. 1:25-cv-02152, Judge Kiel). https://www2.ca3.uscourts.gov/opinarch/251922p.pdf
|
||||
[^31]: Preliminary injunction of April 2025: https://igamingbusiness.com/sports-betting/state-of-the-union-april-11-kalshi-wins-injunction ; dissolution of November 24, 2025 and denial of stay of December 2025, as recorded in KalshiEX, LLC v. Assad, No. 25-7516 (9th Cir. August 28, 2026), and reported at https://casinobeats.com/2025/11/26/nevada-judge-dissolves-kalshi-injunction-stay-ninth-circuit/
|
||||
[^32]: KalshiEX, LLC v. Assad, No. 25-7516 (9th Cir. August 28, 2026), opinion by Judge R. Nelson, concurrence by Judge Lee (argued April 16, 2026), pp. 14 to 17 and note 2 (Fourth Circuit appeal No. 25-1892 pending; D. Ariz. May 5, 2026 injunction, appeal No. 26-2978; S.D.N.Y. July 13, 2026 denial; D. Md. 793 F. Supp. 3d 667; M.D. Tenn. February 19, 2026; S.D. Ohio March 9, 2026). https://www.courthousenews.com/wp-content/uploads/2026/08/kalshiex-ninth-circuit-decision.pdf
|
||||
[^33]: Supreme Court of the United States, docket No. 26-299, Flaherty v. KalshiEX, LLC (lower court 3d Cir. No. 25-1922, decision date April 6, 2026; petition filed September 2, 2026; docketed September 8, 2026; response extended to November 9, 2026). https://www.supremecourt.gov/docket/docketfiles/html/public/26-299.html
|
||||
[^34]: Maryland: preliminary injunction denied by Judge Adam Abelson on August 1, 2025, https://news.worldcasinodirectory.com/maryland-judge-rejects-kalshis-bid-to-block-state-gambling-laws-denies-motion-for-preliminary-injunction-119243 ; non-enforcement assurance of August 12, 2025 and briefing schedule, https://www.sportsbettingdime.com/news/betting/maryland-enforcement-efforts-against-kalshi-paused-until-appeal-ruling/ ; appeal docketed August 6, 2025, KalshiEX, LLC v. Assad, note 2 (see above).
|
||||
[^35]: KalshiEX LLC v. Schuler, Nos. 26-3196/5235, and KalshiEX LLC v. Orgel (6th Cir. September 25, 2026) (Clay, Gibbons and Bloomekatz; opinion by Gibbons; argued July 30, 2026; S.D. Ohio No. 2:25-cv-01165, Judge Morrison; M.D. Tenn. No. 3:26-cv-00034, Judge Trauger). https://www.opn.ca6.uscourts.gov/opinions.pdf/26a0272p-06.pdf
|
||||
[^36]: Covers, "Ohio Sends Cease-and-Desists to 10 Prediction Market Companies," October 5, 2026 (notices dated October 2; Kalshi not among them; "Kalshi, which sued Ohio in 2025, was fined $5 million by the Buckeye State in April"). https://www.covers.com/industry/ohio-regulator-sends-cease-and-desist-notices-to-10-prediction-market-companies-oct-5-2026 ; Gambling Insider on the March 9, 2026 denial and the April 2025 letters. https://www.gamblinginsider.com/news/117023/kalshi-ohio-injunction-sixth-circuit-split-jpg
|
||||
[^37]: Reuters, "Massachusetts judge rules Kalshi cannot let state residents bet on sports," January 20, 2026, as published by NBC News. https://www.nbcnews.com/news/us-news/kalshi-cannot-operate-sports-prediction-market-massachusetts-judge-rul-rcna255130
|
||||
[^38]: Commonwealth of Massachusetts v. KalshiEX LLC, SJC-13906 (Appeals Court No. 2026-P-244), Amicus Brief of the Commodity Futures Trading Commission in Support of Appellant, April 24, 2026. https://www.cftc.gov/media/13771/ENFAmicusMassachusettsReview042426/download
|
||||
[^39]: Morgan Lewis, "Arizona Files First Criminal Charges Against a Prediction Market," March 2026 (twenty counts, sixteen unlawful betting and four election wagering, filed March 17, 2026; Kalshi federal suit March 12; CFTC amicus brief in the Ninth Circuit February 17, 2026). https://www.morganlewis.com/pubs/2026/03/arizona-files-first-criminal-charges-against-a-prediction-market
|
||||
[^40]: Buchalter, "Ninth Circuit: Kalshi's sports contracts are Class III gaming on tribal land and tribes can sue to stop them" (Blue Lake Rancheria v. Kalshi, Inc., No. 25-7504, September 16, 2026; Judge Corley's denial; remand). https://www.buchalter.com/insights/ninth-circuit-kalshis-sports-contracts-are-class-iii-gaming-on-tribal-land-and-tribes-can-sue-to-stop-them/
|
||||
[^41]: CasinoBeats, class action filed January 8, 2026 in the Northern District of Illinois, https://casinobeats.com/2026/01/09/illinois-class-action-alleges-kalshi-operates-illegal-gambling-platform/ ; Law360, "Illinois Judge Sends Kalshi Gambling Suit To New York," April 22, 2026, https://www.law360.com/articles/2468509 ; Boston Globe, "Mass. gambler sues Kalshi seeking repayment for lost bets," April 29, 2026, https://boston.com/news/local-news/2026/04/29/mass-gambler-sues-kalshi-seeking-repayment-for-lost-bets ; OpenClassActions, Kalshi v. Illinois (SB 3019), June 27, 2026. https://openclassactions.com/news/kalshi-illinois-sb-3019-prediction-market-lawsuit.php
|
||||
[^42]: National Law Review, "Sixth Circuit Deepens Circuit Split" (CFTC proposed rule RIN 3038-AF82 sent to the White House September 28, 2026). https://natlawreview.com/article/sixth-circuit-deepens-circuit-split-kalshi-sports-event-contracts-are-not-swaps-and
|
||||
[^43]: WilmerHale, "Michael Selig Confirmed as CFTC Chairman: Six Issues to Watch in 2026," December 18, 2025, https://www.wilmerhale.com/en/insights/client-alerts/20251218-michael-selig-confirmed-as-cftc-chairman---six-issues-to-watch-in-2026 ; swearing-in December 22 as reported at https://globalgaminginsider.com/news/5734/former-cftc-commissioner-brian-quintenz-joins-coalition-for-prediction-markets-as-senior-advisor
|
||||
[^44]: Commodity Futures Trading Commission, Release Number 9182-26, "CFTC Announces Innovation Advisory Committee Members," February 12, 2026, as reproduced at https://mondovisione.com/media-and-resources/news/cftc-announces-innovation-advisory-committee-members-2026212/
|
||||
[^45]: Global Gaming Insider, "Former CFTC Commissioner Brian Quintenz joins Coalition for Prediction Markets as Senior Advisor," July 9, 2026 ("Quintenz served as Commissioner of the CFTC from August 2017 to September 2021"). https://globalgaminginsider.com/news/5734/former-cftc-commissioner-brian-quintenz-joins-coalition-for-prediction-markets-as-senior-advisor
|
||||
[^46]: Dan Bernstein, "Brian Quintenz's CFTC Nomination Paused by White House Intervention," Sportico, July 28, 2025. https://www.sportico.com/business/sports-betting/2025/brian-quintenz-senate-cftc-donald-trump-1234863512/
|
||||
[^47]: Dayton Hawk, "Trump nominates Kalshi board member as CFTC chief," iGaming Business, February 12, 2025 (Bloomberg reported the nomination Tuesday night). https://igamingbusiness.com/sports-betting/online-sports-betting/cftc-nominee-kalshi-board-member/
|
||||
[^48]: CasinoBeats, "Trump's CFTC Nomination Quintenz to Resign From Kalshi, Recuse Himself on Related Matters," May 29, 2025, reporting the ethics agreement submitted to the Office of Government Ethics on May 21, 2025. https://casinobeats.com/2025/05/29/trumps-cftc-nomination-quintenz-to-resign-from-kalshi-recuse-himself-on-related-matters/ ; Yogonet, May 28, 2025. https://www.yogonet.com/international/news/2025/05/28/106262-trumpnominated-brian-quintenz-to-resign-from-kalshi-39s-board-of-directors-if-confirmed
|
||||
[^49]: Protos, "The revolving door for lawyers between Kalshi and DOJ" (FOIA documents on Quintenz's incoming staff; Mishory). https://protos.com/the-revolving-door-for-lawyers-between-kalshi-and-doj/
|
||||
[^50]: Callan Quinn, "White House Pulls Quintenz CFTC Chair Nomination After Clash With Winklevoss Twins," Decrypt, October 1, 2025, citing Politico. https://decrypt.co/342460/white-house-pulls-quintenz-cftc-chair-nomination-after-clash-with-winklevoss-twins
|
||||
[^51]: Brian Quintenz joins SUI Group board, The Block, January 2026. https://www.theblock.co/post/384484/brian-quintenz-joins-sui-group-board-following-failed-cftc-chair-bid
|
||||
[^52]: Global Gaming Insider, July 9, 2026 (coalition formed in December 2025; Maloney president and McHenry first senior advisor on January 13, 2026; members Kalshi, Crypto.com, Coinbase, Robinhood and Underdog; Slane and Matt David executive board members). https://globalgaminginsider.com/news/5734/former-cftc-commissioner-brian-quintenz-joins-coalition-for-prediction-markets-as-senior-advisor
|
||||
[^53]: Tarek Mansour, "Kalshi names Donald Trump Jr. as strategic advisor," Kalshi, January 13, 2025. https://news.kalshi.com/p/donald-trump-jr-strategic-advisor
|
||||
[^54]: Jesse Pound, "Kalshi names Donald Trump Jr. as strategic advisor to prediction market firm," CNBC, January 13, 2025, as published by NBC Chicago. https://www.nbcchicago.com/news/business/money-report/kalshi-names-donald-trump-jr-as-strategic-adviser-to-prediction-market-firm/3644650/?amp=1
|
||||
[^55]: Front Office Sports, "Kalshi Advisor Donald Trump Jr. Joins Rival Polymarket Board," August 26, 2025. https://frontofficesports.com/donald-trump-jr-kalshi-polymarket/
|
||||
[^56]: PR News, "Kalshi Taps Precision's Cutter," O'Dwyer's, April 3, 2026. https://www.odwyerpr.com/story/public/24567/2026-04-03/kalshi-taps-precisions-cutter.html ; Casino.org, April 2, 2026. https://www.casino.org/news/kalshi-goes-bipartisan-taps-obama-staffer-policy-advisor/
|
||||
[^57]: Revolving Door Project, "Economic hit men for gambling apps," The American Prospect, July 7, 2026. https://prospect.org/2026/07/07/economic-hit-men-for-gambling-apps/
|
||||
[^58]: Letter from Democratic members of the U.S. Senate Committee on Banking, Housing, and Urban Affairs to Chairman Tim Scott, September 23, 2026 (signed by Elizabeth Warren and ten other senators). https://www.banking.senate.gov/imo/media/doc/2026.09.23%20Letter%20to%20Chair%20Scott%20re%20Prediction%20Market%20Roundtable.pdf
|
||||
[^59]: Federal Election Commission, Schedule A, individual contributions by contributor name "Mansour, Tarek," "Lopes Lara, Luana" and "Mishory," and by contributor employer "Kalshi," queried October 13, 2026 (committee party from the committee record; totals computed excluding memo code X rows and ActBlue conduit rows). https://api.open.fec.gov/v1/schedules/schedule_a/
|
||||
[^60]: U.S. Senate Lobbying Disclosure Act database, 75 filings with client "Kalshi," queried October 13, 2026, with covered positions and amounts as listed on each filing: https://lda.senate.gov/api/v1/filings/?client_name=Kalshi ; registrant record, Kalshi Inc., LDA ID 401109813, https://lda.senate.gov/api/v1/registrants/401109813/
|
||||
[^61]: Resolution Public Affairs, LLC, second-quarter 2026 report for Kalshi Inc., posted July 20, 2026. https://lda.gov/filings/public/filing/a24aede2-fd6c-4e8b-8f48-a752fd800691/print/
|
||||
[^62]: U.S. Senate Lobbying Disclosure Act database, client search "Coalition for Prediction Markets," queried October 13, 2026. https://lda.senate.gov/api/v1/filings/?client_name=Coalition%20for%20Prediction%20Markets
|
||||
[^63]: Novig, "Novig Appoints Elie Mishory as Chief Regulatory and Legal Affairs Officer," PR Newswire, June 2026. https://www.prnewswire.com/news-releases/novig-appoints-elie-mishory-as-chief-regulatory-and-legal-affairs-officer-to-help-lead-the-next-chapter-of-federally-regulated-sports-trading-302807001.html ; Protos (March 2025 departure and SEC role). https://protos.com/the-revolving-door-for-lawyers-between-kalshi-and-doj/
|
||||
[^64]: Milbank LLP, "Josh Sterling" (Director of the CFTC's Market Participants Division). https://www.milbank.com/en/professionals/josh-sterling.html
|
||||
[^65]: Damian Chmiel, "Webull Dares to Enter Prediction Markets Where Robinhood Failed," Finance Magnates, February 13, 2025. https://www.financemagnates.com/forex/webull-dares-to-enter-prediction-markets-where-robinhood-failed/
|
||||
[^66]: Decrypt, "Coinbase Rolls Out Kalshi-Powered Prediction Markets Across United States," January 28, 2026. https://decrypt.co/356236/coinbase-rolls-out-kalshi-powered-prediction-markets-across-united-states
|
||||
[^67]: The Block, "Kalshi becomes CNN's official partner, integrating prediction market data into programming," December 2, 2025. https://www.theblock.co/post/381164/kalshi-cnn-partner
|
||||
[^68]: Finance Magnates, "First CNN, Now CNBC: Kalshi's Event Odds Go Prime Time." https://www.financemagnates.com/forex/first-cnn-now-cnbc-kalshis-event-odds-go-prime-time/ ; Judd Legum, "UPDATE: Kalshi, CNBC, and CNN respond," Popular Information, July 7, 2026. https://popular.info/p/update-kalshi-cnbc-and-cnn-respond
|
||||
[^69]: Yogonet, "Kalshi suspends MrBeast editor and former California candidate in insider trading cases," February 26, 2026. https://www.yogonet.com/international/news/2026/02/26/117792-kalshi-suspends-mrbeast-editor-and-former-california-candidate-in-insider-trading-cases
|
||||
[^70]: CNBC, "Kalshi suspends, fines 3 congressional candidates in 'insider trading' enforcement actions," April 22, 2026. https://www.cnbc.com/2026/04/22/kalshi-insider-trading-congress.html
|
||||
[^71]: The Defiant, "Kalshi Reports 150+ Insider-Trading Investigations in Q1, Rolls Out Employer Checks for High-Risk Markets." https://thedefiant.io/news/regulation/kalshi-insider-trading-investigations-q1-employer-checks
|
||||
359
20 - ORGANIZATIONS/PRIVATE/Polymarket.md
Normal file
359
20 - ORGANIZATIONS/PRIVATE/Polymarket.md
Normal file
|
|
@ -0,0 +1,359 @@
|
|||
---
|
||||
aliases:
|
||||
- Polymarket.com
|
||||
- Polymarket US
|
||||
- Blockratize
|
||||
- Blockratize Inc.
