Sports and Gaming Law 2025 Year in Review: Top Five Developments

February 17, 2026

Client Alert

WHAT YOU NEED TO KNOW:

Prediction Markets Reshape Sports Betting: Prediction markets surged in 2025, with sports-based event contracts drawing major industry players and prompting litigation over whether these products are governed by federal commodities law or state gaming regimes, with courts and the CFTC poised to redefine regulatory authority.
Rising Integrity and Compliance Pressures in Sports Betting: A wave of betting related investigations highlighted vulnerabilities tied to prop and micro betting, driving stronger enforcement efforts and closer coordination among leagues, sportsbooks, and regulators.
Structural Transformation of Sports Business Through Capital, Antitrust, and Global Expansion: Private capital investment, antitrust challenges, and NIL continued to disrupt traditional sports models, while U.S. leagues expanded globally through international games and streaming, introducing new regulatory and governance complexities.

Authors

2025 marked a period of profound transformation across the sports and gaming industries. From the explosive growth of prediction markets and robust integrity enforcement in sports betting to record-setting franchise acquisitions and name, image, and likeness (NIL) deals, the industry saw trends from prior years accelerate. Legal developments—including antitrust litigation and shifting regulatory frameworks—promise to reshape the relationships between leagues, athletes and investors. Meanwhile, US sports leagues continue to focus on growing international engagement and opportunity. This article examines the top five developments that defined sports and gaming in 2025, analyzing the forces driving change and the implications for stakeholders, who must navigate an increasingly complex and dynamic landscape.

Prediction Markets and Sports-Based Event Contracts

Prediction markets are exchanges where participants buy and trade contracts reflecting the outcome of real-world events (event contracts)—from election results¹ to sports games² and more niche questions, such as whether a super volcano will erupt before 2050³and who will play the next James Bond.⁴ Event contracts are generally understood to be a form of derivative, typically structured with a binary payoff that depends on the outcome of an underlying event. Although the Commodity Futures Trading Commission (CFTC) has regulated prediction markets and similar exchanges for decades,⁵ in recent years, the contracts offered on prediction markets have changed dramatically, and the popularity of sports-related event contracts exploded in 2025.

In 2025, trading activity for sports-related event contracts reached unprecedented levels. Reports indicated that the two leading exchanges—Kalshi and Polymarket—collectively recorded more than $6 billion in weekly trading volume.⁶ At the same time, several major gaming companies entered, or began actively exploring, prediction markets as a new frontier. In 2025, prominent entities in the sports and gaming industries—including DraftKings, Underdog,⁷ FanDuel, Fanatics⁸ and Sports Illustrated⁹—announced plans to launch their own prediction market platforms, while major media and technology platforms such as X,¹⁰ Yahoo Finance,¹¹ CNN¹² and Google¹³ began integrating real‑time data from existing exchanges into their products and user experiences.

Despite their rapid growth and increasing mainstream acceptance, sports-related event contracts face significant legal uncertainty. Since the US Supreme Court ruled in Murphy v. NCAA that states could legalize and regulate sports betting,¹⁴ individuals could place sports wagers only in states that affirmatively legalized online sports betting and only with licensed sportsbooks. As a result, sports-related wagers fell outside the purview of the CFTC and under the purview of the states. Recently, however, prediction market platforms introduced nationwide access to wager‑like trading on sports outcomes, even in states where online sports betting is not legal, a move spurred by a 2024 decision from the US Court of Appeals for the District of Columbia permitting Kalshi to offer event contracts tied to the outcome of the November 2024 congressional elections on its CFTC‑regulated platform.¹⁵

The introduction of sports-related event contracts has effectively shifted an activity typically governed by state law—sports-related wagering—into the federal domain.¹⁶ Under the Trump Administration, the CFTC acceded to the notion that all event contracts fall within the exclusive purview of the Commodity Exchange Act (CEA).¹⁷Conversely, state¹⁸ and tribal authorities,¹⁹ which have traditionally overseen sports betting in their jurisdictions, increasingly classify sports-related event contracts as gaming subject to state or tribal gaming regulations. These divergent views—of states and tribes on one hand, and of the CFTC on the other—have fueled a wave of litigation in state and federal courts.²⁰ Meanwhile, federal courts issued conflicting rulings as to whether sports-related event contracts fall within the purview of state anti-gaming laws²¹ or are preempted by the CEA.²²

Without consistent guidance from courts or regulators, prediction market operators must navigate a patchwork of conflicting obligations rife with compliance risk and potential exposure to civil and criminal penalties at the state level. Although CFTC Chairman Michael Selig stated in January 2026 that the CFTC intends to regulate prediction markets under the CEA,²³ state-level litigation and resistance persist, underscoring that courts may ultimately determine the allocation of regulatory authority over prediction markets.²⁴

US Courts of Appeals for the Third, Fourth and Ninth Circuits are considering whether the CEA preempts state anti-gaming laws.²⁵ While the circuit courts’ decisions may bring short-term clarity, the potential for conflicting decisions—absent an ultimate resolution by the US Supreme Court—threatens to prolong regulatory uncertainty. Nonetheless, if the ultimate judicial determination is that the CEA does preempt state laws purporting to regulate sports-related event contracts, states would have to cede authority over those event contracts to the CFTC. Conversely, if the US Supreme Court determines the CEA does not preempt state gaming laws, prediction market operators would have to traverse a complex regulatory landscape, rife with differing state laws that platforms claim would threaten their ability to maintain a “single nationwide market.”²⁶Ultimately, however, these appeals signal that the judiciary is likely to determine whether sports-related event‑contract markets gain long‑sought clarity or remain subject to a divided and burdensome compliance landscape.

Notably, in January 2026, the CFTC expressed its intention to regulate prediction markets exclusively and to allow sports-related event contracts to be traded on CFTC-backed exchanges.²⁷ Chairman Selig directed the CFTC to withdraw Biden-era proposals to “prohibit political and sports-related event contracts” on CFTC-regulated exchanges; to “move forward with drafting an event contracts rulemaking”; to “reassess the [CFTC’s] participation in matters pending before the federal district and circuit courts”; and to “defend [the CFTC’s] exclusive jurisdiction” (i.e., federal preemption) “over commodity derivatives” in court.²⁸ Accordingly, prediction market operators now have an important ally—the CFTC—as they seek to defeat challenges from states, tribes and private entities over sports-related and other event contracts. Nevertheless, clarity may not arrive unless the appellate courts—and ultimately the US Supreme Court—weigh in.

