Is Underdog Predict legal in Missouri?

Attorney General Catherine L. Hanaway's office dated the letter September 17, 2026, headed it "Unlicensed Sport Wagering Operations in Missouri," and sent it through a registered agent in Wilmington, Delaware. The solicitor general signed it (p.3). Its first sentence calls Underdog "an online sports wagering platform" that, "according to its website," offers sports wagering to people located in Missouri "despite not submitting to regulation by the Missouri Gaming Commission" (p.1).

The legal hook is the 2024 vote. The letter quotes the state constitution's statement that the public interest is "best served by a well-regulated sports wagering industry" (Mo. Const. art. III, § 39(g)1) and says that since then, any online platform taking wagers from people in Missouri on professional, collegiate and other competitive events has needed a commission license, a requirement it calls "not optional." By offering sports wagering in Missouri without one, it concludes, Underdog "has been" and "continues to be" in violation of Missouri law (p.1). Each of these is the attorney general's reading.

A cease-and-desist letter is a demand, not a court order. We found nothing withdrawing it and no order enforcing it, and we could not determine whether Underdog has answered it.

The letter is addressed to "Underdog Sports Wagering, LLC" and defines that company as "Underdog" for the rest of the text (p.1). That is not the name Underdog Predict uses in court. In its federal complaints, UDM, LLC says it does business as Underdog Predict and is a futures commission merchant, and it sues alongside Underdog Exchange DCM, Inc., which it says operates a CFTC-regulated designated contract market (Massachusetts complaint, pp.7-8, ¶¶16-17). Neither of those two companies is named anywhere in Missouri's letter.

The letter's substance still points at event contracts: it says Missouri "is aware that Underdog claims it offers 'event contracts'" under the Commodity Exchange Act (p.2). We found no document saying how Underdog Sports Wagering, LLC relates to UDM, LLC or Underdog Exchange DCM, Inc., so this page does not treat them as one company.

This is the passage that sets Underdog's letter apart. It says Missouri bars sports wagering by anyone under 21 (11 C.S.R. § 45-20.360(1)(A)) and puts an "affirmative duty" on platforms to "actively prevent the placement of a wager by individuals under twenty-one (21) years of age" (§ 45-20.360(6)). It then says "Underdog's website reflects that it permits anyone in Missouri who is at least 18 years of age to place wagers," and that allowing wagers by people under 21 "will not be tolerated" (p.2).

That is the attorney general's description of Underdog's site. The page it cites in its only footnote, Underdog's state eligibility help article, returned an error when we tried to read it on October 31, 2026, so we could not check what age it states. The office's September 18 release says five of the six companies it wrote to, Underdog among them, "either permit underage users to access their products or lack adequate safeguards" against Missourians under 21.

The letter's second charge is unpaid taxes and fees. As it states the measure, Missouri "imposes a wagering tax of 10%" on "the adjusted gross revenue" from all in-state sports wagering (art. III, § 39(g)10.a), and online sports wagering platforms owe an initial license fee and a renewal fee every five years, "each of which could be as much as $500,000" (§ 39(g)6). The money, it says, goes to Missouri's schools and colleges and to a Compulsive Gaming Prevention Fund (§ 39(g)15) (p.2). The release describes the same levy as "a 10% tax on sports betting gross receipts."

The letter then applies it to Underdog: Underdog "has made money from sports wagers placed by individuals located in the State of Missouri," has "kept all of that money for itself," and until it pays "will not be permitted to offer the use of its online sports wagering platform in Missouri" (p.2). Those are the attorney general's claims. We found no Missouri Gaming Commission assessment against any Underdog company. The 10% is a levy on an operator's revenue; it does not reach what a person trading on Underdog makes.

The letter asks Underdog to confirm "within thirty days of the date of this letter" that it complies with Missouri law or has stopped sports wagering in the state (p.3). Thirty days from September 17 is October 17, 2026; the letter itself gives no calendar date. "Otherwise," it says, "the State of Missouri will take legal action against Underdog," though Missouri "remains open to possible legislative reforms in the future" (p.3).

As of October 31, 2026, a search of the attorney general's posts since September 1 for Underdog, prediction markets and wagering returns only the September 18 release, and the Missouri Gaming Commission's home page does not mention Underdog. We did not search Missouri's state courts or the federal dockets for this check, so we cannot say whether any Underdog company has sued Missouri or been sued there. We found no public reply from Underdog to the letter.

We found no document in which Underdog answers Missouri. Its argument is on record elsewhere: in the Massachusetts suit, Underdog Exchange DCM, Inc. and UDM, LLC say that through the Commodity Exchange Act "Congress vested the U.S. Commodity Futures Trading Commission ('CFTC') with sole regulatory authority over event contracts" traded on designated contract markets (p.2, ¶2), and that the CFTC has "exclusive jurisdiction" over that trading (p.2, ¶3). That is Underdog's argument in a case against another state; we have not read that docket past the complaint.

The Missouri letter answers it in advance. It says Missouri "shares the same view as the majority of federal courts" that the Commodity Exchange Act does not preempt state law here and that sports event contracts are not swaps (p.2). It lists eight decisions: seven in Kalshi cases and one involving North American Derivatives Exchange. No Underdog company is a party to any of them, and "majority" is the attorney general's word.

The September 18 release lists six recipients: "Polymarket, Kalshi, Crypto.com, Novig, Underdog, and Robinhood." It calls facilitating sports event contracts "unlicensed sports wagering under Missouri law" and says "Failure to comply will result in enforcement action by the State of Missouri." Those are the office's statements. Each of the other letters has its own page here: Kalshi in Missouri, Polymarket in Missouri, Robinhood in Missouri and Novig in Missouri.

Connecticut's governor announced on September 10, 2026 that the Department of Consumer Protection had issued cease-and-desist orders to nine prediction markets, and its list includes Underdog Predict. In Massachusetts, Underdog's two companies sued the attorney general and Gaming Commission officials on September 8, 2026, asking the court to bar them from enforcing state gambling laws against Underdog (D. Mass. No. 1:26-cv-14098, pp.41-42). In Tennessee, their complaint, dated October 13, 2026, says the Sports Wagering Council sent Underdog a cease-and-desist on October 9 (p.2, ¶4). Each state is on the Underdog legal page.

No: it is a demand about who may offer sports wagering in Missouri, and a state gaming position is not a ruling on federal income tax. How the people we've seen file report event contracts, with no IRS guidance on them, is in the prediction market tax guide and how to file Kalshi taxes.