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The company must also provide data to the firms making markets on those events.

“If we just sold the data to Kalshi in order to list the markets but no one was coming in and placing liquidity, there’s no point in them listing the markets,” Monk said. “We also need to supply the data to the market makers to inform their models.”

Catalist initially received a list of fewer than 10 potential market makers from Kalshi. It has since completed agreements with close to 20 and is engaging with approximately another 20.

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Regarding account takeovers, the guide emphasised technical mitigations such as two-factor authentication for withdrawals and changes to banking details.

For poker collusion and bot use, recommended contractual provisions allow operators to redistribute illegitimate winnings to affected players. The guide noted that courts have validated such actions when supported by robust data.

The ANJ has called for operators to provide proof rather than act on suspicion alone. The guide outlined the types of evidence and “converging indicators” (faisceaux d’indices) that French courts have accepted in previous litigations, including IP addresses, device logs and connection timings.

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