Integrity Issues and Sports Betting

Although integrity concerns in sports betting are long-standing, recent enforcement actions highlight the risks related to the proliferation of legalized sports betting.²⁹ In 2025, several NBA players and coaches were charged with conspiracy to commit wire fraud and money laundering for allegedly using insider information to win bets,³⁰and Toronto Raptors player Jontay Porter pleaded guilty to conspiracy to commit wire fraud for doing the same.³¹ Meanwhile, MLB pitchers Emmanuel Clase and Luis Ortiz pleaded not guilty to conspiracy charges for allegedly rigging player position bets related to their pitching.³²

The House and Senate have taken notice of the high-profile investigations. On the heels of the Ortiz and Clase indictments,³³ the US Senate Committee on Commerce, Science, and Transportation sent inquiries to MLB in November 2025 requesting information “on allegations of gambling corruption in the league.”³⁴ Similarly, in October 2025, the House Committee on Energy and Commerce sent an inquiry to the NBA following a federal investigation into an illegal betting ring³⁵ and a letter to NCAA President Charlie Baker regarding the NCAA’s announcement that athletes and staff will be allowed to bet on professional sports.³⁶

Proposition bets (prop bets)—wagers on specific in-game events (e.g., whether a player will score or a quarterback will throw an interception)—are a common source of integrity violations, in part because players can personally influence specific occurrences. Some leagues, including MLB,³⁷ the NBA³⁸and the NFL³⁹ have worked with sportsbooks to curb unlawful prop bets and to reduce or eliminate the availability of bets that are uniquely susceptible to manipulation.⁴⁰ And legislators in several states—citing “a torrent of controversies related to match fixing in professional and collegiate sports”—have introduced legislation seeking to ban in-game prop betting.⁴¹ Because prop bets are highly profitable—and even considered by some to be the “backbone” of popular wagers⁴²—sportsbooks, leagues and states are incentivized to prevent manipulation.

Although it is impossible to stop all illegal activity, coordination between leagues, teams, sportsbooks and law enforcement—facilitated by the increased regulation of sports betting—has markedly improved the ability to detect illegal activity.⁴³ “[R]egulated sportsbooks are proving to be effective watchdogs,” not instruments that undermine fair play, in part because “[t]heir data-driven insights and compliance protocols are helping uncover misconduct that would have otherwise remained buried.”⁴⁴ Compliance measures like Know Your Customer protocols and anti-money laundering laws help uncover misconduct, unlike “illegal betting markets [which] lack oversight” and are therefore “fertile ground for corruption.”⁴⁵ Indeed, illegal betting has dropped sharply—from between $149 billion and $500 billion in 2017 to $63.8 billion in 2023⁴⁶—reflecting the success and draw of legal frameworks. With leagues, sportsbooks and states benefiting from betting revenue,⁴⁷ key stakeholders have a vested interest in integrity, which remains critical; fans will only watch—and bet on—sports if they trust the games are fair.

Franchise Acquisitions and Private Capital Investment in Sports

In 2025, the sports industry cemented its status as a premier investment sector. 2025 saw record-high valuations and landmark franchise sales, including the sales of the Los Angeles Lakers⁴⁸ and the Boston Celtics,⁴⁹ and the acquisition of shares by institutional investors in marquee franchises like the San Francisco Giants,⁵⁰ the New England Patriots⁵¹ and the New York Giants.⁵² The influx of institutional capital is substantial; today, nearly 20% of teams across the four major men’s US professional sports leagues (NFL, NBA, MLB and NHL) have some level of private equity involvement.⁵³ This growth also reached emerging organizations and women’s professional sports leagues, such as the NWSL and WNBA,⁵⁴ which increasingly leverage private lenders and institutional capital to fuel rapid expansion, driven by their own record valuations.

Professional sports leagues draw major investment for a variety of reasons. In particular, their closed‑system structure—characterized by revenue sharing, player drafts and salary caps—helps ensure predictable long‑term costs and stable cash flow, reinforced by diversified revenue sources (e.g., multiyear media rights agreements, corporate sponsorships and in-venue revenue). Investors are also drawn to sports franchises because of their ability to monetize real estate assets, using stadiums for large-scale, mixed-use developments that integrate hospitality, retail and residential components and to host community development projects. Similarly, international expansion and the adaptive nature of franchises’ business models (e.g., the ability to generate revenue through hospitality, content creation and data analytics) have also driven institutional investments.

Private investment activity also flourished for collegiate athletics, as universities and conferences explored new financial models to fund operations, facilities and sponsorships in the NIL era. The Big Ten Conference is negotiating a $2.4 billion proposal with UC Investments for a 10% stake in future media rights and sponsorships through 2046 in exchange for an immediate cash infusion to its 18 member schools,⁵⁵ and the University of Utah is finalizing a landmark partnership with Otro Capital to create a for-profit, distinct entity projected to generate an estimated $500 million for the school.⁵⁶

Nevertheless, collegiate athletics will likely face governance challenges throughout 2026 as schools navigate how to weigh private credit deals against fiduciary duties. Several schools have publicly noted the risks associated with complex private credit proposals, such as long-term value erosion, inflexibility and governance deficiencies.⁵⁷ Others have acknowledged the risk of friction if the venture fails to generate expected revenue and the inherent tension between commercial success and the university’s mission, even claiming the school could veto any sponsorship opportunity at odds with its values.⁵⁸

The distinct structural and economic characteristics of professional sports leagues will likely continue to fuel transactional activity throughout 2026, which will necessarily heighten litigation and governance risk. Private equity investments may trigger regulatory scrutiny and disputes centering on governance structure, control provisions, fiduciary duties, valuation methodologies and revenue-sharing arrangements. And the prevalence of minority investments promises to create fertile ground for stakeholder friction.⁵⁹ Consequently, teams should implement robust governance frameworks and comprehensive operating agreements that clearly define decision-making authority, information rights and the processes governing major capital expenditures. Doing so will help ensure clarity regarding authority over decisions impacting profits and valuations—a uniquely important determination for sports franchises, whose on-the-field success directly impacts revenue and valuation.

The Growing Conflict Between Sports and Antitrust Laws

In 2025, collegiate and professional sports saw antitrust challenges over NIL rights, revenue sharing and market control—developments that could dismantle traditional regulations and usher in a new era for sports businesses. These cases highlight a clear theme: Antitrust law is a useful mechanism for redefining economic relationships in sports. Indeed, without comprehensive legislation from Congress, athletes and teams are increasingly turning to litigation to assert competition rights, pressuring traditional league models to evolve.

