How We Just Raised $6M At An $80M Valuation From 100+ Investors Using A Link (Without Pitching)
Lawtrades nearly failed three years ago.
We couldn't raise Series A or enthusiasm from VCs.
We raised $6M (at a $80M valuation) from 100 customers and investors using a link and no pitching.
Step-by-step:
We refocused our business first.
Lawtrades raised $3.7M while Atrium raised $75M. By comparison, we seemed unimportant.
We had to close the company or try something new.
As I've written previously, a pivot saved us. Our initial focus on SMBs attracted many unprofitable customers. SMBs needed one-off legal services, meaning low fees and high turnover.
Tech startups were different. Their General Councels (GCs) needed near-daily support, resulting in higher fees and lower churn than SMBs.
We stopped unprofitable customers and focused on power users. To avoid dilution, we borrowed against receivables. We scaled our revenue 10x, from $70k/mo to $700k/mo.
Then, we reconsidered fundraising (and do it differently)
This time was different. Lawtrades was cash flow positive for most of last year, so we could dictate our own terms. VCs were still wary of legaltech after Atrium's shutdown (though they were thinking about the space).
We neither wanted to rely on VCs nor dilute more than 10% equity. So we didn't compete for in-person pitch meetings.
AngelList Roll-Up Vehicle (RUV). Up to 250 accredited investors can invest in a single RUV. First, we emailed customers the RUV. Why? Because I wanted to help the platform's users.
Imagine if Uber or Airbnb let all drivers or Superhosts invest in an RUV. Humans make the platform, theirs and ours. Giving people a chance to invest increases their loyalty.
We expanded after initial interest.
We created a Journey link, containing everything that would normally go in an investor pitch:
- Slides
- Trailer (from me)
- Testimonials
- Product demo
- Financials
We could also link to our AngelList RUV and send the pitch to an unlimited number of people. Instead of 1:1, we had 1:10,000 pitches-to-investors.
We posted Journey's link in RUV Alliance Discord. 600 accredited investors noticed it immediately. Within days, we raised $250,000 from customers-turned-investors.
Stonks, which live-streamed our pitch to thousands of viewers, was interested in our grassroots enthusiasm. We got $1.4M from people I've never met.
These updates on Pump generated more interest. Facebook, Uber, Netflix, and Robinhood executives all wanted to invest. Sahil Lavingia, who had rejected us, gave us $100k.
We closed the round with public support.
Without a single pitch meeting, we'd raised $2.3M. It was a result of natural enthusiasm: taking care of the people who made us who we are, letting them move first, and leveraging their enthusiasm with VCs, who were interested.
We used network effects to raise $3.7M from a founder-turned-VC, bringing the total to $6M at a $80M valuation (which, by the way, I set myself).
What flipping the fundraising script allowed us to do:
We started with private investors instead of 2–3 VCs to show VCs what we were worth. This gave Lawtrades the ability to:
- Without meetings, share our vision. Many people saw our Journey link. I ended up taking meetings with people who planned to contribute $50k+, but still, the ratio of views-to-meetings was outrageously good for us.
- Leverage ourselves. Instead of us selling ourselves to VCs, they did. Some people with large checks or late arrivals were turned away.
- Maintain voting power. No board seats were lost.
- Utilize viral network effects. People-powered.
- Preemptively halt churn by turning our users into owners. People are more loyal and respectful to things they own. Our users make us who we are — no matter how good our tech is, we need human beings to use it. They deserve to be owners.
I don't blame founders for being hesitant about this approach. Pump and RUVs are new and scary. But it won’t be that way for long. Our approach redistributed some of the power that normally lies entirely with VCs, putting it into our hands and our network’s hands.
This is the future — another way power is shifting from centralized to decentralized.
More on Entrepreneurship/Creators
Hasan AboulHasan
3 years ago
High attachment products can help you earn money automatically.
Affiliate marketing is a popular online moneymaker. You promote others' products and get commissions. Affiliate marketing requires constant product promotion.
Affiliate marketing can be profitable even without much promotion. Yes, this is Autopilot Money.
How to Pick an Affiliate Program to Generate Income Autonomously
Autopilot moneymaking requires a recurring affiliate marketing program.
Finding the best product and testing it takes a lot of time and effort.
Here are three ways to choose the best service or product to promote:
Find a good attachment-rate product or service.
When choosing a product, ask if you can easily switch to another service. Attachment rate is how much people like a product.
Higher attachment rates mean better Autopilot products.
Consider promoting GetResponse. It's a 33% recurring commission email marketing tool. This means you get 33% of the customer's plan as long as he pays.
GetResponse has a high attachment rate because it's hard to leave and start over with another tool.
2. Pick a good or service with a lot of affiliate assets.
Check if a program has affiliate assets or creatives before joining.
