Comment Text:
Dear Chair Behnam:
I am writing on behalf of the Workers Circle in response to the request for public comment on the proposal of KalshiEX, LLC’s proposal. As an organization deeply committed to protecting and strengthening democracy, we are focused on ensuring that voting rights are protected and that elections in our country are accessible to all eligible voters, fair, and free from interference. We believe that the Kalshi proposal poses a serious threat to the future of elections in the United States at all levels of government.
Founded in the United States by Eastern European immigrants in 1900, the Workers Circle is a social justice organization that powers progressive Jewish identity through Jewish cultural engagement, Yiddish language learning, and social justice activism. Our founders fled oppression in their home countries, seeking the freedom and promise afforded by a strong democracy. Today, more than 120 years later, our activists work to defend and strengthen our democracy.
We are compelled to comment on the Kalshi proposal because we believe that offering de facto betting contracts on the outcome of US elections via so-called “event contracts” would have troubling implications and would incentivize election interference, abuse, and misconduct. Regardless of the initial limited plan, if allowed, Kalshi and others would likely offer similar contracts on all kinds of elections from the local level up to the highest office of the Presidency, ushering in widespread election gambling nationwide. In order to maximize their winnings, gamblers may resort to tactics that not only would threaten election integrity but, given the current environment around elections, feed harmful suspicions about the process and outcomes of our elections.
Green-lighting this proposal would open the door to additional election interference. Widespread gambling on elections facilitated by the click of a button runs contrary to the purpose and function of our important election processes and undermine the very democratic value of elections. While we have said that democracy is not a spectator sport, we never contemplated that it could be reduced to a speculative spectator sport by allowing betting.
Especially today when there is an alarming reduction in confidence in elections, allowing gambling on the outcome would run contrary to the public interest and pose an existential threat to our democracy. As such, we strongly urge the CFTC to deny the proposal.
Thank you for the opportunity to comment on this dangerous and misguided proposal.