In 2021, the US Supreme Court ruled in In re College Athlete NIL Litigation⁶⁰ that NCAA restrictions on athlete compensation violated Section I of the Sherman Act, uprooting the history of amateurism that had long been the hallmark of collegiate athletics. The parties reached a $2.8 billion settlement in 2024,⁶¹ which was approved by Judge Claudia Wilken in June 2025⁶² but is the subject of three Title IX appeals before the US Court of Appeals for the Ninth Circuit.⁶³

The ruling that NCAA athletes are eligible for compensation exemplifies the need for a new legal regime to govern collegiate athletics. But recent legislation, including the Student Compensation and Opportunity through Rights and Endorsements Act (SCORE Act)—which was designed to address athletes’ compensation, clarify that NCAA athletes are not employees and provide the NCAA with antitrust immunity⁶⁴—has stalled.⁶⁵ This may signal a shift in Congress’s views regarding antitrust protections and caution among lawmakers around expanding antitrust exemptions—a posture that may increase scrutiny of practices that limit competition.

Mounting antitrust pressure on NASCAR, for example, highlights growing scrutiny of how major sports organizations wield market power. In October 2024, 23Xl Racing—owned by NBA superstar Michael Jordan—and Front Row Motorsports sued NASCAR, claiming NASCAR’s control of the racing market violated the Sherman Act.⁶⁶ The dispute centered on NASCAR’s charter agreement, which plaintiffs claimed functionally forced teams to sign unfair terms to avoid “economically devastating” consequences and which prohibited participation in “automobile or truck racing” outside NASCAR events.⁶⁷ Although the parties reached a settlement agreement in December 2025,⁶⁸ this controversy illustrates a potential transformation in NASCAR’s approach to its traditional business model and the strength of athletes’ demands for fairness; plaintiffs lauded the settlement as evidence of “progress.”⁶⁹

Furthermore, recent lawsuits against professional tennis organizations exemplify the escalating clash between sports leagues and antitrust law. In March 2025, the Professional Tennis Players Association and numerous athletes sued professional tennis organizations⁷⁰ and organizers of the Grand Slam events, alleging violations of the Sherman Act, related in part to player compensation, competition, NIL rights and sponsorship restrictions.⁷¹ This case underscores the movement toward safeguarding athletes’ economic rights and could significantly reshape how professional tennis and other sports organizations operate.

In short, the sports industry is recalibrating as athletes increasingly challenge entrenched governance and economic arrangements through litigation. In both professional and collegiate sports, these disputes reflect growing pressure on traditional power dynamics. Although 2025 did not conclusively determine how changes to athletes’ economic rights will ultimately play out, it did move the needle one step further in athletes’ favor.

Growth of US Sports Abroad

2025 may have marked an inflection point in the outward expansion of America’s major leagues, with the NFL, the NBA and MLB all staging high‑profile events outside US borders and, in some cases, committing to multiyear footholds in new markets.⁷²

In 2025, the NFL expanded its international reach, scheduling a record seven regular-season international games in five countries: Brazil, Ireland, Germany, Spain and the United Kingdom. Madrid and Berlin hosted their first-ever NFL games that year,⁷³ and NFL Commissioner Roger Goodell reiterated that the league plans to increase the number of international games such that each team will play one game abroad each year.⁷⁴The NFL has separately sought to grow its international fan base by “expand[ing] its Global Markets Program, which awards teams international marketing rights to build brand awareness and fandom beyond the United States”; “[n]ow[,] all 32 teams participate in the program across 21 international markets”—a substantial increase from 2019, when only 25 clubs participated across 19 markets.⁷⁵

The NBA likewise sought to grow its international presence. It broadened its calendar of overseas showcases⁷⁶ and has stated it plans to host “preseason games in China and Europe.”⁷⁷ The NBA is also eyeing an expansion in Europe and Asia and has had conversations with investors and partners about creating an “NBA-backed European league.”⁷⁸

MLB has similarly expanded its international reach. In 2025, for the first time in MLB history, the regular season began and ended outside the United States,⁷⁹ as MLB opted to host these “season-defining events” abroad⁸⁰—a move driven by profitable international TV details and fan demand.⁸¹ Notably, globalization proved lucrative; in 2024, for instance, viewership, jersey and apparel sales, and sponsorships abroad grew substantially.⁸² Indeed, when Shohei Ohtani, a Japanese-born pitcher for the Los Angeles Dodgers, won his third MVP award in 2024, the Dodgers received an influx of Japanese sponsors, netting the team $100 million in one year.⁸³

This international growth is accompanied by a rapidly evolving international media ecosystem. Streaming services will be integral to distributing games abroad, and spending on streaming rights has ballooned in recent years, with one estimate projecting that streaming services will account for $12.5 billion in sports-rights expenditure in 2025.⁸⁴ Relatedly, media spending on streaming rights to live sports in the US surged to roughly $30 billion in 2025, reflecting the premium value of live sports.⁸⁵ Recently, the NBA reached a multiyear deal with Tencent, a Chinese digital media company, allowing Tencent to stream NBA games in China through 2027.⁸⁶ The deal suggests that the NBA’s interest in China—long a top overseas market⁸⁷—has regained momentum and signals the willingness of American leagues to expand globally—a posture bolstered by the NBA’s 2025 decision to host its first games in China since 2019. As various leagues seek to expand their reach abroad and as cross‑border distribution becomes increasingly reliant on streaming services, each league will have to navigate complex rights architectures in foreign countries.

Labor, immigration and commercial restrictions also loom large as US-based leagues seek to expand internationally. Player and staff visa logistics and taxation, for example, vary by host country. Sponsorship and ownership trends—particularly private equity and potential sovereign capital—raise governance issues and, in certain regions, risk exposure to sanctions and Foreign Corrupt Practices Act and/or UK Bribery Act liability over such investments. Meanwhile, antitrust scrutiny is intensifying, a theme that may continue to arise as US sports seek expansion into international markets, often with different—and stricter—antitrust laws.

The international expansion of American sports leagues in 2025 marks a pivotal shift in the global sports landscape. As American leagues continue to build their brands and operations worldwide, their success will depend on navigating diverse legal frameworks—ensuring that the promise of global growth is matched by careful compliance and adaptive strategy.

Conclusion

The changes of 2025 have positioned 2026 as a pivotal year for the sports industry. Courts and regulators may finally decide whether sports‑related event contracts fall under state anti‑gaming laws or the CEA—a determination that could reset the sports wagering landscape. Pressure to curb manipulation may drive limits on prop bets, while private equity investment, Title IX appeals and athlete‑compensation cases could reshape governance and collegiate sports obligations. And as US leagues push abroad, new opportunities for growth are likely to emerge, while challenges, related primarily to streaming rights and foreign regulations, may confront stakeholders in new environments. Ultimately, 2026 is poised to clarify unsettled areas and open new paths for strategic growth.

