Chris Christie Told State AGs to Send Cease-and-Desist Letters. His Own State Sent One and Got Enjoined.

Chris Christie stood up at Southern New Hampshire University on Tuesday and delivered the clearest sentence anyone has produced about prediction markets: "They say, 'Oh we are not a sports betting company, we are a commodity called the Rams minus 6 and a half.'"

That is the whole state case in one line. It took a former governor speaking without notes at a responsible-gambling summit to say it better than four dozen attorneys general have managed in eighteen months of filings.

Then he told the room what to do about it, and the advice fell apart.

The ask

Christie, keynoting the Granite State Summit on Responsible Gambling in Manchester, urged New Hampshire Attorney General John Formella and his counterparts in other states to issue cease-and-desist orders — to force prediction-market platforms either into licensure or out of business. "Here's the truth," he said. "These are betting companies operating in New Hampshire as we speak in an unlicensed way."

Here is the difficulty. New Jersey's Division of Gaming Enforcement did exactly that. Kalshi sued. The Third Circuit upheld an injunction barring New Jersey from enforcing its gambling laws against the exchange, and on September 2 New Jersey went to the Supreme Court asking it to say whether the 2010 Dodd-Frank Act preempted states from regulating sports bets placed inside their own borders when those bets clear on a CFTC-registered market.

Christie is recommending, in September 2026, the enforcement tool that his own state deployed, lost on, and has now escalated to the Supreme Court because it lost.

He is not unaware of this. He is a lawyer who spent six years in the litigation that ended at the same court. But the speech treated cease-and-desist letters as an unexhausted option, and they are the single most exhausted option in this fight. Connecticut has issued nine of them plus roughly 30 subpoenas. Missouri sent six. Arizona went further and referred criminally. The letters are not a plan that nobody has tried. They are the plan, and the score after eighteen months of it is one circuit for the states, one circuit for the exchange, and a cert petition.

What the letters have actually accomplished

They have worked — on everybody except the two companies that matter.

Underdog gave up licences. Robinhood switched off Michigan. Novig, ProphetX, Webull, Gemini and the crypto brokerages have been named, subpoenaed, or quietly narrowed. The smaller a platform's legal budget, the faster a state letter changes its behaviour.

Kalshi and Polymarket have balance sheets that turn a cease-and-desist into a filing fee. Kalshi's response to Montana was to litigate until both sides agreed on September 17 to dismiss and stand still while the federal appeals run. That is not compliance. That is a company with enough capital to treat state enforcement as a scheduling problem.

So the honest description of the AG campaign is that it is consolidating the market it is trying to suppress. Every mid-sized operator that folds hands its users to the two exchanges that will not. PitchBook's analyst put the commercial version of this bluntly this week: the window for new entrants has passed. Enforcement helped close it.

Christie's remedy, applied at scale, produces a duopoly of the most litigious survivors. That may still be better than the alternative, but it is not what "put them out of business" describes, and a former prosecutor should be asked about the difference.

The part of the speech that deserved the headline

The genuinely new thing Christie said had nothing to do with Kalshi.

"If I had to do it all over again," he said, "I would have gone further and not permitted sports betting on college athletics, period."

That is the architect of Christie v. NCAA saying the legalisation he won was under-designed. He described a 2011 law written for casino windows in Atlantic City, drafted before anybody modelled what happens when the window is in everyone's pocket: "It has gotten away from everybody in some respects, run away in a way none of us anticipated back in 2011."

He also told the room what Roger Goodell said to him when the NFL was trying to kill the law — "I don't want you to mess up like this; you should get rid of the law," and then "You aren't going to beat us" — and what he answered: "I am first and goal at the one, and you are asking me to punt."

The league that said that now sells official sportsbook partnerships. Christie now says he should have carved out college sports. Both men changed their minds in the direction of their interests, and only one of them said so out loud on a stage in Manchester.

Where the argument actually goes

If cease-and-desist letters cannot reach the two large exchanges, and the Supreme Court is the only body that can resolve the split, then the state-level action worth doing in the meantime is not more letters. It is the boring part: age verification, tax parity, and self-exclusion interoperability.

The age gap is the strongest ground the states have and it is barely being pressed. A licensed sportsbook takes 21-year-olds. Kalshi takes 18-year-olds. Missouri's letters named underage access directly. That is a consumer-protection claim, not a preemption claim, and preemption arguments are much harder to run against a state's power to keep 19-year-olds away from a product than against its power to ban the product outright.

Christie also raised the tax asymmetry — New York taxes licensed operators at rates up to 50 per cent — without following it to the obvious place. A state that cannot ban an exchange can still decline to let its own licensees be undercut by an untaxed competitor, and the legislature, not the attorney general, is where that gets fixed.

The best version of the other side

The serious objection to everything above is that we are scoring the campaign on the wrong clock.

Cease-and-desist letters are not primarily meant to stop Kalshi today. They are meant to build a record — a documented pattern of states asserting authority, being ignored, and preserving the issue — that makes certiorari more likely and a favourable ruling more likely once granted. On that measure the letters have been a success. New Jersey's petition is stronger because Connecticut, Missouri, Nevada, Arizona and dozens of others have been visibly refused. A court asked whether this is a live national conflict has a thick answer now precisely because attorneys general kept writing letters into the wind.

That is a real point and it changes the scoring. It does not change the recommendation. If the letters are litigation infrastructure rather than enforcement, then say that, because the difference matters to the New Hampshire residents in that room who heard a former governor suggest the state could shut these platforms off. New Hampshire cannot shut them off. It can build the record, protect 18-to-20-year-olds, and wait for the Supreme Court like everyone else.

Christie has never had trouble saying an unpopular thing plainly. This one was available to him and he took the easier line instead.

Editor's note: TrueEdge builds odds and line-shopping tools and earns affiliate commissions from licensed sportsbooks. We have a direct commercial interest in how prediction markets are regulated relative to licensed operators. This piece argues a position; weigh it accordingly.