|
||||
- Blockratize, Inc.
|
||||
- Adventure One QSS
|
||||
- Adventure One QSS Inc.
|
||||
- QCX LLC
|
||||
- QCEX
|
||||
category: "Private Organization"
|
||||
tags:
|
||||
- Organization
|
||||
- Polymarket
|
||||
- PredictionMarkets
|
||||
- EventContracts
|
||||
- CFTC
|
||||
- ShayneCoplan
|
||||
- FoundersFund
|
||||
- BlockchainCapital
|
||||
- IntercontinentalExchange
|
||||
- DonaldTrumpJr
|
||||
- InsiderTrading
|
||||
- Lobbying
|
||||
- Panama
|
||||
- Crypto
|
||||
location: "New York, New York"
|
||||
summary: "Polymarket is a New York prediction market that a 2022 CFTC order found had run an unregistered event-contract facility, and whose investors include Founders Fund, Intercontinental Exchange and Donald Trump Jr.'s 1789 Capital."
|
||||
created: 2026-10-13
|
||||
updated: 2026-10-13
|
||||
relations:
|
||||
- type: founded
|
||||
with: "[[Shayne Coplan]]"
|
||||
reverse: true
|
||||
start: 2020
|
||||
fn: 1
|
||||
- type: funded
|
||||
with: "[[Polychain Capital]]"
|
||||
reverse: true
|
||||
role: "reported lead of a seed round of about 4 million dollars; participant in the 2024 Series A"
|
||||
start: 2020-10
|
||||
fn: 17
|
||||
- type: funded
|
||||
with: "[[General Catalyst]]"
|
||||
reverse: true
|
||||
role: "lead of the 25 million dollar Series A"
|
||||
start: 2024-05
|
||||
fn: 19
|
||||
- type: funded
|
||||
with: "[[Founders Fund]]"
|
||||
reverse: true
|
||||
role: "lead of the 45 million dollar Series B"
|
||||
start: 2024-05
|
||||
fn: 19
|
||||
- type: funded
|
||||
with: "[[Founders Fund]]"
|
||||
reverse: true
|
||||
role: "lead of the 2025 round, reported by Bloomberg as more than 200 million dollars at about 1 billion dollars and described by Coplan as 150 million dollars at 1.2 billion dollars"
|
||||
start: 2025-06
|
||||
fn: 26
|
||||
- type: funded
|
||||
with: "[[Blockchain Capital]]"
|
||||
reverse: true
|
||||
role: "lead of a 55 million dollar round at a 350 million dollar post-money valuation"
|
||||
start: 2024
|
||||
fn: 20
|
||||
- type: funded
|
||||
with: "[[Intercontinental Exchange]]"
|
||||
reverse: true
|
||||
role: "1.0 billion dollars for Series D preferred stock on October 7, 2025, and 600 million dollars for Series E preferred stock on March 26, 2026"
|
||||
start: 2025-10-07
|
||||
fn: 30
|
||||
- type: funded
|
||||
with: "[[1789 Capital]]"
|
||||
reverse: true
|
||||
role: "strategic investment, later reported at 200 million dollars, followed by a reported 300 million dollars in the 2026 round"
|
||||
start: 2025-08-26
|
||||
fn: 31
|
||||
- type: owned
|
||||
with: "[[QCX LLC]]"
|
||||
role: "bought the holding company of QCEX for 112 million dollars"
|
||||
start: 2025-07-21
|
||||
fn: 14
|
||||
- type: prosecuted
|
||||
with: "[[Commodity Futures Trading Commission]]"
|
||||
reverse: true
|
||||
role: "filed and settled charges; 1.4 million dollar civil monetary penalty"
|
||||
start: 2022-01-03
|
||||
fn: 1
|
||||
- type: investigated
|
||||
with: "[[Federal Bureau of Investigation]]"
|
||||
reverse: true
|
||||
role: "executed a search warrant at the Manhattan home of the chief executive"
|
||||
start: 2024-11-13
|
||||
fn: 37
|
||||
- type: investigated
|
||||
with: "[[Department of Justice]]"
|
||||
reverse: true
|
||||
role: "criminal inquiry into access by U.S. users, closed by declination notice"
|
||||
start: 2024-11
|
||||
end: 2025-07
|
||||
fn: 38
|
||||
- type: member_of
|
||||
with: "[[Donald Trump Jr.]]"
|
||||
reverse: true
|
||||
role: "member of the advisory board"
|
||||
start: 2025-08-26
|
||||
fn: 31
|
||||
- type: member_of
|
||||
with: "[[J. Christopher Giancarlo]]"
|
||||
reverse: true
|
||||
role: "chairman of the advisory board"
|
||||
start: 2022-05-19
|
||||
fn: 35
|
||||
- type: director_of
|
||||
with: "[[Bart Stephens]]"
|
||||
reverse: true
|
||||
role: "director named in the Form D filed October 18, 2024"
|
||||
start: 2024-10-04
|
||||
fn: 11
|
||||
- type: director_of
|
||||
with: "[[Joshua Rivera]]"
|
||||
reverse: true
|
||||
role: "director named in the Form D amendment of February 25, 2025 and the Form D of August 1, 2025"
|
||||
start: 2025-02-11
|
||||
fn: 23
|
||||
- type: director_of
|
||||
with: "[[Shayne Coplan]]"
|
||||
reverse: true
|
||||
role: "president of Adventure One QSS Inc. from December 22, 2021 to April 7, 2022; remains a director"
|
||||
start: 2021-12-22
|
||||
fn: 2
|
||||
- type: employed_by
|
||||
with: "[[Richard Jaycobs]]"
|
||||
reverse: true
|
||||
role: "Head of Market Expansion"
|
||||
start: 2024-05
|
||||
fn: 19
|
||||
- type: represented
|
||||
with: "[[Advocus Partners]]"
|
||||
reverse: true
|
||||
role: "registered lobbyist for Blockratize, Inc. on digital asset policy and information markets, 90,000 dollars per quarter"
|
||||
start: 2025-04-21
|
||||
fn: 44
|
||||
- type: partner_of
|
||||
with: "[[TKO Group]]"
|
||||
role: "official and exclusive prediction market partner of UFC and Zuffa Boxing"
|
||||
start: 2025-11-12
|
||||
fn: 64
|
||||
- type: partner_of
|
||||
with: "[[Dow Jones]]"
|
||||
role: "exclusive prediction market partner; data on WSJ, Barron's, MarketWatch and Investor's Business Daily"
|
||||
start: 2026-01-07
|
||||
fn: 62
|
||||
---
|
||||
|
||||
Polymarket is a prediction market platform, headquartered in [[New York City|New York]], on which users buy and sell shares in the outcomes of future events, with trades funded in the dollar stablecoin [[USD Coin]]. The company was founded in 2020 by [[Shayne Coplan]] and operates through several legal entities: the Delaware corporation [[Blockratize]], Inc., the Panamanian company Adventure One QSS Inc., which operates the international exchange, and, since 2025, a U.S.-licensed exchange and clearing house.[^1][^2]
|
||||
|
||||
### Founding and the Early Product
|
||||
|
||||
Coplan's earlier company was Union, a staking marketplace at union.market, which the [[Internet Archive]] first captured on July 17, 2019. A capture of November 9, 2020 carries the description "Visit Union to Join The Staking Economy and Start Earning Today."[^3] [[The Block]] published an essay on staking on March 2, 2020 that it credited to "Union founder Shayne Coplan."[^4] [[Cointelegraph]] reported that Union had secured venture capital funding, and quoted a post in which Coplan wrote that at the onset of the pandemic he was 21, running out of money and 2.5 years out of [[New York University]], with nothing to show for it.[^5] Coplan has also posted that in 2020 he was a "solo founder" with his headquarters in a "makeshift bathroom office."[^6]
|
||||
|
||||
A post by the company dated September 2020 states that the Polymarket beta left stealth on June 16, 2020. It describes the first product as having a [[MetaMask]]-only login, high [[Ethereum]] transaction fees and limited liquidity, and announces a second stage with free trades, card deposits, email login and a free 100 USDC for early-access users.[^7] The earliest archived capture of polymarket.com in the Internet Archive is dated June 18, 2020 and contains only the site title.[^8] A capture from March 2021 shows a homepage of binary markets, led by a market titled "Will Donald Trump be President of the USA on March 31, 2021?" with trading volume of $6,024,110.[^9]
|
||||
|
||||
The product was a set of binary markets priced by an automated market maker and resolved by the company itself. The [[Commodity Futures Trading Commission]] order of 2022 describes contracts on cryptocurrency prices, COVID-19 case counts and elections, including "Will Trump win the 2020 presidential election?", and states that disputes over outcomes were resolved by a committee of Polymarket staff.[^1]
|
||||
|
||||
By 2025 the platform ran on [[Polygon]]. On December 22, 2025 a member of the team confirmed in the platform's Discord community that Polymarket planned to leave Polygon for an Ethereum layer-2 network of its own called POLY.[^10]
|
||||
|
||||
### Entities and Corporate Structure
|
||||
|
||||
The CFTC named Blockratize, Inc. as the respondent in 2022, describing it as a Delaware corporation headquartered in New York that owns and operates the website and does business as Polymarket.[^1] Securities filings made by the company carry the same entity name.[^11]
|
||||
|
||||
[[Sportico]] reviewed more than 100 pages of Panamanian corporate filings for Adventure One QSS Inc. The company's articles of incorporation are dated October 15, 2021, and name the law firm of Mario Ernesto García de Paredes as resident agent. At a special shareholder meeting on December 22, 2021, Adventure One designated Coplan as its president. At a special meeting on April 7, 2022, it replaced him with Harry Jones, who is listed on LinkedIn as Polymarket's director of global affairs, and Coplan remained a director. A notice at the foot of the Polymarket website states that "the international platform is not regulated by the CFTC and operates independently."[^2] France's gaming regulator names Adventure One QSS Inc. as the operator of the site.[^12]
|
||||
|
||||
[[NPR]] reported on May 5, 2026 that a law office listed in Panamanian government documents as the entity's address, on the 21st floor of the Oceania Business Plaza in [[Panama City]], showed no sign of Polymarket or Adventure One when a reporter visited, and that a worker there had never heard of either. At least fifteen other cryptocurrency companies use the same office as their headquarters, and court filings show the firm was listed as owed $13,889 in the bankruptcy of [[FTX]]. NPR also reported that Polymarket has no employees in Panama and has an office on New York's Upper East Side, and that the terms of service send legal disputes to closed arbitration in [[Panama]] and tell users not to use a virtual private network.[^13]
|
||||
|
||||
On July 21, 2025 Polymarket announced the purchase of QCEX, a derivatives exchange and clearing house based in [[Boca Raton]], [[Florida]], for $112 million, with Coplan saying that the acquisition would let Polymarket re-enter the United States "as a fully regulated and compliant platform."[^14] The businesses are QCX LLC, a Delaware limited liability company, and QC Clearing LLC. The CFTC's order designating QCX LLC as a designated contract market rests on an application record running from June 16, 2022 to June 17, 2025. The order describes an anonymous electronic central limit order book and states that QCX may not permit any futures commission merchant to intermediate its trades or carry customer accounts unless the order is amended; a later amendment, signed in late November 2025, permitted futures commission merchants to carry accounts.[^15][^16]
|
||||
|
||||
### Funding and Capitalization
|
||||
|
||||
Cryptorank data, as reported by [[Decrypt]], records a seed round of $4 million led by [[Polychain Capital]] in 2020, and the Seedtable company record is dated October 19, 2020.[^17] A Form D filed in June 2021 discloses a $2,999,999 offering by an entity named PTC Polymarket LLC, a Delaware pooled investment fund with 17 investors whose first sale was June 3, 2021. Its executive officer is listed as PTC Crypto Partners SPV LLC, and the filing does not name the company whose interests it sold.[^18]
|
||||
|
||||
On May 13, 2024 the company announced $70 million raised across two previously unannounced rounds. The $45 million Series B was led by [[Founders Fund]] together with the existing investors 1confirmation and [[ParaFi]], with participation from [[Vitalik Buterin]], [[Dragonfly]] and [[Kevin Hartz]]. The $25 million Series A was led by [[General Catalyst]], with participation from the [[Airbnb]] co-founder [[Joe Gebbia]], Polychain and others. The release states that a record $202 million of predictions had been made on the platform in 2024 to that date, and that trading was unavailable in the United States. Joey Krug, a partner at Founders Fund, said that the firm had "developed a habit of checking Polymarket at times of breaking news." The release also announced the hiring of [[Richard Jaycobs]] as Head of Market Expansion to explore U.S. regulated activities; Jaycobs had been president of [[Cantor Exchange]] and chief executive of The Clearing Corporation. [[J. Christopher Giancarlo]], described as a former CFTC chairman, is named as chairman of Polymarket's advisory board, and is quoted as saying he had "watched the growth and evolution of Polymarket's product, business and team" over three years.[^19]
|
||||
|
||||
[[Blockchain Capital]] published a post on October 9, 2025 stating that "a little over a year ago, months before the 2024 US presidential election," it led a $55 million financing round for Polymarket at a $350 million post-money valuation. The post thanks the team members who contributed, including Bart Stephens and Joshua Rivera. The firm's team pages list Stephens as founder and managing partner and Rivera as operating partner and general counsel (joined June 2018), and its portfolio page lists Polymarket as a growth-stage investment.[^20][^21] The Form D filed April 16, 2020 for Blockchain Capital V lists a "P. Bart Stephens" of San Francisco as a director of the fund's general partner.[^22]
|
||||
|
||||
The first Form D under the Blockratize name was filed on October 18, 2024 (first sale October 4, 2024), five months after the May 2024 announcement. It names Coplan as executive officer and director and Bart Stephens as a director, and describes equity and warrants sold under a Rule 506(b) exemption. An amendment filed February 25, 2025 to the same offering (SEC file number 021-527240) names Coplan and Joshua Rivera as directors. A second Form D filed August 1, 2025 (file number 021-553453; first sale July 18, 2025) names Coplan and Rivera. The filings do not state an affiliation for either director. The identity of the two men with Blockchain Capital's founder and general counsel rests on the matching names, the firm's lead of the 2024 round, and the firm's own post crediting both men with the Polymarket work.[^11][^23][^24]
|
||||
|
||||
The announced rounds, the Form D filings and the later disclosures read side by side:
|
||||
|
||||
| Date | Announced, reported or disclosed | Blockratize Form D |
|
||||
|---|---|---|
|
||||
| October 2020 | Seed of about $4 million, Polychain reported lead | none |
|
||||