Footnotes
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1. See generally Kalshi, Politics: US Elections, https://kalshi.com/?category=politics&tag=us-elections (last visited Dec. 5, 2025).
2. See generally Kalshi, Sports: Games, https://kalshi.com/sports/all-sports (last visited Dec. 5, 2025).
3. Kalshi, Will a supervolcano erupt before 2050?, https://kalshi.com/markets/kxeruptsuper/supervolcano/kxeruptsuper-0 (last visited Dec. 7, 2025).
4. Kalshi, Who will be the next James Bond?, https://kalshi.com/markets/kxbond/next-bond-actor/kxbond-30 (last visited Dec. 7, 2025). Unfortunately, nobody is betting that the undersigned authors of this article will play 007.
5. See Remarks of Chairman Michael S. Selig at CFTC-SEC Event on Harmonization, The Next Phase of Project Crypto: Unleashing Innovation for the New Frontier of Finance, CFTC (Jan. 29, 2026), https://www.cftc.gov/PressRoom/SpeechesTestimony/opaselig1 (“[Prediction] markets are not new. They have operated within the CFTC’s regulatory perimeter for more than two decades.”).
6. See, e.g., Valerie Cross, Prediction Markets Hit New $6.2B High as Kalshi Extends Win Streak, DeFi Rate (Jan. 26, 2026), https://defirate.com/news/prediction-markets-hit-new-6-2b-high-as-kalshi-extends-win-streak/#:~:text=Table_title: Top platforms notional volume and market,($): $6,181,713,904 | WoW Change: 3.1% |.
7. In September, Underdog Sports and Crypto.com announced a partnership to offer sports prediction markets in more than a dozen states, many of which have not yet legalized traditional sports betting. See Contessa Brewer, Crypto.com and Underdog partner to offer sports prediction markets, CNBC (Sept. 2, 2025), https://www.cnbc.com/2025/09/02/cryptocom-and-underdog-partner-to-offer-sports-prediction-markets.html.
8. In December 2025, Fanatics entered the prediction market space, partnering with Crypto.com to allow users in nearly half of US states to trade event contracts tied to outcomes in sports, pop culture and politics. Niket Nishant, Fanatics wades into prediction markets as users seek fresh trading options, Reuters (Dec. 4, 2025), https://www.reuters.com/business/fanatics-wades-into-prediction-markets-users-seek-fresh-trading-options-2025-12-03/.
9. In March 2025, Galactic and Sports Illustrated—a leading sports and culture brand—announced plans to launch SI Predict, a new prediction market platform that promises to “transform[] fandom into active participation.” Authentic Brands Group, Galactic to Launch SI Predict, a First-of-Its-Kind Prediction Platform Under License from Sports Illustrated, Authentic Brands Group (March 27, 2025), https://corporate.authentic.com/press-releases/galactic-si-predict-first-of-its-kind-prediction-platform-sports-illustrated.
10. X reached a deal with Polymarket to integrate its prediction market data into X users’ feeds and home pages. Kirk Ogunrinde, Musk’s X Selects Polymarket as Prediction Market Partner, Bloomberg (June 6, 2025), https://www.bloomberg.com/news/articles/2025-06-06/musk-s-x-selects-polymarket-as-prediction-market-partner.
11. Yahoo Finance teamed up with Polymarket to integrate its prediction data into its user interface. André Beganski, Yahoo Finance Taps Polymarket as Exclusive Prediction Market Provider, yahoo! finance (Nov. 12, 2025), https://finance.yahoo.com/news/yahoo-finance-taps-polymarket-exclusive-211454809.html.
12. CNN partnered with Kalshi to embed prediction market probabilities into its programming and news ticker. See Sara Fischer, Exclusive: CNN strikes prediction data partnership with Kalshi, Axios (Dec. 2, 2025), https://www.axios.com/2025/12/02/cnn-kalshi-prediction-market-data.
13. This year, Google announced its collaboration with both Kalshi and Polymarket to incorporate predictive analytics into its search and content tools. Rob Wile, Google will integrate Kalshi and Polymarket predictions into its finance AI tools, NBC News (Nov. 7, 2025), https://www.nbcnews.com/business/consumer/google-kalshi-polymarket-prediction-markets-rcna242670.
14. 584 U.S. 453 (2018).
15. See Opinion, KalshiEX LLC v. CFTC, No. 23-cv-03257 (D.C. Cir. Oct. 2, 2024) at 2.
16. See Ben Blatt and Amy Fan, Is Sports Betting Illegal in Your State? Not if You Call It a ‘Prediction Market,’ New York Times (Oct. 5, 2025), https://www.nytimes.com/2025/10/05/upshot/sports-betting-prediction-markets.html.
17. See Remarks of Chairman Michael S. Selig at CFTC-SEC Event on Harmonization, supra note 5. Moreover, in 2025, the CFTC authorized Polymarket to operate a trading platform subject to the full panoply of requirements (i.e., the CEA and CFTC regulations) applicable to federally regulated US exchanges. And earlier in 2025, the CFTC withdrew its appeal of a federal court’s decision, authorizing Kalshi to list certain event contracts as derivatives subject to CFTC jurisdiction. See Laura Matthews & Chris Prentice, CFTC moves to drop appeal in Kalshi’s event contracts case, Reuters (May 5, 2025), https://www.reuters.com/markets/commodities/cftc-moves-drop-appeal-kalshis-event-contracts-case-2025-05-05/.
18. Moreover, recently, Massachusetts added a notable new data point—one that arrived through a different procedural posture. Rather than a prediction market operator suing in federal court to enjoin state enforcement, the Massachusetts Attorney General brought an enforcement action in state court in September 2025, alleging that Kalshi was offering de facto sports wagering without the required state license. In January 2026, the Massachusetts Superior Court granted the Attorney General’s motion for a preliminary injunction prohibiting Kalshi from offering sports‑related event contracts in Massachusetts absent a license under the state’s Sports Wagering Law and denied Kalshi’s motion to dismiss, rejecting Kalshi’s federal preemption arguments. Order on Plaintiff’s Mot. for a Prelim. Injunction and Def. Mot. to Dismiss, Massachusetts v. KalshiEX LLC, No. 2584CV02525 (Mass. Super. Ct. Jan. 20, 2026) at 17. In doing so, the court relied in part on the presumption against preemption in an area of traditional state police power and suggested that state licensing requirements may coexist with the federal derivatives regime. Id. at 15.