Images and banners to promote the product in your business.
They save time; I look for promotional creatives. Creatives or affiliate assets are website banners or images. This reduces design time.
3. Select a service or item that consumers already adore.
New products are hard to sell. Choosing a trusted company's popular product or service is helpful.
As a beginner, let people buy a product they already love.
Online entrepreneurs and digital marketers love Systeme.io. It offers tools for creating pages, email marketing, funnels, and more. This product guarantees a high ROI.
Make the product known!
Affiliate marketers struggle to get traffic. Using affiliate marketing to make money is easier than you think if you have a solid marketing strategy.
Your plan should include:
1- Publish affiliate-related blog posts and SEO-optimize them
2- Sending new visitors product-related emails
3- Create a product resource page.
4-Review products
5-Make YouTube videos with links in the description.
6- Answering FAQs about your products and services on your blog and Quora.
7- Create an eCourse on how to use this product.
8- Adding Affiliate Banners to Your Website.
With these tips, you can promote your products and make money on autopilot.
Eve Arnold
3 years ago
Your Ideal Position As a Part-Time Creator
Inspired by someone I never met
Inspiration is good and bad.
Paul Jarvis inspires me. He's a web person and writer who created his own category by being himself.
Paul said no thank you when everyone else was developing, building, and assuming greater responsibilities. This isn't success. He rewrote the rules. Working for himself, expanding at his own speed, and doing what he loves were his definitions of success.
Play with a problem that you have
The biggest problem can be not recognizing a problem.
Acceptance without question is deception. When you don't push limits, you forget how. You start thinking everything must be as it is.
For example: working. Paul worked a 9-5 agency work with little autonomy. He questioned whether the 9-5 was a way to live, not the way.
Another option existed. So he chipped away at how to live in this new environment.
Don't simply jump
Internet writers tell people considering quitting 9-5 to just quit. To throw in the towel. To do what you like.
The advice is harmful, despite the good intentions. People think quitting is hard. Like courage is the issue. Like handing your boss a resignation letter.
Nope. The tough part comes after. It’s easy to jump. Landing is difficult.
The landing
Paul didn't quit. Intelligent individuals don't. Smart folks focus on landing. They imagine life after 9-5.
Paul had been a web developer for a long time, had solid clients, and was respected. Hence if he pushed the limits and discovered another route, he had the potential to execute.
Working on the side
Society loves polarization. It’s left or right. Either way. Or chaos. It's 9-5 or entrepreneurship.
But like Paul, you can stretch polarization's limits. In-between exists.
You can work a 9-5 and side jobs (as I do). A mix of your favorites. The 9-5's stability and creativity. Fire and routine.
Remember you can't have everything but anything. You can create and work part-time.
My hybrid lifestyle
Not selling books doesn't destroy my world. My globe keeps spinning if my new business fails or if people don't like my Tweets. Unhappy algorithm? Cool. I'm not bothered (okay maybe a little).
The mix gives me the best of both worlds. To create, hone my skill, and grasp big-business basics. I like routine, but I also appreciate spending 4 hours on Saturdays writing.
Some days I adore leaving work at 5 pm and disconnecting. Other days, I adore having a place to write if inspiration strikes during a run or a discussion.
I’m a part-time creator
I’m a part-time creator. No, I'm not trying to quit. I don't work 5 pm - 2 am on the side. No, I'm not at $10,000 MRR.
I work part-time but enjoy my 9-5. My 9-5 has goodies. My side job as well.
It combines both to meet my lifestyle. I'm satisfied.
Join the Part-time Creators Club for free here. I’ll send you tips to enhance your creative game.
Jenn Leach
3 years ago
How Much I Got Paid by YouTube for a 68 Million Views Video
My nameless, faceless channel case study
The Numbers
I anonymize this YouTube channel.
It's in a trendy, crowded niche. Sharing it publicly will likely enhance competition.
I'll still share my dashboard numbers:
A year ago, the video was released.
What I earned
I'll stop stalling. Here's a screenshot of my YouTube statistics page displaying Adsense profits.
YouTube Adsense made me ZERO dollars.
OMG!
How is this possible?
YouTube Adsense can't monetize my niche. This is typical in faceless niches like TikTok's rain videos. If they were started a while ago, I'm sure certain rain accounts are monetized, but not today.
I actually started a soothing sounds faceless YouTube channel. This was another account of mine.
I looped Pexels films for hours. No background music, just wind, rain, etc.
People could watch these videos to relax or get ready for bed. They're ideal for background noise and relaxation.
They're long-lasting, too. It's easy to make a lot from YouTube Adsense if you insert ads.
Anyway, I tried to monetize it and couldn’t. This was about a year ago. That’s why I doubt new accounts in this genre would be able to get approved for ads.