| June 3, 2021 | none | PTC Polymarket LLC, a separate registrant: $2,999,999 offered, 17 investors |
|
||||
| May 13, 2024 | $25 million Series A (General Catalyst) and $45 million Series B (Founders Fund, 1confirmation, ParaFi) | none filed |
|
||||
| mid-2024, "months before" the November 2024 election | $55 million at $350 million post-money, led by Blockchain Capital (Blockchain Capital post, October 9, 2025) | none filed |
|
||||
| October 4 to 18, 2024 | none | first sale October 4; filed October 18; $86,187,000 offering, $82,203,608 sold, 28 investors; director Stephens |
|
||||
| February 25, 2025 | none | amendment: $91,203,500 offering, $90,948,943 sold, 41 investors; director Rivera |
|
||||
| June 24, 2025 | Bloomberg: more than $200 million led by Founders Fund at about $1 billion before the new money; [[CoinDesk]]: includes $50 million not previously announced | none |
|
||||
| July 18 to August 1, 2025 | none | first sale July 18; filed August 1; $257,535,911 offering, $135,373,939 sold, 23 investors; director Rivera |
|
||||
| August 26, 2025 | strategic investment by 1789 Capital, terms not disclosed | none |
|
||||
| October 7, 2025 | ICE: up to $2 billion at about $8 billion pre-investment; Polymarket: $9 billion post-money | none |
|
||||
| October 8, 2025 | Coplan discloses a $150 million round in 2025 led by Founders Fund at $1.2 billion, and the $55 million round of 2024 | none |
|
||||
| March 26 and April 2026 | ICE: $600 million Series E preferred stock; $40 million tender offer for common stock | none |
|
||||
| September 1, 2026 | $1 billion round at $21 billion led by 1789 Capital | none |
|
||||
|
||||
The Blockratize Form D filings total $226,322,882 sold across the October 2024 offering ($90,948,943 after amendment) and the August 2025 offering ($135,373,939). The most recent Form D in the company's file at the [[Securities and Exchange Commission]] is dated August 1, 2025.[^25]
|
||||
|
||||
The reporting of the 2025 round began on June 24, 2025, when [[Bloomberg News]] reported that Polymarket was finalizing an investment of more than $200 million led by Founders Fund at a valuation of about $1 billion not counting the new money.[^26] After the [[Intercontinental Exchange]] announcement, The Block reported on October 8, 2025 that Coplan had disclosed two earlier unannounced rounds: $55 million in 2024 led by Blockchain Capital at a $350 million valuation, and $150 million in 2025 led by Founders Fund at a $1.2 billion valuation. The later round, he said, included Ribbit, Valor, [[Point72]] Ventures, SV Angel, 1789, 1confirmation, [[Coinbase]] and Dragonfly. The Block put the company's total prior funding, with the $4 million seed and the $70 million of May 2024, at about $279 million.[^27]
|
||||
|
||||
On October 7, 2025, ICE, the owner of the [[New York Stock Exchange]], announced that it would invest up to $2 billion in Polymarket at a valuation of approximately $8 billion before the investment, and would become the global distributor of Polymarket's event-driven data to institutional clients, with cooperation on tokenization.[^28] Polymarket's own announcement described a $9 billion post-money valuation.[^29] ICE's annual report for 2025 states that it paid $1.0 billion for Polymarket in 2025 and has the potential to purchase up to a further $1.0 billion of shares from Polymarket employees and investors. Its quarterly reports state that the October 7 agreement was to buy 9.6 million shares of Series D preferred stock of Blockratize, Inc. for $1.0 billion, about 17 percent of the outstanding shares and 11 percent fully diluted at the time. On March 26, 2026 ICE invested a further $600 million for about 4.2 million shares of Series E preferred stock, and in April 2026 it bought about 0.4 million common shares in a tender offer for $40 million. At March 31, 2026 the Series D and E holdings had a carrying value of about $2.0 billion, about 23 percent of the outstanding and 14 percent of the fully diluted shares, after a $389 million fair value gain recorded in the quarter.[^30]
|
||||
|
||||
On August 26, 2025 [[1789 Capital]], a venture firm in which [[Donald Trump Jr.]] is a partner, was reported to have made a strategic investment in Polymarket, with Trump Jr. joining the company's advisory board; the terms were not disclosed.[^31] On September 1, 2026 coverage reported that 1789 Capital had led a $1 billion round valuing Polymarket at $21 billion, up from $15 billion earlier in the year, with 1789 contributing $300 million on top of $200 million it had previously invested. [[The Wall Street Journal]] was cited for the $300 million.[^32][^33]
|
||||
|
||||
### The 2022 CFTC Order
|
||||
|
||||
On January 3, 2022, the CFTC entered an order filing and settling charges against Blockratize, Inc. d/b/a Polymarket for offering off-exchange event-based binary options contracts without designation as a designated contract market or registration as a swap execution facility. The order found that the platform had operated as an unregistered facility from June 2020, had offered more than 900 event markets, and had run markets through smart contracts on a blockchain. Users were required to use an Ethereum-based wallet and fund it with USDC.[^1]
|
||||
|
||||
The order required a $1.4 million civil monetary penalty, which it reduced in recognition of Polymarket's cooperation with the Division of Enforcement. It also required the winding down of markets that did not comply with the law, and the company's commitment to cease offering access to trading in its markets, unless the offering complied with the Act, by January 14, 2022, with certification by January 24, 2022. The order states that the company had never been registered with the CFTC in any capacity, that it had recorded more than $130 million in trading volume since the beta phase, and that it had represented that it had taken no profits from those transactions. It also states that disputes over the outcome of markets were resolved solely by the company's "Markets Integrity Committee," which the order describes as staffed solely by Polymarket personnel.[^1]
|
||||
|
||||
The company's own post of January 12, 2022 stated that trading on Polymarket.com would no longer be available to users from prohibited jurisdictions, including the United States, from that day, and that a site at Polymarket.us would let past users close out positions and withdraw funds. It said that about 1 million unique visitors had come to the site in its first year and a half, most of whom had never traded, and it recommended [[Kalshi]], [[PredictIt]] and Nadex to Americans who wished to continue trading.[^34]
|
||||
|
||||
On May 19, 2022 the company named Giancarlo, who had chaired the CFTC, as chairman of its advisory board. Coplan said in a thread announcing the appointment that Giancarlo's skillset was "exactly what's needed to pioneer compliant DeFi in the US." The Block reported that Giancarlo, in Bloomberg's coverage of the appointment, said the company had followed the legal process, moved everything offshore and done what was required.[^35]
|
||||
|
||||
### The 2024 Election and the FBI Search
|
||||
|
||||
Polymarket's markets on the 2024 U.S. presidential election drew large volume and one heavy trader, a French trader whose accounts included Fredi9999, PrincessCaro, Theo4 and Michie. [[Fortune]] reported about $40 million in profit from two markets in early November 2024, according to Polymarket Analytics.[^36]
|
||||
|
||||
On November 13, 2024, agents of the [[Federal Bureau of Investigation]] executed a search warrant at Coplan's Manhattan home and took his phone and other electronic devices. The [[New York Post]] first reported the search and said that agents arrived at 6 a.m. Coplan wrote on [[X]] that the search was a "last-ditch effort to go after companies they deem to be associated with political opponents."[^37] NPR later wrote that agents used a battering ram, as part of a probe into whether Polymarket was violating the 2022 settlement.[^13]
|
||||
|
||||
The federal probes examined whether the company had kept accepting bets from users in the United States despite its 2022 commitment. On July 15, 2025, [[CNBC]] reported, citing a source, that Polymarket had received declination notices earlier that month from the [[Department of Justice]] and the CFTC, one covering a criminal and one a civil inquiry, stating that the probes were completed and no further action would be taken; the Manhattan U.S. Attorney's Office had conducted the criminal investigation and declined to comment. Bloomberg News first reported the notices.[^38] Coplan posted on X that day that the FBI had "broke down my door at 6 a.m." eight days after election night, and that "Justice prevailed."[^39] [[Brian Quintenz]], whom [[Donald Trump]] had nominated to chair the CFTC, had joined the board of Kalshi, Polymarket's competitor, in November 2021; the White House withdrew his nomination in late September 2025.[^40][^41]
|
||||
|
||||
### Return to the United States
|
||||
|
||||
Staff of the CFTC's Division of Market Oversight and Division of Clearing and Risk issued Staff Letter 25-28 on September 2, 2025, granting QCX LLC, doing business as Polymarket US, and QC Clearing LLC, doing business as Polymarket Clearing, no-action relief from certain swap data reporting and recordkeeping rules for fully collateralized binary option contracts. One condition barred any participant from clearing a QCEX contract through a third-party clearing member. On November 14, 2025 Polymarket asked the staff to remove that condition, and a supplemental letter, 25-48, dated December 11, 2025, modified the relief.[^16]
|
||||
|
||||
On December 3, 2025 Polymarket announced on X that its U.S. iOS app had launched, rolling out through a waitlist, starting with sports markets.[^42] NPR reported in May 2026 that the website on which the company's international markets operate remained barred to U.S. users under the 2022 settlement, in "view-only mode," while the Trump administration had embraced the company: the Justice Department had dropped its investigation, Trump Jr. had become an adviser, and administration officials had invited Coplan to a White House cryptocurrency roundtable.[^13]
|
||||
|
||||
### Political Giving and Lobbying
|
||||
|
||||
[[Federal Election Commission]] records show contributions by Coplan, and by Polymarket executives, in the 2024 and 2026 cycles. On June 15, 2023 Coplan gave $5,000 to Never Back Down Inc., a super PAC that supported the presidential candidacy of [[Ron DeSantis]]. On September 19, 2024 Polymarket's chief marketing officer, Matthew Modabber, gave $50,000 to the Harris Victory Fund, a joint fundraising committee for [[Kamala Harris]], with allocations to the [[Democratic National Committee]] ($41,300), Harris for President ($3,300) and state parties. On October 21, 2024 Coplan gave $50,000 to the Harris Victory Fund, with the same allocations. On November 1, 2024 Coplan gave $23,300 through [[ActBlue]], earmarked for the Torres Victory Fund of Rep. [[Ritchie Torres]], which the filings show distributed to Torres for Congress ($3,300), the New York State Democratic Committee ($10,000), La Bamba PAC ($5,000) and Equality PAC ($5,000).[^43]
|
||||
|
||||
Coplan's contributions to the [[Republican National Committee]] on August 3, 2026, with his employer listed as Blockratize Inc. and his occupation as CEO, were $72,800 to the headquarters account, $132,900 to the legal proceedings account and $44,300 to the general account, $250,000 in all. The company's chief legal officer, Neal Kumar, gave $6,818.18 each to [[WinRed]] and Team Jordan in October 2025 and $10,000 to the Democratic Senatorial Campaign Committee on July 17, 2026.[^43]
|
||||
|
||||
Under the Lobbying Disclosure Act, [[Advocus Partners]], LLC registered on April 21, 2025 to lobby for Blockratize, Inc. on the issue "Financial Institutions/Investments/Securities," described as "strategic counsel and advocacy regarding development of digital asset policy and information markets." The registration lists [[David Urban]] (chief of staff to Sen. [[Arlen Specter]]; chairman of the American Battle Monuments Commission; USMA Board of Visitors) and Patrick Ames (senior policy adviser and counselor at the CFTC; law clerk to CFTC Commissioner Giancarlo). The firm reported $90,000 in income from the client in each of six quarterly reports, first quarter 2025 through second quarter 2026, $540,000 in all; the reports for 2026 add Andrew Lewin, a former House legislative assistant.[^44]
|
||||
|
||||
Trump Jr. is a partner at 1789 Capital and sits on Polymarket's advisory board.[^31] The [[Associated Press]] wrote in April 2026 that he is separately a paid strategic adviser to Kalshi.[^45]
|
||||
|
||||
On March 1, 2026, Rep. [[Mike Levin]] posted a demand for answers about an account that had profited from a bet on U.S. strikes on Iran, and noted that Trump Jr. sat on the advisory board and that his firm had put "double-digit millions" into the company the previous year.[^46] The Associated Press reported in April 2026 that at least 50 new accounts had bet on a U.S.-Iran ceasefire shortly before it was announced; Torres wrote to the CFTC asking it to review the trades, and Sen. [[Richard Blumenthal]] wrote to Polymarket that it had "become an illicit market to sell and exploit national security secrets unlike any in history, and by extension a potential honeypot for foreign intelligence services."[^45]
|
||||
|
||||
On June 6, 2025, X named Polymarket its official prediction market partner, with a first product that combined Polymarket odds with X data and annotations from [[Grok]].[^47]
|
||||
|
||||
### Market Resolution and the UMA Oracle
|
||||
|
||||
Polymarket settles disputed outcomes by a vote of holders of the [[UMA]] token in an optimistic oracle. On March 25, 2025 a $7 million market asking whether Trump would secure a rare earth minerals agreement with Ukraine by the end of March was resolved in favor of the claim although no deal had been confirmed. [[CryptoSlate]] reported that Wu Blockchain had said a single holder allegedly used three wallets to cast 5 million UMA tokens, about 25 percent of the votes. Polymarket called the event "unprecedented" and said that the market was resolved according to protocol and that users would not be reimbursed.[^48]