19. Tribes have also brought their own challenges under the Indian Gaming Regulatory Act (IGRA), arguing that sports‑based event contracts amount to Class III gaming occurring on Indian lands without the compacts and regulatory safeguards the IGRA requires. See Michael McCann, Tribes Sue Kalshi, Alleging Illegal Sports Betting on Reservations, Sportico (July 28, 2025), https://www.sportico.com/law/analysis/2025/tribes-kalshi-lawsuit-igra-1234864478/. In California, tribes sought to enjoin Kalshi (and related partners) and force geofencing of tribal lands, but a federal court denied preliminary relief in November 2025. See Order Denying Plaintiffs’ Mot. for Prelim. Injunction, Dkt. 35, 25-cv-06162 at 2 (N.D. Cal., Nov. 10, 2025); see Jessica Welman, CA judge hands tribes first loss in sports contract legal battle, SBC Americas (Nov. 10, 2025), https://sbcamericas.com/2025/11/10/kalshi-tribal-injunction-denial/. Other tribes have also pursued similar IGRA‑based claims seeking injunctive relief. See Ganesh Setty, Wis. Tribe Seeks to Block Kalshi Sports Contracts, Law360 (Dec. 18, 2025), https://www.law360.com/articles/2423626/wis-tribe-seeks-to-block-kalshi-sports-contracts.
20. In 2025, several states sued Kalshi, Robinhood and other operators, asserting that sports-related event contracts constitute illegal gaming under state law. Jamie Wilde, State Regulators Bet on a Legal Difference Between Prediction Markets, Sports Gambling, yahoo! finance (Dec. 8, 2025), https://finance.yahoo.com/news/state-regulators-bet-legal-difference-050100300.html (Connecticut); Ayana Brown and Stephen Piepgrass, Nevada Judge Rules Prediction Market Firm Falls Under State Gaming Laws, JD Supra (Dec. 8, 2025), https://www.jdsupra.com/legalnews/nevada-judge-rules-prediction-market-4809441/ (Nevada); Contessa Brewer, Massachusetts sues Kalshi alleging illegal sports gambling, CNBC (Sept. 12, 2025), https://www.cnbc.com/2025/09/12/massachusetts-sues-kalshi-sports-gambling.html.
21. In December 2025, a Nevada federal court dissolved an injunction shielding Kalshi, holding that certain sports markets resemble sportsbook wagers and fall within state gaming jurisdiction. Brown & Piepgrass, supra note 20. But more recently, a California federal court denied a motion filed by California tribal entities under the IGRA seeking to prohibit Kalshi from operating on tribal lands. Alan Wilmot, California Denies Tribes’ Motion To Enjoin Kalshi In State, Legal Sports News (Nov. 11, 2025), https://www.legalsportsreport.com/246285/california-denies-tribes-motion-to-enjoin-kalshi-in-state/. The court reasoned that because event contracts offered on Kalshi are not bets or wagers under the Unlawful Internet Gambling Enforcement Act, there is no violation of the IGRA where contracts are received, made or transmitted on Indian lands where internet gaming is prohibited. Id.
22. For instance, in 2025, two federal courts reached different results when deciding whether the CEA preempts state gaming laws; a New Jersey federal court ruled in April that the CEA preempted state gaming laws, while a Maryland district court ruled in August that even though event contracts were “swaps” under the CEA, the CEA did not preempt state gaming laws. Daniel J. Davis, et al., Place Your Bets: US District Courts Are Split on Whether the Commodity Exchange Act Preempts State Gaming Laws with Respect to Sports Event Contracts, Nat’l L. Rev. (Aug. 15, 2025), https://natlawreview.com/article/place-your-bets-us-district-courts-are-split-whether-commodity-exchange-act.
23. See Remarks of Chairman Michael S. Selig at CFTC-SEC Event on Harmonization, supra note 5.
24. During his November 2025 Senate confirmation hearing, Chairman Selig stated that the CFTC would comply with judicial decisions regarding authority to regulate prediction markets. See Marcus DeNitto, Mike Selig: CFTC Will Lean on Courts To Determine If Sports Event Contracts Are Gambling, DeFi Rate (Nov. 19, 2025), https://defirate.com/news/mike-selig-cftc-sports-event-contracts-gambling/.
25. See KalshiEx, LLC v. Flaherty, No. 25-1922 (3d Cir., 2025); KalshiEx, LLC v. Hendrick, No. 25-7516 (9th Cir., 2025); KalshiEx, LLC v. Martin, No. 25-1892 (4th Cir., 2025) (Fourth Circuit).
26. Appellant’s Br., KalshiEx, LLC v. Hendrick, No. 25-7516, Dkt. 20, at 37 (9th Cir., 2025).
27. See Remarks of Chairman Michael S. Selig at CFTC-SEC Event on Harmonization, supra note 5.
28. Id. (“Where jurisdictional questions are at issue, the commission has the expertise and responsibility to defend its exclusive jurisdiction over commodity derivatives.”); see Dan Bernstein, The CFTC Isn’t Deferring on Prediction Markets Anymore, Sportico (Jan. 29, 2026), https://www.sportico.com/business/sports-betting/2026/cftc-prediction-markets-michael-selig-kalshi-1234882936/ (“Michael Selig, chairman of the Commodity Futures Trading Commission (CFTC), spoke in favor of sports prediction markets falling under his agency’s jurisdiction rather than states on Thursday.”).
29. As of 2025, 38 states have legalized sports betting. Matthew Waters, Sports Betting States: Latest US Legislation & Bill Tracker, LegalSportsReport (Nov. 21, 2025), https://www.legalsportsreport.com/sports-betting-states/.
30. Press Release, US Attorney’s Office for the Eastern District of New York, Current and Former National Basketball Association Players and Four Other Individuals Charged in Widespread Sports Betting and Money Laundering Conspiracy (Oct. 23, 2025), https://www.justice.gov/usao-edny/pr/current-and-former-national-basketball-association-players-and-four-other-individuals.
31. Mike Vorkunov, Jontay Porter pleads guilty to conspiracy to commit wire fraud, likely faces prison sentence, N.Y. Times: The Athletic (Jan. 13, 2025), https://www.nytimes.com/athletic/5629647/2024/07/10/jontay-porter-pleads-guilty-betting-scandal/; Logan Reardon, Who has been busted for sports gambling? Here’s a list of the major betting scandals, NBC N.Y. (Nov. 10, 2025), https://www.nbcnewyork.com/news/sports/list-players-coaches-sports-betting-gambling-allegations/6408736/.
