Is Underdog Predict legal in Connecticut?

The source is a single release from the governor's office, dated September 10, 2026. It says the Department of Consumer Protection issued nine cease-and-desist orders that week and lists the recipients: Polymarket, Coinbase, Crypto.com, Robinhood, ProphetX, Novig, Webull, Gemini and, last, Underdog Predict. It describes all nine as "prediction markets known to be operating illegally in Connecticut." Those are the governor's office's words; no court has ruled on them as to Underdog.

The release states the order's reach in one sentence. All nine are "ordered to immediately cease and desist advertising, offering, promoting, or otherwise making available 'sports event contracts' or any other form of unlicensed online gambling to Connecticut residents." Sports contracts are named; the release does not say what else "any other form" covers.

What reasons does the release give?

It speaks about sports prediction markets as a group, not about Underdog. It says they operate "in violation of Connecticut gaming and unfair trade practices laws," that they are "known to offer and accept wagers" from people under 21 and people on the state's voluntary self-exclusion list, and that they offer wagers on Connecticut college sports, which state law prohibits. It names no conduct by Underdog in particular.

What penalty does the release mention?

"Failure to comply may result in additional action including, but not limited to, civil penalties under the Connecticut Unfair Trade Practices Act and/or criminal penalties for violations of Connecticut's gaming statutes." That is a warning, not a penalty. We found none imposed on any Underdog company.

Why can't we quote the order?

The department has not posted it. The release says "Copies of the cease-and-desist letters and subpoenas are available upon request to DCP" through its GovQA portal. Without the text we cannot give the order's exact date, its addressee or the statutes it cites. An agency order like this one is not a court judgment, and we found no court ruling that enforces it or sets it aside.

The same week, the release says, the department sent nearly 30 subpoenas: to nine gaming service licensees, 15 media organizations, and app stores and payment companies including the Apple App Store, Google Play and Stripe. It says the businesses subpoenaed are not under investigation.

The release uses a brand, Underdog Predict, not a company name, and we could not tell which company received the order. Underdog's Predict page, read on November 10, 2026, puts two businesses under that brand. One is UDM, LLC, doing business as Underdog Predict, "a CFTC-registered Futures Commission Merchant (FCM)." The other is Underdog's own exchange, which the page calls Aristotle Exchange DCM, Inc. and "UDX," "a CFTC regulated exchange." The page also says Underdog Sports Holdings, Inc. and its affiliates do business as "Underdog Predict" or "Underdog Exchange."

Underdog's Massachusetts complaint says the CFTC designated Aristotle Exchange DCM, Inc. on September 5, 2025, that Underdog bought it in March 2026, and that it became Underdog Exchange DCM, Inc. on August 31, 2026 (p.9, ¶28).

We found no court order or filing that limits withdrawals, deposits or open positions for Connecticut users of Underdog Predict. The release has one sentence on customer money, and it does not settle Underdog's case. Right after the list of nine, it says: "DCP also ordered all three platforms to allow Connecticut residents to withdraw any funds currently held by the platforms." It never says which three.

The same sentence appears in the attorney general's August 26, 2026 release, where it follows a description of December 2025 orders to "Kalshi and two other sites." The CFTC's complaint against Connecticut identifies the December 2, 2025 recipients as KalshiEx, Crypto.com and Robinhood Derivatives (¶60, p.18). Underdog is not among them. We could not determine whether the September order to Underdog Predict has a withdrawal term.

We could not read any court filing in a Connecticut case involving Underdog. The public docket index we rely on refused our reads, and neither Underdog's news page nor the attorney general's press releases, checked November 10, 2026, posts a complaint. So this page describes no Underdog lawsuit in Connecticut and no ruling in one.

Underdog's argument is on record in other states. In Massachusetts its exchange and its broker arm say that "Congress vested the U.S. Commodity Futures Trading Commission ('CFTC') with sole regulatory authority over event contracts and other derivatives traded on designated contract markets" (p.2, ¶2). That is Underdog's position in a case against another state, and we found no ruling on it there.

Underdog Predict's page says its contracts are offered by exchanges "including UDX, Kalshi, and Crypto.com | Derivatives North America." Connecticut had already ordered two of those exchanges, Kalshi and Crypto.com, to stop sports contracts in December 2025, and cases over those orders are pending.

The federal rulings. On August 10, 2026, a federal judge in Connecticut denied Coinbase a preliminary injunction against the state's officials, "largely in line with" the court's companion order in Kalshi's own case (ECF 93, p.1). On November 3, 2026 a Second Circuit panel denied injunctions pending appeal in Kalshi's Connecticut appeal, Coinbase's Connecticut appeal and Kalshi's New York appeal, because the appellants "failed to make the required showing." The appeals themselves are undecided. No Underdog company is a party to any of them.

The CFTC's suit. The United States and the CFTC sued Connecticut on April 2, 2026 (D. Conn. No. 3:26-cv-00498), saying they act "in response to Defendants' sending of cease and desist letters to various CFTC-regulated entities" (¶1). The complaint predates Underdog's exchange launch and names no Underdog company. The attorney general's August 26 release says the state has moved to dismiss; we have not read that motion.

Where each of those stands is in Kalshi in Connecticut and Crypto.com in Connecticut. Underdog's dealings with Massachusetts, Missouri and Tennessee are on the Underdog legal page.

We could not determine it. The Predict page names no states, and its disclaimer for Crypto.com contracts says a user "Must be 18+ and present in a state where Underdog Predict operates." A search of Underdog's legal center, read on November 10, 2026, found no mention of Connecticut. We found no Underdog notice saying it has stopped or kept offering sports contracts there since the order.

The release adds its own context: Connecticut licenses three platforms for sports wagering, DraftKings, FanDuel and Fanatics, and sets 21 as the minimum age to wager.

A consumer protection order about who may offer sports contracts in Connecticut decides nothing about federal income tax, and the IRS has not issued guidance on event contracts. The common ways people report them are set out in the prediction market tax guide, with the steps for a venue's trades in how to file Kalshi taxes.