|
||||
|
||||
### Insider Trading and Suspicious Wagers
|
||||
|
||||
On June 21, 2025, the United States struck the Fordow nuclear site in Iran. The Anti-Corruption Data Collective and Der Standard reported on June 11, 2026 that an account named "Skoobidoobnj" began betting on a U.S. strike about ten hours before it, staked nearly $9,000 at odds of about one to ten, and won more than $100,000. A second account, "0xoracle," placed bets on the strike and on the destruction of Fordow. The researchers wrote that more than half of military-related longshot bets of at least $2,500 succeeded, and that nine interconnected accounts identified by Bubblemaps made more than $2.4 million, almost entirely from bets on U.S. military operations.[^49]
|
||||
|
||||
On October 10, 2025 the Norwegian Nobel Committee's announcement of the Peace Prize to [[Maria Corina Machado]] followed a rise in her Polymarket odds from roughly 3.6 percent to more than 70 percent about ten hours earlier, driven by a few accounts. Bloomberg identified one trader, "dirtycup," who had opened the account that month, and three accounts earned about $90,000 together. The director of the [[Norwegian Nobel Institute]], Kristian Berg Harpviken, said the spike "seems we have been prey to a criminal actor who wants to earn money on our information," and the institute said it would review whether confidential information had been accessed or shared unlawfully.[^50]
|
||||
|
||||
In the predawn hours of January 3, 2026, the United States apprehended [[Nicolás Maduro]]. A Polymarket account created less than a week earlier had bought roughly $32,000 of shares in a market on whether Maduro would be out by January 31, and Fortune reported a net of $436,759.61 for the account.[^51] Torres announced on January 5 that he would introduce the Public Integrity in Financial Prediction Markets Act of 2026.[^52] On April 23, 2026 the Justice Department unsealed an indictment of Gannon Ken Van Dyke, a U.S. Army soldier stationed at Fort Bragg who the indictment alleges participated in planning Operation Absolute Resolve. The indictment alleges that he created a Polymarket account on or about December 26, 2025, made about 13 "YES" bets totaling about $33,034 on Venezuela and Maduro markets, and profited about $409,881; that he withdrew most of the proceeds on January 3; and that on January 6 he asked Polymarket to delete the account, claiming he had lost access to its email address. The charges are three counts under the Commodity Exchange Act, wire fraud and an unlawful monetary transaction. NPR reported that Van Dyke pleaded not guilty.[^13][^53] The House Oversight letter of May 22, 2026 describes him as an Army master sergeant and dates the indictment April 24, 2026.[^54]
|
||||
|
||||
On February 28, 2026, the United States struck Iran. [[Bubblemaps]], a blockchain analytics firm, flagged six wallets that had been funded within 24 hours of the strike, bought "yes" shares on the February 28 contract hours before the operation, and called the group "suspected insiders" with $1.2 million in profit; The Block's tally of the same wallets was $989,191.[^55] [[Quartz]] reported that an account named "Magamyman" bet $87,000 about 71 minutes before the attacks became public, when the market priced them at 17 percent, and that the position was worth more than $553,000; Levin's post gave the gain as $515,000.[^46][^56]
|
||||
|
||||
On May 27, 2026 the CFTC filed a civil complaint in the Southern District of New York, and federal prosecutors unsealed a criminal complaint in the same court, against Michele Spagnuolo, a Google employee. The CFTC complaint describes him as a resident of Switzerland and a software engineer at Google; the complaints allege that he traded as "AlphaRaccoon" on contracts tied to Google's 2025 Year in Search list, using confidential data, and collected about $1.2 million in profit after Google announced the results on or about December 4, 2025. The criminal complaint charges wire fraud, commodities fraud and money laundering. Google said he had been placed on leave. The allegations have not been tested in court.[^57]
|
||||
|
||||
On March 23, 2026, Polymarket published "Enhanced Market Integrity Rules." The rules bar trading on confidential information held in breach of a duty of trust or confidence, and bar people able to influence an outcome from trading markets on that outcome, with a member of Congress unable to buy contracts on a specific legislative proposal.[^58]
|
||||
|
||||
### House Oversight Letter and Wall Street Journal Reporting, 2026
|
||||
|
||||
On May 22, 2026 [[James Comer]], chairman of the [[House Committee on Oversight and Government Reform]], signed a four-page letter to Coplan as chief executive of Blockratize, Inc. doing business as Polymarket, with a copy to ranking member [[Robert Garcia]]. The letter states that the committee is examining the use of prediction-market platforms to conduct insider trading and the adequacy of company safeguards against offshore access that circumvents U.S. regulation. It cites the indictment of Van Dyke, a case it describes as alleging the use of classified information about [[Operation Absolute Resolve]] to place wagers worth more than $409,000, and a May 13, 2026 New York Times investigation reporting that more than 80 Polymarket users placed bets with suspicious characteristics, including trades hours before unannounced U.S. and Israeli military operations against Iran. The letter requests documents from January 1, 2024 to the present, due June 5, 2026, in eight categories: identity verification and know-your-customer procedures; detection, investigation and referral of suspicious trading; contracts tied to U.S. or Israeli operations in Iran and to Operation Absolute Resolve; collection and use of personal data; compliance with CFTC regulations and the 2022 settlement; deliberations on contracts tied to armed conflict; current or former officers, directors, employees and advisers who hold or have applied for a U.S. security clearance; and the financial impact of anomalous trading on market integrity.[^54]
|
||||
|
||||
In September 2026 The Wall Street Journal published an investigation by Katherine Long, Caitlin Ostroff and Neil Mehta, which CCN, Quartz and iGaming Express reported on September 21. According to those reports, current and former employees told the Journal that compliance staff escalated to Coplan a stolen-debit-card fraud attempt on Polymarket's U.S. platform, worth at least $10 million, that peaked in February, with the payment processor Checkout.com rejecting more than 80 percent of the deposits it handled at the peak against an industry norm of about 1 percent, and that Coplan replied: "Just keep growing and pay a fine if regulators ever find out." Polymarket has not confirmed the comment, and a spokesperson said the company's "market integrity framework includes processes to detect, review and respond to suspicious activity." The same reports state that the Journal also reported that the CFTC is investigating Polymarket and that staff were told to preserve records; that Polymarket's U.S. chief compliance officer, Andrew Clifford, resigned in April after sending executives a report on the fraud; that the U.S. division's chief executive, Justin Hertzberg, was later fired; that a review by the law firm Sullivan & Cromwell concluded the company had complied with applicable regulations; and that Polymarket was raising $1 billion at a valuation of about $21 billion, with 1789 Capital investing roughly $300 million.[^59]
|
||||
|
||||
### Foreign Restrictions
|
||||
|
||||
In [[France]] the national gaming regulator, the [[Autorité nationale des jeux]] (ANJ), followed the company from November 2024, when betting was already barred, and on July 16, 2026 ordered internet providers to block the site. The regulator found that the geoblocking introduced after its notice was largely circumvented, noted the absence of identity verification, and treated the live odds on the home page as illegal advertising liable to a fine of 100,000 euros. The Paris prosecutor's office opened a criminal investigation on May 4, 2026, and the report mentions suspicion that weather markets were rigged by tampering with weather sensors.[^12]
|
||||
|
||||
In [[Belgium]] the [[Kansspelcommissie]] placed the site on its blacklist of illegal gambling sites effective January 30, 2025, after three warnings went unanswered and a request to the public prosecutor to block IP access.[^60]
|
||||
|
||||
In [[Singapore]] the [[Gambling Regulatory Authority]] showed users a notice from January 12, 2025 declaring Polymarket an illegal gambling site operated by an unlicensed provider, citing Section 20 of the Gambling Control Act 2022, which carries fines of up to $10,000 or six months in prison.[^61]
|
||||
|
||||
### Data, Media and Sports Partnerships
|
||||
|
||||
On January 7, 2026, [[Dow Jones]], publisher of The Wall Street Journal, announced an exclusive partnership under which Polymarket's data appears across the Journal, [[Barron's]], [[MarketWatch]] and [[Investor's Business Daily]], with a custom earnings calendar built on market-implied expectations.[^62]
|
||||
|
||||
Polymarket and [[Substack]] announced in 2026 a partnership that lets writers embed Polymarket data in newsletters and Notes; it builds on a partnership first announced in 2024, and the company joined Substack's sponsorship pilot program.[^63]
|
||||
|
||||
On November 12, 2025, [[TKO Group]], the parent company of the [[Ultimate Fighting Championship]] and [[Zuffa Boxing]], announced a multi-year agreement naming Polymarket the Official and Exclusive Prediction Market Partner of UFC and Zuffa Boxing, with a real-time Fan Prediction Scoreboard in UFC broadcasts. Coverage reported that Polymarket had signed a similar agreement with the [[National Hockey League]] in October 2025.[^64]
|
||||
|
||||
### Footnotes
|
||||
|
||||
[^1]: Commodity Futures Trading Commission, *In the Matter of Blockratize, Inc. d/b/a Polymarket.com*, CFTC Docket No. 22-09, order filing and simultaneously settling charges, January 3, 2022. https://www.cftc.gov/media/6891/enfblockratizeorder010322/download. The press release of the same date is Release Number 8478-22, https://www.cftc.gov/PressRoom/PressReleases/8478-22.
|
||||
[^2]: Dan Bernstein, "What Is Polymarket Doing in Panama?," Sportico, February 19, 2026. https://www.sportico.com/business/sports-betting/2026/polymarket-panama-adventure-one-prediction-market-1234885035/.
|
||||
[^3]: Internet Archive, captures of https://union.market/ dated July 17, 2019 (https://web.archive.org/web/20190717093112/https://union.market/) and November 9, 2020 (https://web.archive.org/web/20201109032613/https://union.market/).
|
||||
[^4]: Shayne Coplan, "Staking Beyond Consensus: decentralized digital labor markets," The Block, March 2, 2020. https://www.theblock.co/post/56263/staking-beyond-consensus-decentralized-digital-labor-markets.
|
||||
[^5]: Cointelegraph, "From Rags to riches: Polymarket founder Shayne Coplan Defies the odds," quoting a post by Coplan, October 2025. https://cointelegraph.com/news/polymarket-founder-coplan-billionaires-nyse-investment.
|
||||
[^6]: Decrypt, "Decrypt's 2024 Person of the Year: Polymarket CEO Shayne Coplan," December 2024, quoting a post by Coplan. https://decrypt.co/295680/2024-person-of-the-year-polymarket-ceo-shayne-coplan.
|
||||
[^7]: Polymarket, "A new Polymarket is coming.. Stage 2 of the Polymarket Beta is...," Medium, September 2020 (capture of October 29, 2020). https://web.archive.org/web/20201029073909/https://medium.com/polymarket/a-new-polymarket-is-coming-d98478ec86a.
|
||||
[^8]: Internet Archive, capture of http://www.polymarket.com/ dated June 18, 2020. https://web.archive.org/web/20200618071823/http://www.polymarket.com:80/.
|
||||
[^9]: Internet Archive, capture of https://polymarket.com/ dated March 1, 2021. https://web.archive.org/web/20210301000000/https://polymarket.com/.
|
||||
[^10]: Odaily, "The economic implications of Polymarket's exodus from Polygon," December 2025. https://www.odaily.news/en/post/5208320.
|
||||
[^11]: U.S. Securities and Exchange Commission, EDGAR, Form D filed October 18, 2024 by Blockratize Inc. (CIK 0002041378). https://www.sec.gov/Archives/edgar/data/2041378/000204137824000001/primary_doc.xml.
|
||||
[^12]: Gambling Insider (French edition), "L'ANJ ordonne le blocage de Polymarket en France," updated July 20, 2026. https://www.gamblinginsider.com/fr/?p=106304. The regulator's findings are as reported there.
|
||||
[^13]: Bobby Allyn and Eliana Morales Gil, "NPR went looking for Polymarket's Panama headquarters. It's elusive," NPR, May 5, 2026. https://www.npr.org/2026/05/05/nx-s1-5807918/polymarket-panama-prediction-market.
|
||||
[^14]: Cointelegraph, "Polymarket Set to Reenter US After $112M Acquisition of QCEX," July 21, 2025. https://cointelegraph.com/news/polymarket-reenter-us-acquisition-qcex-exchange.
|
||||
[^15]: Commodity Futures Trading Commission, Order of Designation, *In the Matter of the Application of QCX LLC for Designation as a Contract Market*, 2025. https://www.cftc.gov/filings/documents/2025/orgdcmqcexorderofd250709.pdf.
|
||||
[^16]: CFTC Letter No. 25-48, Supplemental Staff Letter regarding No-Action Position for QCEX Contracts, December 11, 2025, which describes CFTC Letter No. 25-28 (September 2, 2025) and the November 14, 2025 request. https://www.cftc.gov/csl/25-48/download; https://www.cftc.gov/csl/25-28/download.
|
||||
[^17]: Decrypt, "Decrypt's 2024 Person of the Year: Polymarket CEO Shayne Coplan," citing Cryptorank data on a 2020 seed round led by Polychain Capital, https://decrypt.co/295680/2024-person-of-the-year-polymarket-ceo-shayne-coplan; Seedtable company record, dated October 19, 2020, https://seedtable.com/companies/polymarket. Polychain is named among the participants in the Series A in the Business Wire release of May 13, 2024.
|
||||
[^18]: U.S. Securities and Exchange Commission, EDGAR, Form D filed June 9, 2021 by PTC Polymarket LLC (CIK 0001862792). https://www.sec.gov/Archives/edgar/data/1862792/000186112821000004/primary_doc.xml.