32. Aaron Katersky, Cleveland Guardians pitcher Luis Ortiz pleads not guilty in connection to MLB sports betting scandal, ABC News (Nov. 12, 2025), https://abcnews.go.com/Sports/cleveland-guardians-pitcher-luis-ortiz-pleads-not-guilty/story?id=127448876. Yet these are just some of the many sports betting–related scandals of this year. Reardon, supra note 31.
33. Id.
34. Press Release, US S. Comm. on Commerce, Science, and Transportation, Senate Commerce Committee Probes Gambling in Major Leagues Baseball (Nov. 17, 2025), https://www.commerce.senate.gov/2025/11/senate-commerce-committee-probes-gambling-in-major-league-baseball; Ben Horney, Congress Turns Up Heat on Sports Leagues Over Betting Integrity Issues, Front Office Sports (Nov. 18, 2025, 10:54 AM), https://frontofficesports.com/congress-turns-up-heat-on-sports-leagues-over-betting-integrity-issues/; Letter, from US S. Comm. on Commerce, Science, and Transportation to Robert D. Manfred Commission of Baseball at 3–4 (Nov. 14, 2025), https://www.commerce.senate.gov/services/files/302C8B04-E5AD-4D7F-BFF7-7D776DEB4D35.
35. Press Release, US H. Comm. on Energy and Commerce, Bipartisan E&C Leaders Request Briefing From NBA Commissioner Adam Silver Following Allegations of Sports Fixing and Illegal Gambling (Oct. 24, 2025), https://democrats-energycommerce.house.gov/media/press-releases/bipartisan-ec-leaders-request-briefing-nba-commissioner-adam-silver-following.
36. Press Release, Chairmen Brett Guthrie, US H. Comm. on Energy and Commerce, Chairmen Guthrie, Joyce, and Bilirakis Send Letter to NCAA Over Decision to Let Students Athletes Gamble on Professional Sports (Oct. 31, 2025), https://energycommerce.house.gov/posts/chairmen-guthrie-joyce-and-bilirakis-send-letter-to-ncaa-over-decision-to-let-student-athletes-gamble-on-professional-sports; Letter, from US H. Comm. on Energy and Commerce to Charlie Baker, Nat’l Collegiate Athletic Ass’n (Oct. 30, 2025), https://d1dth6e84htgma.cloudfront.net/10_30_2025_Letter_to_NCAA_on_Sports_Betting_final_a72fd0caac.pdf.
37. MLB, for instance, entered into an agreement with sportsbooks to place a $200 cap on prop bets tied to its games in response to the Clase and Ortiz indictments. See Anthony Castrovince, MLB, sportsbook partners announce limits on pitch-level wagers, MLB.com (Nov. 10, 2025), https://www.mlb.com/news/limits-on-pitch-level-markets-announced.
38. The NBA removed certain prop bets, like those associated with missed free throws and turnovers. See Robert O’Connell & Jared Diamond, Prop Bets Are Scandal Magnets for Sports Leagues. They’re Also Serious Moneymakers., Wall St. J. (Nov. 16, 2025, 8:00 AM), https://www.wsj.com/sports/prop-bets-gambling-scandal-4f52a654?.
39. The NFL sent a memo to teams outlining prohibited wager categories and noting that it intends to work with sportsbooks, state lawmakers and regulators to curb illicit prop betting. Id.
40. See Blake Silverman, NBA Pushes for Major Changes to Prop Bets in Wake of Gambling Scandal, Sports Illustrated (Dec. 19, 2025), https://www.si.com/nba/nba-pushes-major-changes-prop-bets-wake-gambling-scandal (“The NBA is . . . pushing gaming companies to make changes to offered prop bets surrounding individual players, such as limiting maximum amounts that can be bet, limits on ‘under’ prop bets, limiting the population of players and eliminating problematic bet types, like bets on an action in a single play.”).
41. See, e.g., Jessica Welman, NJ lawmakers hear both sides on the issue of banning in-game prop bets, SBC Americas (Dec. 15, 2025), https://sbcamericas.com/2025/12/15/new-jersey-in-game-prop-hearing/ (New Jersey); Tom Nightingale, New York legislator takes swing at banning in-play betting, SBC Americas (Jan. 2, 2026), https://sbcamericas.com/2026/01/02/new-york-in-play-betting-bill-ban/ (reporting that New York Assemblymember Linda Rosenthal introduced legislation to ban prop betting “after the controversies of 2025” and noting that “[l]awmakers in other states[,] such as Maryland[,] have also recently floated the idea of looking to curb prop wagering to some extent, citing concerns over betting manipulation and sporting integrity”).
42. See Leagues work to tighten prop bet limits amid integrity concerns, Sports Bus. J. (Nov. 18, 2025), https://www.sportsbusinessjournal.com/Articles/2025/11/18/leagues-work-to-tighten-prop-bet-limits-amid-integrity-concerns/. “The prop bet is not just a ‘piece of the economy of legal sports betting.’ It has ‘become the backbone of the most popular, and profitable, wagers—the single most efficient means of turning a sports fan into a profit engine for betting companies.” Id.; O’Connell & Diamond, supra note 38.
43. For instance, sportsbooks originally caught the unusual betting activity that led to the discovery of Porter and Rozier’s allegedly illicit activity. About us – Who we are, sportradar (last visited Dec. 11, 2025), https://sportradar.com/about/; Thomas B. Shepherd III & Jones Walker, Legal Sportsbooks – The Unexpected Watchdogs of Integrity in Professional Sports, Nat. L. Rev. (Oct. 24, 2025), https://natlawreview.com/article/legal-sportsbooks-unexpected-watchdogs-integrity-professional-sports.
44. Shepherd III & Walker, supra note 43.
45. Id.
46. Justin Leventhal, The Economic Standard: California’s Losing Bet on Fantasy Sports, Am. Consumer Inst. (July 15, 2025), https://www.theamericanconsumer.org/2025/07/the-economic-standard-californias-losing-bet-on-fantasy-sports.
47. “States collected more than $1.8 billion in tax revenue from sports betting taxes in fiscal year 2023.” Adam Hoffer, Bets on Legal Sports Markets Pay Off Big for States, Sportsbooks, and Consumers, Tax Found. (Dec. 10, 2024), https://taxfoundation.org/research/all/state/sports-betting-tax-revenue/. Moreover, “[d]irect sponsorship deals between various legal sports books and the top American sports leagues are worth billions of dollars spread over several years and likely more than $1 billion annually[.] … [B]etting drives more overall revenue for sports, thus further lifting broadcast and streaming rights deals into the tens of billions.” Chris Isidore, Do recent sports gambling scandals mean the end of leagues’ deals with sportsbook apps? It’s a longshot, CNN Bus. (Oct. 25, 2025), https://www.cnn.com/2025/10/25/business/this-is-how-sports-gaming-has-become-crucial-to-leagues-bottom-lines.