Back to my faceless channel with 68 million views.
I received nothing from YouTube Adsense, but I made money elsewhere.
Getting paid by the gods of affiliate marketing
Place links in the video and other videos on the channel to get money. Visitors that buy through your affiliate link earn you a commission.
This video earned many clicks on my affiliate links.
I linked to a couple of Amazon products, a YouTube creator tool, my kofi link, and my subscribe link.
Sponsorships
Brands pay you to include ads in your videos.
This video led to many sponsorships.
I've done dozens of sponsorship campaigns that paid $40 to $50 for an end screen to $450 for a preroll ad.
Last word
Overall, I made less than $3,000.
If I had time, I'd be more proactive with sponsorships. You can pitch brand sponsorships. This actually works.
I'd do that if I could rewind time.
I still can, but I think the reaction rate would be higher closer to the viral video's premiere date.
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Peter Steven Ho
3 years ago
Thank You for 21 Fantastic Years, iPod
Apple's latest revelation may shock iPod fans and former owners.
Apple discontinued the iPod touch on May 11, 2022. After 21 years, Apple killed the last surviving iPod, a device Steve Jobs believed would revolutionize the music industry.
Jobs was used to making bold predictions, but few expected Apple's digital music player to change the music industry. It did.
This chaos created new business opportunities. Spotify, YouTube, and Amazon are products of that chaotic era.
As the digital landscape changes, so do consumers, and the iPod has lost favor. I'm sure Apple realizes the importance of removing an icon. The iPod was Apple like the Mac and iPhone. I think it's bold to retire such a key Apple cornerstone. What would Jobs do?
iPod evolution across the ages
Here's an iPod family tree for all you enthusiasts.
iPod vintage (Oct 2001 to Sep 2014, 6 generations)
The original iPod had six significant upgrades since 2001. Apple announced an 80 GB ($249) and 160 GB ($349) iPod classic in 2007.
Apple updated the 80 GB model with a 120 GB device in September 2008. Apple upgraded the 120 GB model with a 160 GB variant a year later (2009). This was the last iteration, and Apple discontinued the classic in September 2014.
iPod nano (Jan 2004 to Sep 2005, 2 generations)
Apple debuted a smaller, brightly-colored iPod in 2004. The first model featured 4 GB, enough for 1,000 songs.
Apple produced a new 4 GB or 6 GB iPod mini in February 2005 and discontinued it in September when they released a better-looking iPod nano.
iTouch nano (Sep 2005 to July 2017, 7 generations)
I loved the iPod nano. It was tiny and elegant with enough tech to please most music aficionados, unless you carry around your complete music collection.
Apple owed much of the iPod nano's small form and success to solid-state flash memory. Flash memory doesn't need power because it has no moving parts. This makes the iPod nano more durable than the iPod classic and mini, which employ hard drives.
Apple manufactured seven generations of the iPod nano, improving its design, display screen, memory, battery, and software, but abandoned it in July 2017 due to dwindling demand.
Shuffle iPod (Jan 2005 to Jul 2017, 4 generations)
The iPod shuffle was entry-level. It was a simple, lightweight, tiny music player. The iPod shuffle was perfect for lengthy bike trips, runs, and hikes.
Apple sold 10 million iPod shuffles in the first year and kept making them for 12 years, through four significant modifications.
iOS device (Sep 2007 to May 2022, 7 generations)
The iPod touch's bigger touchscreen interface made it a curious addition to the iPod family. The iPod touch resembled an iPhone more than the other iPods, making them hard to tell apart.
Many were dissatisfied that Apple removed functionality from the iPod touch to avoid making it too similar to the iPhone. Seven design improvements over 15 years brought the iPod touch closer to the iPhone, but not completely.
The iPod touch uses the same iOS operating system as the iPhone, giving it access to many apps, including handheld games.
The iPod touch's long production run is due to the next generation of music-loving gamers.
What made the iPod cool
iPod revolutionized music listening. It was the first device to store and play MP3 music, allowing you to carry over 1,000 songs anywhere.
The iPod changed consumer electronics with its scroll wheel and touchscreen. Jobs valued form and function equally. He showed people that a product must look good to inspire an emotional response and ignite passion.
The elegant, tiny iPod was a tremendous sensation when it arrived for $399 in October 2001. Even at this price, it became a must-have for teens to CEOs.
It's hard to identify any technology that changed how music was downloaded and played like the iPod. Apple iPod and iTunes had 63% of the paid music download market in the fourth quarter of 2012.
The demise of the iPod was inevitable
Apple discontinuing the iPod touch after 21 years is sad. This ends a 00s music icon.
Jobs was a genius at anticipating market needs and opportunities, and Apple launched the iPod at the correct time.
Few consumer electronics items have had such a lasting impact on music lovers and the music industry as the iPod.