|
||||
[^19]: Business Wire, "Polymarket Raises $70m From Thiel's Founders Fund, General Catalyst, Vitalik Buterin to Scale Global Prediction Market," May 13, 2024. https://www.businesswire.com/news/home/20240513090515/en/Polymarket-Raises-%2470m-From-Thiels-Founders-Fund-General-Catalyst-Vitalik-Buterin-to-Scale-Global-Prediction-Market.
|
||||
[^20]: Blockchain Capital, "Put Your Money Where Your Mouth Is: Polymarket and the Future of News," October 9, 2025. https://blockchaincapital.com/blog/put-your-money-where-your-mouth-is-polymarket-and-the-future-of-news.
|
||||
[^21]: Blockchain Capital, team pages for Bart Stephens and Joshua Rivera, and portfolio page. https://blockchaincapital.com/team/bart-stephens; https://blockchaincapital.com/team/joshua-rivera; https://blockchaincapital.com/portfolio.
|
||||
[^22]: U.S. Securities and Exchange Commission, EDGAR, Form D filed April 16, 2020 for Blockchain Capital V QP, LP. https://www.sec.gov/Archives/edgar/data/1808666/000180866620000001/primary_doc.xml.
|
||||
[^23]: U.S. Securities and Exchange Commission, EDGAR, Form D/A filed February 25, 2025 by Blockratize Inc., amending accession no. 0002041378-24-000001. https://www.sec.gov/Archives/edgar/data/2041378/000204137825000001/primary_doc.xml.
|
||||
[^24]: U.S. Securities and Exchange Commission, EDGAR, Form D filed August 1, 2025 by Blockratize Inc. https://www.sec.gov/Archives/edgar/data/2041378/000204137825000003/primary_doc.xml.
|
||||
[^25]: U.S. Securities and Exchange Commission, EDGAR company filing list for Blockratize Inc. (CIK 0002041378), accessed October 2026. https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0002041378.
|
||||
[^26]: Bloomberg, "Polymarket Is Set to Raise Funding at $1 Billion Valuation," June 24, 2025. https://www.bloomberg.com/news/articles/2025-06-24/polymarket-is-set-to-raise-funding-at-1-billion-valuation; CoinDesk, "Polymarket on the Verge of Raising $200M at $1B Valuation: Report," June 24, 2025. https://www.coindesk.com/business/2025/06/24/polymarket-on-the-verge-of-raising-usd200m-at-usd1b-valuation-report.
|
||||
[^27]: Naga Avan-Nomayo, "Polymarket discloses past funding rounds totaling $205 million before $2 billion ICE investment," The Block, October 8, 2025. https://www.theblock.co/post/373783/polymarket-discloses-past-funding-rounds-totaling-205-million-before-2-billion-ice-investment.
|
||||
[^28]: Intercontinental Exchange, "ICE Announces Strategic Investment in Polymarket," press release (Exhibit 99.1 to Form 8-K), October 7, 2025. https://www.sec.gov/Archives/edgar/data/1571949/000094787125000890/ss5432176_ex9901.htm.
|
||||
[^29]: Decrypt, "Morning Minute: Polymarket Raises $2B at $9B Valuation from NYSE Parent," October 2025, quoting Polymarket's post on X. https://decrypt.co/343372/morning-minute-polymarket-raises-2b-at-9b-valuation-from-nyse-parent?amp=1.
|
||||
[^30]: Intercontinental Exchange, Form 10-K for 2025 (filed February 5, 2026), Form 10-Q for the quarter ended March 31, 2026 (filed April 30, 2026) and Form 10-Q for the quarter ended June 30, 2026 (filed July 30, 2026), notes on the Polymarket investment. https://www.sec.gov/Archives/edgar/data/1571949/000157194926000004/ice-20251231.htm; https://www.sec.gov/Archives/edgar/data/1571949/000157194926000007/ice-20260331.htm; https://www.sec.gov/Archives/edgar/data/1571949/000157194926000011/ice-20260630.htm.
|
||||
[^31]: Ilya Banares, "Polymarket Gets 1789 Investment, Adds Trump Jr. as Adviser," Bloomberg Law, August 26, 2025. https://news.bloomberglaw.com/esg/polymarket-gets-1789-investment-adds-trump-jr-as-adviser.
|
||||
[^32]: "Polymarket Raises $1 Billion In Latest Funding Round," Yahoo Finance (Cryptoprowl), September 1, 2026. https://finance.yahoo.com/markets/crypto/articles/polymarket-raises-1-billion-latest-135800904.html.
|
||||
[^33]: Covers, "Trump Jr.'s Firm Invests $300 Million into Polymarket," citing The Wall Street Journal, September 1, 2026. https://www.covers.com/industry/trump-jrs-firm-invests-300-million-dollars-into-polymarket-sept-1-2026.
|
||||
[^34]: Polymarket, "Compliance Update, January 2022," January 12, 2022. https://blog.polymarket.com/compliance-update-january-2022/.
|
||||
[^35]: The Block, "Polymarket appoints former CFTC chief Giancarlo as chair of advisory board," May 19, 2022. https://www.theblock.co/news/business/2022-05-19-polymarket-appoints-former-cftc-chief-giancarlo-as-chair-of-advisory-board-147946.
|
||||
[^36]: Fortune, "The French whale on Polymarket just won $40 million betting on Trump," November 6, 2024. https://fortune.com/2024/11/06/polymarket-whale-won-40-million-betting-on-trump.
|
||||
[^37]: Al Jazeera, "FBI raids home of Polymarket CEO," November 14, 2024. https://www.aljazeera.com/economy/2024/11/14/fbi-raids-home-of-polymarket-ceo.
|
||||
[^38]: CNBC, "Trump administration ends Polymarket investigations without charges," July 15, 2025, reprinted by NBC San Diego. https://www.nbcsandiego.com/news/business/money-report/trump-administration-ends-polymarket-investigations-without-charges/3868886/.
|
||||
[^39]: crypto.news, "DOJ, CFTC close Polymarket case months after FBI raid, no charges filed," July 2025, quoting Coplan's post of July 15, 2025. https://crypto.news/doj-cftc-close-polymarket-case-months-after-fbi-raid-no-charges-filed/.
|
||||
[^40]: Kalshi News, "Former CFTC Commissioner Brian Quintenz Joins Our Board," November 16, 2021. https://news.kalshi.com/p/former-cftc-commissioner-brian-quintenz-joins-our-board.
|
||||
[^41]: Cointelegraph, "Crypto industry groups weigh in on CFTC's future after key withdrawal," October 1, 2025. https://cointelegraph.com/news/crypto-organizations-cftc-chair-brian-quintenz-withdrawal.
|
||||
[^42]: CoinDesk, "Polymarket Launches App With CFTC Green Light in U.S. Return," December 3, 2025. https://www.coindesk.com/markets/2025/12/03/polymarket-launches-app-with-cftc-green-light-in-u-s-return.
|
||||
[^43]: Federal Election Commission, Schedule A receipts (OpenFEC API) for contributor Shayne Coplan, employer Polymarket and employer Blockratize, retrieved October 13, 2026. Filings: Never Back Down Inc. (C00834077), https://docquery.fec.gov/cgi-bin/fecimg/?202307319588928213; Harris Victory Fund (C00744946), https://docquery.fec.gov/cgi-bin/fecimg/?202505089760714379; Torres Victory Fund (C00754598), https://docquery.fec.gov/cgi-bin/fecimg/?202412049720190238; Republican National Committee (C00003418), https://docquery.fec.gov/cgi-bin/fecimg/?202609209908290689 and https://docquery.fec.gov/cgi-bin/fecimg/?202609209908269154. Allocation lines of the joint fundraising committees are counted once. The FEC committee records list Andrew Madras as treasurer of the Torres Victory Fund (C00754598), of Torres for Congress (C00699744, candidate H0NY15160, Ritchie John Torres) and of La Bamba PAC (C00753947, sponsor candidate Ritchie John Torres). https://api.open.fec.gov/v1/committee/C00754598/
|
||||
[^44]: U.S. Senate, Lobbying Disclosure Act database, registration and quarterly reports filed April 21, 2025 through July 20, 2026 by Advocus Partners, LLC for client Blockratize, Inc. https://lda.gov/filings/public/filing/84df9d2d-3053-4484-820f-16bddafb8ba9/print/; https://lda.gov/filings/public/filing/0002a0aa-0c8a-4020-b2b8-3481b1765bd0/print/.
|
||||
[^45]: Associated Press, "Well-timed bets on Polymarket tied to the Iran war draw calls for investigations from lawmakers," April 2026, syndicated by WTOP. https://wtop.com/national/2026/04/well-timed-bets-on-polymarket-tied-to-the-iran-war-draw-calls-for-investigations-from-lawmakers/.
|
||||
[^46]: Yahoo Finance, "Polymarket Under Fire After Lawmaker Demands Answers Over $500K Iran Strike Bet," March 2026, reporting Rep. Mike Levin's post of March 1, 2026. https://finance.yahoo.com/news/polymarket-under-fire-lawmaker-demands-033019283.html.
|
||||
[^47]: Covers, "Polymarket, X Announce Prediction Market Partnership," June 6, 2025. https://www.covers.com/industry/polymarket-and-x-announce-partnership-june-6-2025.
|
||||
[^48]: CryptoSlate, "Polymarket faces backlash over resolving disputed $7 million Trump-Ukraine market," March 2025. https://cryptoslate.com/polymarket-faces-backlash-over-resolving-disputed-7-million-trump-ukraine-market/.
|
||||
[^49]: Anton Reckmann, "Profiting from War: Mysterious Bets on Polymarket," Anti-Corruption Data Collective with Der Standard and Paper Trail Media, June 11, 2026. https://acdatacollective.org/work/profiting-from-war-mysterious-bets-on-polymarket/. The patterns are the researchers' analysis.
|
||||
[^50]: Yahoo Finance (Bloomberg), "Probe into Polymarket Nobel Peace Prize Bets," October 2025, https://finance.yahoo.com/news/probe-polymarket-nobel-peace-prize-205100943.html; Blockworks, "Officials suspect potential insider trading after wagers on Nobel Peace Prize winner surged hours before announcement," October 2025, https://blockworks.com/news/polymarket-nobel-probe; The Block, "Officials probe Polymarket over suspicious trades predicting Nobel Peace Prize winner," October 2025, https://www.theblock.co/post/374199/officials-probe-polymarket-over-suspicious-trades-predicting-nobel-peace-prize-winner-reports.
|
||||
[^51]: Fortune, "Polymarket account made $400k from bets on Maduro's capture placed hours before U.S. military strike," January 5, 2026, https://dc.fortune.com/2026/01/05/polymarket-user-400k-maduro-capture-bets-insider-trading-suspicion; NPR, "After Maduro was captured, someone made $400,000 on Polymarket," January 5, 2026, https://npr.org/2026/01/05/nx-s1-5667232/polymarket-maduro-bet-insider-trading.
|
||||
[^52]: The Block, "Rep. Torres targets prediction market 'insider trading' after trader nets $400K on Maduro's capture," January 2026. https://www.theblock.co/post/384200/rep-torres-targets-prediction-market-insider-trading-after-trader-nets-400k-on-maduros-capture-report.
|
||||
[^53]: U.S. Department of Justice, Office of Public Affairs, "U.S. Soldier Charged With Using Classified Information To Profit From Prediction Market Bets," April 23, 2026. https://www.justice.gov/opa/pr/us-soldier-charged-using-classified-information-profit-prediction-market-bets. The allegations are those of the indictment.
|
||||
[^54]: U.S. House Committee on Oversight and Government Reform, letter from Chairman James Comer to Shayne Coplan, Blockratize, Inc. d/b/a Polymarket, May 22, 2026. https://oversight.house.gov/wp-content/uploads/2026/05/Polymarket-Prediction-Markets-Letter.pdf
|
||||
[^55]: The Block, "Fresh accounts netted $1 million on Polymarket hours before US airstrikes on Iran: Bubblemaps," March 2026. https://www.theblock.co/post/391650/fresh-accounts-netted-1-million-on-polymarket-hours-before-us-airstrikes-on-iran-bubblemaps. The labels and the combined figure are Bubblemaps's own.
|
||||
[^56]: Quartz, "A Polymarket bet placed shortly before news of U.S. strikes on Iran turned $87,000 into $553,000," March 2026. https://qz.com/polymarket-iran-strike-insider-bet-prediction-markets.
|
||||
[^57]: Commodity Futures Trading Commission, Release 9237-26, "CFTC Charges Google Employee with Insider Trading in Search Result-Related Event Contracts," May 27, 2026, as reproduced by Mondo Visione, https://mondovisione.com/media-and-resources/news/cftc-charges-google-employee-with-insider-trading-in-search-result-related-event-2026528/; CNBC, "Google employee charged with $1M Polymarket insider trading bet on search term," May 27, 2026, https://www.cnbc.com/2026/05/27/google-employee-polymarket-insider-trading.html. Allegations only.
|
||||
[^58]: Covers, "Polymarket Reveals its Crackdown on Insider Trading," March 23, 2026. https://www.covers.com/industry/polymarkets-plan-to-tackle-insider-trading-march-23-2026.
|
||||
[^59]: Kurt Robson, "Keep Growing and Pay a Fine: Polymarket CEO Allegedly Ignored Warnings as Fraud Attempts Hit $10M," CCN via Yahoo Finance, September 21, 2026, reporting the Wall Street Journal investigation, https://finance.yahoo.com/markets/crypto/articles/keep-growing-pay-fine-polymarket-104716697.html ; Cris Tolomia, "Polymarket's CEO told staff to keep growing as a $10M fraud scheme hit its U.S. platform," Quartz, updated September 21, 2026, https://qz.com/polymarket-ceo-fraud-cftc-investigation-growth-092126 ; Mateusz Mazur, "Polymarket Waved Off Stolen-Card Fraud Warnings, WSJ Reports," iGaming Express, September 21, 2026, naming the Journal's authors, https://igamingexpress.com/polymarket-stolen-card-fraud-coplan-wsj/
|
||||
[^60]: CDC Gaming, "Belgium blocks Polymarket as blacklisted website." https://cdcgaming.com/brief/belgium-blocks-polymarket-as-blacklisted-website/; SBC News, "Polymarket belgium ban," February 3, 2025. https://sbcnews.co.uk/sportsbook/2025/02/03/polymarket-belgium-ban/.