48. Antonio Pequeño IV, NBA Approves $10 Billion Lakers Sale to Dodgers Owner Mark Walter, Forbes (Oct. 30, 2025), https://www.forbes.com/sites/antoniopequenoiv/2025/10/30/nba-approves-10-billion-lakers-sale-to-dodgers-owner-mark-walter/.
49. NBA Approves Sale of Boston Celtics at Record Valuation, Assoc. Press (Aug. 13, 2025), https://www.nba.com/news/nba-approves-sale-of-boston-celtics.
50. Minh Connors, Owning the Game: Private Equity Is Buying into Warriors, Giants. What Happens Next? S.F. Chronicle (Aug. 29, 2025), https://www.sfchronicle.com/sports/giants/article/warriors-giants-private-equity-20895229.php.
51. Kurt Badenhausen, NFL’s New England Patriots Selling 8% Stake at $9 Billion Valuation, Sportico (Sept. 25, 2025), https://www.sportico.com/business/team-sales/2025/new-england-patriots-stake-sale-sixth-street-1234872048/#:~:text=The New England Patriots have,while Metropoulos will own 5%.
52. Ben Horney, Giants Sell Minority Stake to Kochs at Reported $10B Valuation, Front Office Sports (Sept. 4, 2025), https://frontofficesports.com/giants-sell-minority-stake-to-kochs-at-reported-10b-valuation/.
53. Aaron Mulvihill & Grant Papa, What Is Behind the Growth of Private Equity in Sports?, J.P. Morgan Asset Mgmt. (Oct. 15, 2025), https://am.jpmorgan.com/us/en/asset-management/adv/insights/market-insights/market-updates/on-the-minds-of-investors/what-is-behind-the-growth-of-private-equity-in-sports/.
54. See, e.g., Ty Roush, Connecticut Sun Sold for Record $325 Million—As WNBA Team May Move to Boston, Forbes (Aug. 2, 2025), https://www.forbes.com/sites/tylerroush/2025/08/02/connecticut-sun-sold-for-record-325-million-as-wnba-team-may-move-to-boston/.
55. Stewart Mandel & Ralph D. Russo, UC Investments Puts $2.4 Billion Big Ten Deal on Hold Amid Pushback from Michigan and USC, N.Y. Times (Nov. 19, 2025), https://www.nytimes.com/athletic/6815788/2025/11/17/uc-investments-puts-2-4-billion-big-ten-deal-on-hold-amid-pushback-from-michigan-and-usc/.
56. The entity will be co-owned by the university and Otro Capital, with the university retaining majority ownership and decision-making authority over key matters such as scheduling, coaching, and other pertinent factors, like the amount of NIL payments to players. Otro Capital will receive a percentage of the for-profit entity’s annual revenue. The agreement also includes an exit strategy within five to seven years, and the university holds the right to purchase Otro Capital’s ownership stake. Carter Bahns, Utah to Enter Landmark Private Equity Agreement Raising $500 Million, CBS Sports (Dec. 9, 2025), https://www.cbssports.com/college-football/news/utah-college-athetics-football-basketball-private-equity/. Stewart Mandel, Justin Williams, & Matt Baker, The Risks and Rewards of Utah’s Private Equity Plans: Will Others Around College Sports Follow?, N.Y. Times (Dec. 9, 2025), https://www.nytimes.com/athletic/6876083/2025/12/09/utah-private-equity-deal/.
57. USC Athletic Director Jen Cohen noted, “Our fiduciary obligation to [USC] demands we thoroughly evaluate any deals that could impact our long-term value and flexibility, no matter the short-term benefit.” Ben Portnoy, Why Contention Around Big Ten’s Private Capital Play Centers on the League’s Grant of Rights, Sports Bus. J. (Dec. 2, 2025), https://www.sportsbusinessjournal.com/Articles/2025/11/21/why-contention-around-big-tens-private-capital-play-centers-on-the-leagues-grant-of-rights/. Similarly, the University of Michigan has taken a public stance against the proposed Big Ten private credit deal, citing material concerns over long-term value erosion and governance deficiencies. Id.
58. Mandel & Russo, supra note 55. While University of Utah administrators have stated that the school could veto any sponsorship opportunity that does not align with its values, it remains unclear how that process would work in practice. Id.
59. Notably, Phoenix Suns majority owner Matt Ishbia is currently facing litigation from minority investors alleging breaches of contract and fiduciary duty, which include claims of self-dealing through above-market loans and the undisclosed sale of stadium naming rights to his own company. Baxter Holmes, Minority Owners Claim Ishbia Mismanaging Suns in New Lawsuit, ESPN (Nov. 24, 2025), https://www.espn.com/nba/story/_/id/47088678/minority-owners-claim-ishbia-mismanaging-suns-new-lawsuit.
60. Nat. Collegiate Athletic Ass’n v. Alston, 594 U.S. 69 (2021), https://www.supremecourt.gov/opinions/20pdf/20-512_gfbh.pdf.
61. See WilmerHale’s “Sports and Gaming Law 2024 Year in Review: Top Five Developments” for additional information on this settlement. Andrew S. Dulberg, et al., Sports and Gaming Law 2024 Year in Review: Top Five Developments, WilmerHale (March 17, 2025), https://www.wilmerhale.com/en/insights/client-alerts/20250314-sports-and-gaming-law-2024-year-in-review-top-five-developments.
62. In re College Athlete NIL Litig., No. 20-cv-03919-CW (N.D. Cal. filed June 11, 2025), (Opinion Regarding Order Granting Motion for Final Approval of Settlement Agreement); Mark N. Mallery, et al., Antitrust Labor Markets: $2.8 Billion NCAA Settlement Reshapes College Athletics, Nat. L. Rev (June 20, 2025), https://natlawreview.com/article/antitrust-labor-markets-28-billion-ncaa-settlement-reshapes-college-athletics.
63. Notice of Appeal, In re College Athlete Litig., No. 4:20-cv-03919-CW (N.D. Cal. Dec. 11, 2025), ECF 1080; Notice of Appeal, In re College Athlete Litig., No. 4:20-cv-03919-CW (N.D. Cal. Dec. 13, 2025), ECF 1082.
64. Student Compensation and Opportunity through Rights and Endorsements Act, H.R. 4312, 119 Cong. (1st Sess. 2025), https://www.congress.gov/bill/119th-congress/house-bill/4312/text; Lilly Harris, et al., Coming Sooner or Later: Congress Considers Bills to Standardize Name, Image, and Likeness Rights, JD Supra (Oct. 28, 2025), https://www.jdsupra.com/legalnews/coming-sooner-or-later-congress-5829281/.
65. Press Release, Lori Trahan, Trahan Statement on Failed Attempt to Pass SCORE Act (Dec. 3, 2025), https://trahan.house.gov/news/documentsingle.aspx?DocumentID=3692.
66. Complaint, 231 Racing LLC v. Nat. Ass’n for Stock Car Auto Racing LLC, Dkt. 1, No. 3:24-cv-886 (W.D.N.C. 2024), https://www.courthousenews.com/wp-content/uploads/2024/10/nascar-monopoly-antitrust.pdf.
67. Bob Pockrass, What to Know About NASCAR Antitrust Lawsuit: Settlement Reached, Fox Sports (Dec. 11, 2025), https://www.foxsports.com/stories/nascar/what-know-about-nascar-antitrust-lawsuit; 231 Racing LLC v. Nat. Ass’n for Stock Car Auto Racing LLC, Dkt. 1, No. 3:24-cv-886, at ¶ 105 (W.D.N.C. 2024), https://www.courthousenews.com/wp-content/uploads/2024/10/nascar-monopoly-antitrust.pdf.
68. E.g., NASCAR settled federal antitrust case filed by 2 teams, ESPN (Dec. 11, 2025), https://www.espn.com/racing/nascar/story/_/id/47276734/nascar-settles-federal-antitrust-case-filed-2-teams; Nick Bromberg, Michael Jordan prevails in settlement of antitrust lawsuit against NASCAR, yahoo! sports (Dec. 11, 2025), https://sports.yahoo.com/nascar/breaking-news/article/michael-jordan-prevails-in-settlement-of-antitrust-lawsuit-against-nascar-151140835.html.
69. Following the settlement’s announcement, Jordan stated, “From the beginning, this lawsuit was about progress. … It was about making sure our sport evolves in a way that supports everyone: teams, drivers, partners, employees and fans. With a foundation to build equity and invest in the future and a stronger voice in the decisions ahead, we now have the chance to grow together and make the sport even better for generations to come.” Id.
70. The Professional Tennis Players Association initially named International Tennis Federation and International Tennis Integrity Agency in the suit, but both defendants were removed from the case in September 2025. See The PTPA and Tennis Players File Historic Legal Actions Against Governing Bodies Exposing Corrupt, Illegal, and Abusive System, PTPA (March 18, 2025), https://ptpaplayers.com/legal-actions-filed/.
71. Complaint, Pospisil v. ATP Tour, Dkt. 1, No. 1:25-cv-02207 (S.D.N.Y. 2025), https://ptpaplayers.com/wp-content/uploads/2025/03/Pospisil-et-al.-v.-ATP-Tour-Inc.-et-al.-Complaint.pdf. The Court stayed the proceedings against Tennis Australia in November, pending a settlement. Letter Brief, Pospisil v. ATP Tour, Dkt. 170, No. 1:25-cv-02207 (S.D.N.Y. 2025), file:///C:/Users/32916/OneDrive - WilmerHale/Desktop/Shopify/letter for PTPA settlement.pdf.
72. See Zakaria Anani, The Global Spread of US Sports, Glob. Inst. of Sport (Sept. 11, 2025), https://gis.sport/news/the-global-spread-of-us-sports/.
73. See Assoc. Press, NFL remains hot ticket internationally as league expands its global footprint, NFL (Nov. 11, 2025), https://www.nfl.com/news/nfl-remains-hot-ticket-internationally-as-league-expands-its-global-footprint.
74. Commissioner Goodell also stated noted the NFL wants to play in Asia and look at possible locations in Abu Dhabi, United Arab Emirates or Saudi Arabia. See id. Recently, the league announced a multiyear commitment to stage at least three regular‑season games in Rio de Janeiro beginning in 2026. See Assoc. Press, Brazil to host 3 NFL regular-season games over next 5 years, ESPN (Sept. 26, 2025), https://www.espn.com/nfl/story/_/id/46388787/brazil-host-3-nfl-regular-season-games-next-5-years.
75. See Assoc. Press, NFL remains hot ticket internationally as league expands its global footprint, NFL (Nov. 11, 2025), https://www.nfl.com/news/nfl-remains-hot-ticket-internationally-as-league-expands-its-global-footprint.
76. Brian Martin, NBA Abu Dhabi Games 2025: Everything to know, NBA (Oct. 1, 2025), https://www.nba.com/news/nba-abu-dhabi-games-2025-everything-to-know.
77. See Michael Johnson, NBA media deals tip off with innovation, nostalgia and global reach, S&P Glob. (Oct. 30, 2025), https://www.spglobal.com/market-intelligence/en/news-insights/research/2025/10/nba-media-deals-tip-off-with-innovation-nostalgia-and-global-reach.
78. See Mohammad Faisal, Adam Silver Announces Major Update on NBA’s European Expansion, Pro Football Network (Oct. 21, 2025), https://www.profootballnetwork.com/nba/adam-silver-major-update-nba-european-expansion/.
79. Jorge Avila Andrade, America’s pastime? The 2025 season began and will end outside the United States for the first time in MLB history, MARCA (Sept. 30, 2025), https://www.marca.com/en/mlb/world-series/2025/10/30/6902e4e7e2704e1b228b45c6.html.
80. Unlike in past years, when international games were merely exhibition matches, in 2025 the games played abroad were “season-defining events.” Id.
81. Id.
82. For example, in Japan, viewership increased by 42%, apparel and jersey sales increased by 183% year over year, and profit from sponsorships grew by 114%. Shlomo Sprung, How MLB’s Japan Investment Massively Paid Off in Tokyo, Boardroom TV (March 21, 2025), https://boardroom.tv/mlb-tokyo-series-2025-shohei-ohtani-fanatics/.
83. Id.
84. Danni Moore, Streamers will spend $12.5bn on sports rights in 2025, led by DAZN, Ampere Analysis (Feb. 18, 2025), https://www.ampereanalysis.com/insight/streamers-will-spend-125bn-on-sports-rights-in-2025-led-by-dazn.
85. Ed Dixon, US sports rights spending hits US $30.5bn in 2025, SportsPro (Aug. 27, 2025), https://www.sportspro.com/news/sports-broadcast-rights-spending-usa-uk-nfl-nba-ampere-analysis-august-2025/.
86. Sports Business Journal, NBA’s return to China aimed at reconnecting with ‘one of its most important markets,’ Sports Bus. J. (Oct. 10, 2025), https://www.sportsbusinessjournal.com/Articles/2025/10/10/nbas-return-to-china-aimed-at-reconnecting-with-one-of-its-most-important-markets/#:~:text=Matches are “broadcast in China,TIMES, 10/9.
87. See Moore, supra note 84.