|
||||
[^61]: Decrypt, "Singapore Blocks Access to Polymarket Over Gambling Law," January 2025. https://decrypt.co/300583/singapore-blocks-access-to-polymarket-over-gambling-law.
|
||||
[^62]: Business Wire, "Polymarket and Dow Jones, Publisher of The Wall Street Journal, Announce Exclusive Prediction Market Partnership," January 7, 2026. https://www.businesswire.com/news/home/20260107511213/en.
|
||||
[^63]: Nieman Lab, "Polymarket says journalism is better when it's backed by live markets," February 2026. https://www.niemanlab.org/2026/02/polymarket-says-journalism-is-better-when-its-backed-by-live-markets-does-anyone-know-what-that-means/.
|
||||
[^64]: Business Wire, "TKO and Polymarket Announce First-of-Its-Kind Sports Partnership," November 12, 2025, https://www.businesswire.com/news/home/20251112645203/en/TKO-and-Polymarket-Announce-First-of-Its-Kind-Sports-Partnership; Yogonet, November 14, 2025, https://www.yogonet.com/international/news/2025/11/14/116324-polymarket-signs-multiyear-deal-as-ufcs-exclusive-prediction-market-partner.
|
||||
|
|
@ -67,7 +67,7 @@ relations:
|
|||
with: "[[Don Vieira]]"
|
||||
reverse: true
|
||||
role: "partner, chief legal officer and chief policy officer"
|
||||
fn: 24
|
||||
fn: 30
|
||||
- type: employed_by
|
||||
with: "[[Shaun Maguire]]"
|
||||
reverse: true
|
||||
|
|
@ -102,33 +102,48 @@ relations:
|
|||
with: "[[Twitter]]"
|
||||
start: 2022-05
|
||||
role: "$800 million equity commitment by Sequoia Capital Fund, L.P. to Elon Musk's acquisition"
|
||||
fn: 14
|
||||
fn: 20
|
||||
- type: funded
|
||||
with: "[[FTX]]"
|
||||
start: 2021-07
|
||||
end: 2022-11-09
|
||||
role: "Series B investor through Global Growth Fund III and SCGE Fund; marked to zero"
|
||||
fn: 16
|
||||
fn: 22
|
||||
- type: funded
|
||||
with: "[[ByteDance]]"
|
||||
start: 2014-03
|
||||
role: "Sequoia Capital and Sequoia Capital China investments of about $1.4 billion"
|
||||
fn: 23
|
||||
fn: 29
|
||||
- type: funded
|
||||
with: "[[23andMe]]"
|
||||
role: "17,818,438 Class B shares held by Sequoia Capital Operations, LLC in 2021"
|
||||
fn: 25
|
||||
fn: 31
|
||||
- type: subject_of
|
||||
with: "[[House Select Committee on the CCP]]"
|
||||
start: 2023-10-17
|
||||
role: "letter to Roelof Botha and Don Vieira; report of February 8, 2024"
|
||||
fn: 22
|
||||
fn: 28
|
||||
- type: subject_of
|
||||
with: "[[In re FTX Cryptocurrency Exchange Collapse Litigation]]"
|
||||
role: "defendant, as Sequoia Capital Operations, LLC, one of the Domestic Investor Defendants"
|
||||
fn: 19
|
||||
fn: 25
|
||||
- type: funded
|
||||
with: "[[Kalshi]]"
|
||||
start: 2021-02-17
|
||||
role: "led the 30 million dollar Series A"
|
||||
fn: 14
|
||||
- type: funded
|
||||
with: "[[Kalshi]]"
|
||||
start: 2025-06-25
|
||||
role: "participant in the 185 million dollar Series C led by Paradigm"
|
||||
fn: 16
|
||||
- type: funded
|
||||
with: "[[Kalshi]]"
|
||||
start: 2025-10-10
|
||||
role: "co-led the 300 million dollar Series D with Andreessen Horowitz"
|
||||
fn: 17
|
||||
created: 2026-10-01
|
||||
updated: 2026-10-01
|
||||
updated: 2026-10-13
|
||||
---
|
||||
|
||||
### Founding
|
||||
|
|
@ -165,35 +180,41 @@ In 2025 Maguire called the New York mayoral candidate [[Zohran Mamdani]] an "Isl
|
|||
|
||||
Records for Leone with Sequoia Capital as employer include $125,000 to Right to Rise USA in January 2015; $100,000 to the John Bolton Super PAC in June 2017; $50,000 each to America First Action and Trump Victory in 2019; $100,000 to Security is Strength PAC and $100,900 to the Senate Georgia Battleground Fund in 2020; $893,500 to the [[Senate Leadership Fund]] in three gifts from November 2020 to February 2022; about $501,000 to the [[Congressional Leadership Fund]]; $820,900 to the McCarthy Victory Fund, in part with the employer given as "venture capitalist"; $213,500 to the [[Republican National Committee]] in two gifts on December 7, 2021; $2,000,000 to Never Back Down Inc. on April 19, 2023; $1,000,000 to America PAC on June 14, 2024; and $250,000 to the [[Trump 47 Committee]] on October 30, 2024. A $2,000,000 gift to Right for America on June 4, 2024 appears under his name with the employer given as self-employed. Botha's two gifts, of $5,000 each, went to the [[National Venture Capital Association]]'s VenturePAC.[^13]
|
||||
|
||||
### Kalshi
|
||||
|
||||
Sequoia Capital led the 30 million dollar Series A of [[Kalshi]], the CFTC-regulated event-contract exchange, in February 2021, with [[Charles Schwab]] and [[Henry Kravis]] participating.[^14] A Form D filed February 23, 2021 for a first sale on December 18, 2020 (29,999,999 dollars sold to 10 investors) lists [[Tarek Mansour]], [[Luana Lopes Lara]] and Alfred Lin as directors of Kalshi Inc. Lin remains a listed director in the Form D for the October 2025 round, which also lists [[Michael Seibel]] and [[Matt Huang]], and in the Form D for the April 2026 round.[^15]
|
||||
|
||||
Sequoia participated in the 185 million dollar Series C at a 2 billion dollar valuation, announced June 25, 2025 and led by [[Paradigm (investment firm)]], according to Mansour's announcement.[^16] Kalshi's announcement of October 10, 2025 describes its 300 million dollar Series D at a 5 billion dollar valuation as "co-led by Andreessen Horowitz (a16z) and Sequoia Capital, with significant participation from Paradigm."[^17] The Block reported on November 20, 2025, citing TechCrunch, that Sequoia and CapitalG led a 1 billion dollar round at an 11 billion dollar valuation; Kalshi's announcement of December 2, 2025 describes that Series E as led by Paradigm with participation from Sequoia.[^18] Sequoia is named among the participants in the 1 billion dollar Series F at a 22 billion dollar valuation, led by [[Coatue Management]], reported on May 7, 2026.[^19]
|
||||
|
||||
### Twitter
|
||||
|
||||
On May 5, 2022 Musk filed an amendment to his Schedule 13D for [[Twitter]] listing co-investors who had signed equity commitment letters for his acquisition. Sequoia Capital Fund, L.P. committed $800,000,000. The other commitments on the list included the Lawrence J. Ellison Revocable Trust ($1,000,000,000), [[VyCapital]] ($700,000,000), [[Binance]] ($500,000,000), AH Capital Management, L.L.C. of [[Andreessen Horowitz]] ($400,000,000), [[Qatar Holding LLC]] ($375,000,000), Fidelity ($316,139,386), Brookfield ($250,000,000) and [[Witkoff Capital]] ($100,000,000).[^14]
|
||||
On May 5, 2022 Musk filed an amendment to his Schedule 13D for [[Twitter]] listing co-investors who had signed equity commitment letters for his acquisition. Sequoia Capital Fund, L.P. committed $800,000,000. The other commitments on the list included the Lawrence J. Ellison Revocable Trust ($1,000,000,000), [[VyCapital]] ($700,000,000), [[Binance]] ($500,000,000), AH Capital Management, L.L.C. of [[Andreessen Horowitz]] ($400,000,000), [[Qatar Holding LLC]] ($375,000,000), Fidelity ($316,139,386), Brookfield ($250,000,000) and [[Witkoff Capital]] ($100,000,000).[^20]
|
||||
|
||||
### FTX
|
||||
|
||||
In a profile of [[Sam Bankman-Fried]] published on Sequoia's website on September 22, 2022, the writer [[Adam Fisher]] recounted that Lin and [[Michelle Bailhe]] had studied cryptocurrency exchanges during the pandemic and contacted Bankman-Fried during FTX's Series B round in the summer of 2021, and that after a video call in which he described a financial "super-app," partners typed "I LOVE THIS FOUNDER" and "I am a 10 out of 10" in the chat window. The profile quotes FTX's head of product, [[Ramnik Arora]], saying Bankman-Fried had been "playing League of Legends through the entire meeting."[^15] On October 1, 2026 the profile's address redirected to Sequoia's FTX company page.[^15]
|
||||
In a profile of [[Sam Bankman-Fried]] published on Sequoia's website on September 22, 2022, the writer [[Adam Fisher]] recounted that Lin and [[Michelle Bailhe]] had studied cryptocurrency exchanges during the pandemic and contacted Bankman-Fried during FTX's Series B round in the summer of 2021, and that after a video call in which he described a financial "super-app," partners typed "I LOVE THIS FOUNDER" and "I am a 10 out of 10" in the chat window. The profile quotes FTX's head of product, [[Ramnik Arora]], saying Bankman-Fried had been "playing League of Legends through the entire meeting."[^21] On October 1, 2026 the profile's address redirected to Sequoia's FTX company page.[^21]
|
||||
|
||||
Sequoia invested in [[FTX]]'s Series B in July 2021, at an $18 billion valuation; the Series C of January 2022 valued FTX at $32 billion.[^16] On November 9, 2022 Sequoia told the limited partners of Global Growth Fund III, and posted the letter publicly, that "a liquidity crunch has created solvency risk for FTX" and that it was marking the investment to zero. The letter gave a cost basis of $150 million in that fund, Sequoia Capital Global Growth Fund III, Endurance Partners, L.P., under 3 percent of its committed capital and offset by about $7.5 billion of gains in the fund, and $63.5 million invested by SCGE Fund, L.P. It stated that in 2021 FTX had generated about $1 billion of revenue and more than $250 million of operating income, "as was made public in August 2022," and that "We are in the business of taking risk."[^16][^17] SC GGF III, the same Endurance Partners fund, appears among the Maplebear reporting persons in 2024.[^8]
|
||||
Sequoia invested in [[FTX]]'s Series B in July 2021, at an $18 billion valuation; the Series C of January 2022 valued FTX at $32 billion.[^22] On November 9, 2022 Sequoia told the limited partners of Global Growth Fund III, and posted the letter publicly, that "a liquidity crunch has created solvency risk for FTX" and that it was marking the investment to zero. The letter gave a cost basis of $150 million in that fund, Sequoia Capital Global Growth Fund III, Endurance Partners, L.P., under 3 percent of its committed capital and offset by about $7.5 billion of gains in the fund, and $63.5 million invested by SCGE Fund, L.P. It stated that in 2021 FTX had generated about $1 billion of revenue and more than $250 million of operating income, "as was made public in August 2022," and that "We are in the business of taking risk."[^22][^23] SC GGF III, the same Endurance Partners fund, appears among the Maplebear reporting persons in 2024.[^8]
|
||||
|
||||
Sequoia Capital Operations, LLC was named a defendant in O'Keefe v. Sequoia Capital Operations, LLC, filed in the Southern District of Florida on February 22, 2023 against investors, auditors, banks and the law firm [[Fenwick & West]]; the case was closed on June 21, 2023 on transfer into the multidistrict litigation In re FTX Cryptocurrency Exchange Collapse Litigation before Judge [[K. Michael Moore]].[^18] In that litigation Sequoia appears among the "Domestic Investor Defendants" with Altimeter, Multicoin, Paradigm, Ribbit, [[SkyBridge Capital]], [[Thoma Bravo]] and [[Tiger Global Management]]. These defendants responded to a notice of supplemental authority in May 2025 and to the plaintiffs' motion to lift the discovery stay in June 2025, and on June 5, 2026 filed a reservation of rights on the plaintiffs' motion for preliminary approval of a second tranche of settlements.[^19]
|
||||
Sequoia Capital Operations, LLC was named a defendant in O'Keefe v. Sequoia Capital Operations, LLC, filed in the Southern District of Florida on February 22, 2023 against investors, auditors, banks and the law firm [[Fenwick & West]]; the case was closed on June 21, 2023 on transfer into the multidistrict litigation In re FTX Cryptocurrency Exchange Collapse Litigation before Judge [[K. Michael Moore]].[^24] In that litigation Sequoia appears among the "Domestic Investor Defendants" with Altimeter, Multicoin, Paradigm, Ribbit, [[SkyBridge Capital]], [[Thoma Bravo]] and [[Tiger Global Management]]. These defendants responded to a notice of supplemental authority in May 2025 and to the plaintiffs' motion to lift the discovery stay in June 2025, and on June 5, 2026 filed a reservation of rights on the plaintiffs' motion for preliminary approval of a second tranche of settlements.[^25]
|
||||
|
||||
### Sequoia Capital China and HongShan
|
||||
|
||||
On June 6, 2023 Botha, Shen and [[Shailendra Singh]] announced that Sequoia would separate into Sequoia Capital in the United States and Europe, [[Peak XV Partners]] in India and Southeast Asia, and [[HongShan]] in China by March 2024, writing that "It has become increasingly complex to run a decentralized global investment business."[^20] Peak XV's adviser registration lists it as formerly Sequoia Capital India Operations II LLC, based in Mauritius.[^21]
|
||||
On June 6, 2023 Botha, Shen and [[Shailendra Singh]] announced that Sequoia would separate into Sequoia Capital in the United States and Europe, [[Peak XV Partners]] in India and Southeast Asia, and [[HongShan]] in China by March 2024, writing that "It has become increasingly complex to run a decentralized global investment business."[^26] Peak XV's adviser registration lists it as formerly Sequoia Capital India Operations II LLC, based in Mauritius.[^27]
|
||||
|
||||
On October 17, 2023 [[Mike Gallagher]] and [[Raja Krishnamoorthi]], chairman and ranking member of the [[House Select Committee on the CCP]], wrote to Botha and to [[Don Vieira]], partner and global chief policy officer. The committee stated its understanding, from source material on file, that each of Sequoia's five entities had its own investment committee but that roughly 20 percent of the carry from each deal flowed to the top of the Sequoia family, a central compliance office in Menlo Park reviewed every deal, Sequoia Capital's chief financial officer and legal counsel retained authority over the foreign entities, and 60 to 70 percent of Sequoia Capital China's limited partners had been American, later about half. It described a screening process adopted in the summer of 2022 that covered only Chinese quantum, semiconductor and aerospace investments, named investments in EverSec, 4Paradigm, DJI and DeepGlint, and observed that the planned Treasury outbound investment rules would not reach HongShan once it was independent.[^22]
|
||||
On October 17, 2023 [[Mike Gallagher]] and [[Raja Krishnamoorthi]], chairman and ranking member of the [[House Select Committee on the CCP]], wrote to Botha and to [[Don Vieira]], partner and global chief policy officer. The committee stated its understanding, from source material on file, that each of Sequoia's five entities had its own investment committee but that roughly 20 percent of the carry from each deal flowed to the top of the Sequoia family, a central compliance office in Menlo Park reviewed every deal, Sequoia Capital's chief financial officer and legal counsel retained authority over the foreign entities, and 60 to 70 percent of Sequoia Capital China's limited partners had been American, later about half. It described a screening process adopted in the summer of 2022 that covered only Chinese quantum, semiconductor and aerospace investments, named investments in EverSec, 4Paradigm, DJI and DeepGlint, and observed that the planned Treasury outbound investment rules would not reach HongShan once it was independent.[^28]
|
||||
|
||||
The committee's report of February 8, 2024 states that Sequoia had partnered with local leaders in 2005 to form Sequoia Capital China; that Sequoia Capital and Sequoia Capital China had invested about $1.4 billion in [[ByteDance]] from March 2014, and Shen sat on its board; that Shen had been a "steward of Sequoia Capital" and a representative to the [[Chinese People's Political Consultative Conference]]; that Sequoia Capital China invested $36 million in [[DJI]] from August 2014 and exited in 2019 and 2021, and RMB 466 million ($76 million) plus about $5 million through a fund with American limited partners in 4Paradigm from March 2015; and that Sequoia Capital China invested about $32 million in BGI Tech, a subsidiary of [[BGI Group]], from 2013, exiting in November 2020, after an internal memo of September 2012 touted BGI's acquisition of the American sequencing company [[Complete Genomics]]. The [[Department of Commerce]] added BGI Tech to the Entity List in March 2023. Sequoia told the committee that its entry into China "coincided with expressed government policies and public positions in the US that encouraged businesses to invest in the region" and that Sequoia Capital China's renminbi funds had no American limited partners.[^23]
|
||||
The committee's report of February 8, 2024 states that Sequoia had partnered with local leaders in 2005 to form Sequoia Capital China; that Sequoia Capital and Sequoia Capital China had invested about $1.4 billion in [[ByteDance]] from March 2014, and Shen sat on its board; that Shen had been a "steward of Sequoia Capital" and a representative to the [[Chinese People's Political Consultative Conference]]; that Sequoia Capital China invested $36 million in [[DJI]] from August 2014 and exited in 2019 and 2021, and RMB 466 million ($76 million) plus about $5 million through a fund with American limited partners in 4Paradigm from March 2015; and that Sequoia Capital China invested about $32 million in BGI Tech, a subsidiary of [[BGI Group]], from 2013, exiting in November 2020, after an internal memo of September 2012 touted BGI's acquisition of the American sequencing company [[Complete Genomics]]. The [[Department of Commerce]] added BGI Tech to the Entity List in March 2023. Sequoia told the committee that its entry into China "coincided with expressed government policies and public positions in the US that encouraged businesses to invest in the region" and that Sequoia Capital China's renminbi funds had no American limited partners.[^29]
|
||||
|
||||
[[Skadden, Arps, Slate, Meagher & Flom]] describes Vieira as a former chief of staff of the [[National Security Division]] of the [[Department of Justice]] and counselor to the assistant attorney general for national security (2009 to 2011), an espionage prosecutor, deputy chief counsel of the [[House Permanent Select Committee on Intelligence]] and staff director of its oversight subcommittee, and a Skadden national security partner from 2017 to 2019. At Sequoia he founded the Washington office and global policy function, was chief legal officer, and represented the firm on the board of the National Venture Capital Association; he also sat on the boards of Genuity Science and [[Hakluyt & Company|Hakluyt & Co.]] He returned to Skadden on September 9, 2025.[^24]
|
||||
[[Skadden, Arps, Slate, Meagher & Flom]] describes Vieira as a former chief of staff of the [[National Security Division]] of the [[Department of Justice]] and counselor to the assistant attorney general for national security (2009 to 2011), an espionage prosecutor, deputy chief counsel of the [[House Permanent Select Committee on Intelligence]] and staff director of its oversight subcommittee, and a Skadden national security partner from 2017 to 2019. At Sequoia he founded the Washington office and global policy function, was chief legal officer, and represented the firm on the board of the National Venture Capital Association; he also sat on the boards of Genuity Science and [[Hakluyt & Company|Hakluyt & Co.]] He returned to Skadden on September 9, 2025.[^30]
|
||||
|
||||
### 23andMe
|
||||
|
||||
When [[23andMe]] became public through a merger in June 2021, Botha was a director and Sequoia Capital Operations, LLC held 17,818,438 of the 18,442,574 Class B shares attributed to him, 4.54 percent.[^25] On September 17, 2024 Botha and the six other independent directors resigned together, writing to [[Anne Wojcicki]] that they had not received "a fully financed, fully diligenced, actionable proposal" and would leave "because of your concentrated voting power."[^26]
|
||||
When [[23andMe]] became public through a merger in June 2021, Botha was a director and Sequoia Capital Operations, LLC held 17,818,438 of the 18,442,574 Class B shares attributed to him, 4.54 percent.[^31] On September 17, 2024 Botha and the six other independent directors resigned together, writing to [[Anne Wojcicki]] that they had not received "a fully financed, fully diligenced, actionable proposal" and would leave "because of your concentrated voting power."[^32]
|
||||
|
||||
### San Francisco
|
||||
|
||||
Moritz gave $300,000 in September 2020 to Neighbors for a Better [[San Francisco]], the political action committee that later spent about $4 million on the recall of District Attorney [[Chesa Boudin]]; he told [[Mission Local]] the 2020 gift was for that year's supervisorial elections.[^27] In 2024 he gave just under $1 million in January and $1.5 million in late August to the committee for Proposition D, the charter measure of [[TogetherSF]], a group he chaired and funded; Mission Local described him as a major benefactor of TogetherSF and the [[San Francisco Standard]] and reported that he had given more than $300 million to causes in the city.[^28] Proposition D, which would have capped city commissions at 65, expanded mayoral hiring and firing power and restricted police oversight, drew $9.5 million and was losing 45 to 55 percent in early returns on November 6, 2024; the mayoral candidate TogetherSF ranked first, [[Mark Farrell]], drew $5.4 million and stood fourth.[^29]
|
||||
Moritz gave $300,000 in September 2020 to Neighbors for a Better [[San Francisco]], the political action committee that later spent about $4 million on the recall of District Attorney [[Chesa Boudin]]; he told [[Mission Local]] the 2020 gift was for that year's supervisorial elections.[^33] In 2024 he gave just under $1 million in January and $1.5 million in late August to the committee for Proposition D, the charter measure of [[TogetherSF]], a group he chaired and funded; Mission Local described him as a major benefactor of TogetherSF and the [[San Francisco Standard]] and reported that he had given more than $300 million to causes in the city.[^34] Proposition D, which would have capped city commissions at 65, expanded mayoral hiring and firing power and restricted police oversight, drew $9.5 million and was losing 45 to 55 percent in early returns on November 6, 2024; the mayoral candidate TogetherSF ranked first, [[Mark Farrell]], drew $5.4 million and stood fourth.[^35]
|
||||
|
||||
### Footnotes
|
||||
|
||||
|
|
@ -210,19 +231,25 @@ Moritz gave $300,000 in September 2020 to Neighbors for a Better [[San Francisco
|
|||
[^11]: Marina Temkin, "Sequoia names Alfred Lin and Pat Grady as new co-stewards as Roelof Botha steps down," TechCrunch, November 4, 2025. https://techcrunch.com/2025/11/04/sequoia-names-alfred-lin-and-pat-grady-as-new-co-stewards-as-roelof-botha-steps-down/
|
||||
[^12]: Julie Bort, "Vinod Khosla publicly disavows Keith Rabois' comments on ICE shooting," TechCrunch, January 26, 2026. https://techcrunch.com/2026/01/26/vinod-khosla-publicly-disavows-keith-rabois-comments-on-ice-shooting/
|
||||
[^13]: Federal Election Commission, Schedule A receipts, queried October 1, 2026 through https://api.open.fec.gov/v1/schedules/schedule_a/ ; contributor "Moritz, Michael" (rows with employer Sequoia Capital, Sequoia Heritage or HRTG Partners; AB PAC C00492140, e.g. sub_id 4053020241951316444), "Leone, Doug" and "Leone, Douglas" (e.g. sub_ids 4080120231758607105, 4103020241011643180, 4021320251172522832, 4071920241978175326) and "Botha, Roelof" (committee C00150367); memo-coded rows excluded; AB PAC committee history at https://api.open.fec.gov/v1/committee/C00492140/history/
|
||||
[^14]: Elon R. Musk, Amendment No. 3 to Schedule 13D re Twitter, Inc., filed May 5, 2022, Item 4 (equity commitment table). https://www.sec.gov/Archives/edgar/data/1418091/000110465922056055/tm2214608-1_sc13da.htm
|
||||
[^15]: Adam Fisher, "Sam Bankman-Fried Has a Savior Complex, And Maybe You Should Too," Sequoia Capital website, September 22, 2022, as archived by the Internet Archive on November 9, 2022, https://web.archive.org/web/20221109025610/https://www.sequoiacap.com/article/sam-bankman-fried-spotlight/ ; live address checked October 1, 2026, redirecting to https://sequoiacap.com/companies/ftx
|
||||
[^16]: Connie Loizos, "Sequoia Capital marks its FTX investment down to zero dollars," TechCrunch, November 9, 2022, reproducing Sequoia's letter to limited partners. https://techcrunch.com/2022/11/09/sequoia-capital-marks-its-ftx-investment-down-to-zero-dollars/
|
||||
[^17]: Steve Mollman, "VC giant Sequoia writes down $214 million investment in FTX to zero: 'We are in the business of taking risk'," Fortune, November 10, 2022. https://fortune.com/2022/11/10/ftx-sam-bankman-fried-sequoia-writes-down-214-million-investment-to-zero-venture-capital-crypto
|
||||
[^18]: O'Keefe v. Sequoia Capital Operations, LLC, No. 1:23-cv-20700 (S.D. Fla.), docket (filed February 22, 2023; terminated June 21, 2023), ECF Nos. 1 and 3. https://www.courtlistener.com/docket/66837140/okeefe-v-sequoia-capital-operations-llc/
|
||||
[^19]: In re FTX Cryptocurrency Exchange Collapse Litigation, No. 1:23-md-03076-KMM (S.D. Fla.), ECF No. 914 (May 29, 2025), ECF No. 930 (June 16, 2025) and ECF No. 1124 (June 5, 2026). https://www.courtlistener.com/docket/67478547/in-re-ftx-cryptocurrency-exchange-collapse-litigation/
|
||||
[^20]: Manish Singh and Rita Liao, "Sequoia splits China and India arms from US mothership to avoid 'portfolio conflict' and 'market confusion'," TechCrunch, June 6, 2023. https://techcrunch.com/2023/06/06/sequoia-rebrands-china-india-and-southeast-asia-units/
|
||||
[^21]: SEC Investment Adviser Public Disclosure, firm search for "Sequoia Capital Operations" (Peak XV Partners Operations LLC, file 801-132249, formerly Sequoia Capital India Operations II LLC), queried October 1, 2026. https://api.adviserinfo.sec.gov/search/firm?query=sequoia%20capital%20operations
|
||||
[^22]: Rep. Mike Gallagher and Rep. Raja Krishnamoorthi, letter to Roelof Botha and Don Vieira, Sequoia Capital, October 17, 2023, Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party. https://chinaselectcommittee.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-document/2023.10.17-letter-to-sequoia-capital.pdf
|
||||
[^23]: Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party, "The CCP's Investors: How American Venture Capital Fuels the PRC Military and Human Rights Abuses," February 8, 2024, pp. 4 to 5 and note c, 7, 18, 21 and 22. https://chinaselectcommittee.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-document/2024-02-08%20-%20VC%20Report%20-%20FINAL.pdf
|
||||
[^24]: Skadden, Arps, Slate, Meagher & Flom LLP, "Don L. Vieira" (professional biography), https://www.skadden.com/professionals/v/vieira-donald-l ; "Skadden Welcomes Back Don Vieira as Partner in Washington, DC," September 9, 2025, https://www.skadden.com/about/news-and-rankings/news/2025/09/skadden-welcomes-back-don-vieira-as-partner-in-washington-dc
|
||||
[^25]: 23andMe Holding Co., Form 8-K, filed June 21, 2021 (accession 0001193125-21-194255), security ownership table and footnotes 4 and 5. https://www.sec.gov/Archives/edgar/data/1804591/000119312521194255/d187358d8k.htm
|
||||
[^26]: 23andMe Holding Co., Form 8-K, filed September 18, 2024 (accession 0001193125-24-221081), Item 5.02 and Exhibit 17. https://www.sec.gov/Archives/edgar/data/1804591/000119312524221081/d894676dex17.htm
|
||||
[^27]: Will Jarrett, "Explore: $6M poured into Boudin recall," Mission Local, May 23, 2022. https://missionlocal.org/2022/05/explore-almost-9-million-donated-for-and-against-boudin-recall/
|
||||
[^28]: Kelly Waldron, "Follow the money: Bloomberg drops $1M on Breed, Moritz puts $1.5M into charter reform," Mission Local, September 4, 2024. https://missionlocal.org/2024/09/follow-the-money-bloomberg-drops-1m-on-breed-moritz-puts-1-5m-into-prop-d/
|
||||
[^29]: Joe Rivano Barros, "Michael Moritz sank millions into losing S.F. races. What happened?" Mission Local, November 7, 2024. https://missionlocal.org/2024/11/michael-moritz-togethersf-sf-elections-november-2024/
|
||||
[^14]: Ali Partovi, "Kalshi raises $30M from Sequoia and Wall St titans," Neo News, February 19, 2021, https://neo.substack.com/p/kalshi-raises-30m-from-sequoia-and ; Kalshi, "Kalshi Raises $30 Million in Series A Funding Led by Sequoia," February 17, 2021. https://news.kalshi.com/p/kalshi-raises-30-million-in-series-a-funding-led-by-sequoia
|
||||
[^15]: SEC Form D, Kalshi Inc. (CIK 1806928): accession 0001806928-21-000001, filed February 23, 2021, https://www.sec.gov/Archives/edgar/data/1806928/000180692821000001/primary_doc.xml ; accession 0001231919-25-000344, first sale October 8, 2025, filed October 23, 2025 (294,500,203 dollars sold to 20 investors), https://www.sec.gov/Archives/edgar/data/1806928/000123191925000344/primary_doc.xml ; accession 0001231919-26-001066, first sale April 3, 2026, filed August 25, 2026 (1,120,010,122 dollars sold to 71 investors). https://www.sec.gov/Archives/edgar/data/1806928/000123191926001066/primary_doc.xml
|
||||
[^16]: Decrypt, "Prediction market Kalshi hits $2 billion valuation with $185 million raise," June 25, 2025, quoting Mansour's post: "The round was led by Paradigm with participation from Sequoia, Multicoin, Peng Zhao, Neo, and Bond Capital." https://decrypt.co/327074/prediction-market-kalshi-2-billion-valuation-185-million-raise
|
||||
[^17]: Kalshi, "Kalshi hits $5 billion valuation amid international expansion," October 10, 2025. https://news.kalshi.com/p/kalshi-hits-5-billion-valuation-amid-international-expansion
|
||||
[^18]: Timmy Shen, "Kalshi secures $1 billion in latest funding at $11 billion valuation: report," The Block, November 20, 2025, https://www.theblock.co/post/379851/kalshi-1-billion-funding ; Kalshi, "Kalshi Reaches $11 Billion Valuation as App Takes over America," December 2, 2025. https://news.kalshi.com/p/kalshi-11-billion-valuation-series-e
|
||||
[^19]: Brian Danga, "Kalshi hits $22 billion valuation after $1 billion raise led by Coatue," The Block, May 7, 2026. https://www.theblock.co/post/400413/kalshi-hits-22-billion-valuation-after-1-billion-raise-led-by-coatue
|
||||
[^20]: Elon R. Musk, Amendment No. 3 to Schedule 13D re Twitter, Inc., filed May 5, 2022, Item 4 (equity commitment table). https://www.sec.gov/Archives/edgar/data/1418091/000110465922056055/tm2214608-1_sc13da.htm
|
||||
[^21]: Adam Fisher, "Sam Bankman-Fried Has a Savior Complex, And Maybe You Should Too," Sequoia Capital website, September 22, 2022, as archived by the Internet Archive on November 9, 2022, https://web.archive.org/web/20221109025610/https://www.sequoiacap.com/article/sam-bankman-fried-spotlight/ ; live address checked October 1, 2026, redirecting to https://sequoiacap.com/companies/ftx
|
||||
[^22]: Connie Loizos, "Sequoia Capital marks its FTX investment down to zero dollars," TechCrunch, November 9, 2022, reproducing Sequoia's letter to limited partners. https://techcrunch.com/2022/11/09/sequoia-capital-marks-its-ftx-investment-down-to-zero-dollars/
|
||||
[^23]: Steve Mollman, "VC giant Sequoia writes down $214 million investment in FTX to zero: 'We are in the business of taking risk'," Fortune, November 10, 2022. https://fortune.com/2022/11/10/ftx-sam-bankman-fried-sequoia-writes-down-214-million-investment-to-zero-venture-capital-crypto
|
||||
[^24]: O'Keefe v. Sequoia Capital Operations, LLC, No. 1:23-cv-20700 (S.D. Fla.), docket (filed February 22, 2023; terminated June 21, 2023), ECF Nos. 1 and 3. https://www.courtlistener.com/docket/66837140/okeefe-v-sequoia-capital-operations-llc/
|
||||
[^25]: In re FTX Cryptocurrency Exchange Collapse Litigation, No. 1:23-md-03076-KMM (S.D. Fla.), ECF No. 914 (May 29, 2025), ECF No. 930 (June 16, 2025) and ECF No. 1124 (June 5, 2026). https://www.courtlistener.com/docket/67478547/in-re-ftx-cryptocurrency-exchange-collapse-litigation/
|
||||
[^26]: Manish Singh and Rita Liao, "Sequoia splits China and India arms from US mothership to avoid 'portfolio conflict' and 'market confusion'," TechCrunch, June 6, 2023. https://techcrunch.com/2023/06/06/sequoia-rebrands-china-india-and-southeast-asia-units/
|
||||
[^27]: SEC Investment Adviser Public Disclosure, firm search for "Sequoia Capital Operations" (Peak XV Partners Operations LLC, file 801-132249, formerly Sequoia Capital India Operations II LLC), queried October 1, 2026. https://api.adviserinfo.sec.gov/search/firm?query=sequoia%20capital%20operations
|
||||
[^28]: Rep. Mike Gallagher and Rep. Raja Krishnamoorthi, letter to Roelof Botha and Don Vieira, Sequoia Capital, October 17, 2023, Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party. https://chinaselectcommittee.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-document/2023.10.17-letter-to-sequoia-capital.pdf
|
||||
[^29]: Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party, "The CCP's Investors: How American Venture Capital Fuels the PRC Military and Human Rights Abuses," February 8, 2024, pp. 4 to 5 and note c, 7, 18, 21 and 22. https://chinaselectcommittee.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-document/2024-02-08%20-%20VC%20Report%20-%20FINAL.pdf
|
||||
[^30]: Skadden, Arps, Slate, Meagher & Flom LLP, "Don L. Vieira" (professional biography), https://www.skadden.com/professionals/v/vieira-donald-l ; "Skadden Welcomes Back Don Vieira as Partner in Washington, DC," September 9, 2025, https://www.skadden.com/about/news-and-rankings/news/2025/09/skadden-welcomes-back-don-vieira-as-partner-in-washington-dc
|
||||
[^31]: 23andMe Holding Co., Form 8-K, filed June 21, 2021 (accession 0001193125-21-194255), security ownership table and footnotes 4 and 5. https://www.sec.gov/Archives/edgar/data/1804591/000119312521194255/d187358d8k.htm
|
||||
[^32]: 23andMe Holding Co., Form 8-K, filed September 18, 2024 (accession 0001193125-24-221081), Item 5.02 and Exhibit 17. https://www.sec.gov/Archives/edgar/data/1804591/000119312524221081/d894676dex17.htm
|
||||
[^33]: Will Jarrett, "Explore: $6M poured into Boudin recall," Mission Local, May 23, 2022. https://missionlocal.org/2022/05/explore-almost-9-million-donated-for-and-against-boudin-recall/
|
||||
[^34]: Kelly Waldron, "Follow the money: Bloomberg drops $1M on Breed, Moritz puts $1.5M into charter reform," Mission Local, September 4, 2024. https://missionlocal.org/2024/09/follow-the-money-bloomberg-drops-1m-on-breed-moritz-puts-1-5m-into-prop-d/
|
||||
[^35]: Joe Rivano Barros, "Michael Moritz sank millions into losing S.F. races. What happened?" Mission Local, November 7, 2024. https://missionlocal.org/2024/11/michael-moritz-togethersf-sf-elections-november-2024/
|
||||
|
|
|
|||
|
|
@ -119,8 +119,13 @@ relations:
|
|||
start: 2023-12-11
|
||||
role: "registered lobbyist"
|
||||
fn: 37
|
||||
- type: funded
|
||||
with: "[[Kalshi]]"
|
||||
start: 2019
|
||||
role: "accelerator, Winter 2019 batch; YC Continuity in the Series A; named among the Series E participants"
|
||||
fn: 39
|
||||
created: 2026-10-01
|
||||
updated: 2026-10-01
|
||||
updated: 2026-10-13
|
||||
---
|
||||
|
||||
Y Combinator (YC) is a startup investment firm that [[Paul Graham]] and [[Jessica Livingston]] decided to start on March 11, 2005, walking home from dinner in [[Harvard Square]]. Graham agreed to put in 100,000 dollars, and over the following days [[Robert Tappan Morris|Robert Morris]] and [[Trevor Blackwell]] put in 50,000 dollars each, so that the firm began with 200,000 dollars. It was first called Cambridge Seed and was renamed Y Combinator before its announcement a few days later.[^1] Its standard deal is 500,000 dollars per company: 125,000 dollars for 7 percent on a post-money SAFE and 375,000 dollars on an uncapped SAFE with a most-favored-nation clause.[^2] Its investment adviser, Y Combinator Management, LLC, reports nineteen private funds with combined gross assets of about 22 billion dollars.[^3]
|
||||
|
|
@ -195,6 +200,10 @@ The firm [[Venture Politics]] registered on September 5, 2014 to lobby for Y Com
|
|||
|
||||
The Series F announcement of [[Scale AI]] on May 21, 2024 lists Y Combinator among the existing investors in the 1 billion dollar round at a 13.8 billion dollar valuation, alongside [[Nat Friedman]], [[Index Ventures]], Founders Fund and the lead investor [[Accel]], and lists [[Meta Platforms|Meta]] among the new investors.[^38]
|
||||
|
||||
### Kalshi
|
||||
|
||||
[[Kalshi]], a New York event-contract exchange, is listed in the Y Combinator company directory as a Winter 2019 batch company with founders [[Tarek Mansour]] and [[Luana Lopes Lara]]. The directory gives 2019 as the founding year and calls the company the "1st federally regulated exchange where people can trade on events."[^39] Y Combinator's October 8, 2018 hackathon recap reports 250 participants and three teams winning office hours, one of them "Kalshi," "Opinion gathering platform," with Mansour, Lopes Lara and [[Duncan Cock Foster]] as members.[^40] The company's first Form D, filed March 19, 2020, gives 2018 as the year of incorporation.[^41] [[YC Continuity]] was among the previous investors in the 30 million dollar Series A of February 17, 2021, and Y Combinator is named among the participants in the 1 billion dollar Series E announced December 2, 2025.[^42] A Form D filed October 23, 2025 lists [[Michael Seibel]] as a director of Kalshi Inc.[^43] On March 20, 2025 Mansour wrote on X: "Without @mwseibel, Kalshi wouldn’t exist."[^44]
|
||||
|
||||
### Footnotes
|
||||
|
||||
[^1]: Graham, Paul. "How Y Combinator Started." paulgraham.com, March 2012. https://paulgraham.com/ycstart.html
|
||||
|
|
@ -235,3 +244,9 @@ The Series F announcement of [[Scale AI]] on May 21, 2024 lists Y Combinator amo
|
|||
[^36]: Federal Election Commission, Schedule A (42 records) and Schedule B (72 records) for committee C00930727, two-year period 2026, queried October 1, 2026. https://api.open.fec.gov/v1/schedules/schedule_a/?committee_id=C00930727 ; https://api.open.fec.gov/v1/schedules/schedule_b/?committee_id=C00930727
|
||||
[^37]: U.S. Senate and House, Lobbying Disclosure Act filings for client Y Combinator: Venture Politics registration posted September 5, 2014, https://lda.gov/filings/public/filing/7f934920-3e3f-46e4-bfe0-2cd9379fbdae/print/ , and termination posted October 20, 2014, https://lda.gov/filings/public/filing/784b304f-43fa-4dc0-8ddc-bd1a64a8f877/print/ ; The Joseph Group, LLC registration posted December 11, 2023, https://lda.gov/filings/public/filing/cd6749cc-6a4f-4565-8b39-e4f42f395e7d/print/ , and quarterly reports for the fourth quarter of 2023 through the second quarter of 2026, https://lda.gov/api/v1/filings/?client_name=Y+Combinator
|
||||
[^38]: Wang, Alexandr. "Scale's Series F: Expanding the Data Foundry for AI." Scale AI, May 21, 2024. https://scale.com/blog/scale-ai-series-f
|
||||
[^39]: Y Combinator, company page for Kalshi (W19). https://www.ycombinator.com/companies/kalshi
|
||||
[^40]: Y Combinator, "October 2018 Hackathon Recap," October 8, 2018. https://www.ycombinator.com/blog/october-2018-hackathon-recap
|
||||
[^41]: SEC Form D, Kalshi Inc. (CIK 1806928), accession 0001806928-20-000001, filed March 19, 2020. https://www.sec.gov/Archives/edgar/data/1806928/000180692820000001/primary_doc.xml
|
||||
[^42]: Kalshi, "Kalshi Raises $30 Million in Series A Funding Led by Sequoia," February 17, 2021, https://news.kalshi.com/p/kalshi-raises-30-million-in-series-a-funding-led-by-sequoia ; "Kalshi Reaches $11 Billion Valuation as App Takes over America," December 2, 2025. https://news.kalshi.com/p/kalshi-11-billion-valuation-series-e
|
||||
[^43]: SEC Form D, Kalshi Inc., accession 0001231919-25-000344, filed October 23, 2025. https://www.sec.gov/Archives/edgar/data/1806928/000123191925000344/primary_doc.xml
|
||||
[^44]: Tarek Mansour (@mansourtarek_), X, March 20, 2025. https://x.com/mansourtarek_/status/1902515335560880431
|
||||
|
|
|
|||
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