Smartphones and social media have contributed to the iPod's decline. Instead of moving to the music, the new generation of consumers is focused on social media. They're no longer passive content consumers; they're active content creators seeking likes and followers. Here, the smartphone has replaced the iPod.
It's hard not to feel a feeling of loss, another part of my adolescence now forgotten by the following generation.
So, if you’re lucky enough to have a working iPod, hang on to that relic and enjoy the music and the nostalgia.
Tim Denning
3 years ago
I Posted Six Times a Day for 210 Days on Twitter. Here's What Happened.
I'd spend hours composing articles only to find out they were useless. Twitter solved the problem.
Twitter is wrinkled, say critics.
Nope. Writing is different. It won't make sense until you write there.
Twitter is resurgent. People are reading again. 15-second TikToks overloaded our senses.
After nuking my 20,000-follower Twitter account and starting again, I wrote every day for 210 days.
I'll explain.
I came across the strange world of microblogging.
Traditional web writing is filler-heavy.
On Twitter, you must be brief. I played Wordle.
Twitter Threads are the most popular writing format. Like a blog post. It reminds me of the famous broetry posts on LinkedIn a few years ago.
Threads combine tweets into an article.
Sharp, concise sentences
No regard for grammar
As important as the information is how the text looks.
Twitter Threads are like Michael Angelo's David monument. He chipped away at an enormous piece of marble until a man with a big willy appeared.
That's Twitter Threads.
I tried to remove unnecessary layers from several of my Wordpress blog posts. Then I realized something.
Tweeting from scratch is easier and more entertaining. It's quicker and makes you think more concisely.
Superpower: saying much with little words. My long-form writing has improved. My article sentences resemble tweets.
You never know what will happen.
Twitter's subcultures are odd. Best-performing tweets are strange.
Unusual trend: working alone and without telling anyone. It's a rebellion against Instagram influencers who share their every moment.
Early on, random thoughts worked:
My friend’s wife is Ukrainian. Her family are trapped in the warzone. He is devastated. And here I was complaining about my broken garage door. War puts everything in perspective. Today is a day to be grateful for peace.
Documenting what's happening triggers writing. It's not about viral tweets. Helping others matters.
There are numerous anonymous users.
Twitter uses pseudonyms.
You don't matter. On sites like LinkedIn, you must use your real name. Welcome to the Cyberpunk metaverse of Twitter :)
One daily piece of writing is a powerful habit.
Habits build creator careers. Read that again.
Twitter is an easy habit to pick up. If you can't tweet in one sentence, something's wrong. Easy-peasy-japanese.
Not what I tweeted, but my constancy, made the difference.
Daily writing is challenging, especially if your supervisor is on your back. Twitter encourages writing.
Tweets evolved as the foundation of all other material.
During my experiment, I enjoyed Twitter's speed.
Tweets get immediate responses, comments, and feedback. My popular tweets become newspaper headlines. I've also written essays from tweet discussions.
Sometimes the tweet and article were clear. Twitter sometimes helped me overcome writer's block.
I used to spend hours composing big things that had little real-world use.
Twitter helped me. No guessing. Data guides my coverage and validates concepts.
Test ideas on Twitter.
It took some time for my email list to grow.
Subscribers are a writer's lifeblood.
Without them, you're broke and homeless when Mark Zuckerberg tweaks the algorithms for ad dollars. Twitter has three ways to obtain email subscribers:
1. Add a link to your bio.
Twitter allows bio links (LinkedIn now does too). My eBook's landing page is linked. I collect emails there.
2. Start an online newsletter.
Twitter bought newsletter app Revue. They promote what they own.
I just established up a Revue email newsletter. I imported them weekly into my ConvertKit email list.
3. Create Twitter threads and include a link to your email list in the final tweet.
Write Twitter Threads and link the last tweet to your email list (example below).
Initial email subscribers were modest.
Numbers are growing. Twitter provides 25% of my new email subscribers. Some days, 50 people join.
Without them, my writing career is over. I'd be back at a 9-5 job begging for time off to spend with my newborn daughter. Nope.
Collect email addresses or die trying.
As insurance against unsubscribes and Zucks, use a second email list or Discord community.
What I still need to do
Twitter's fun. I'm wiser. I need to enable auto-replies and auto-DMs (direct messages).
This adds another way to attract subscribers. I schedule tweets with Tweet Hunter.
It’s best to go slow. People assume you're an internet marketer if you spam them with click requests.
A human internet marketer is preferable to a robot. My opinion.
210 days on Twitter taught me that. I plan to use the platform until I'm a grandfather unless Elon ruins it.
Liam Vaughan
3 years ago
Investors can bet big on almost anything on a new prediction market.
Kalshi allows five-figure bets on the Grammys, the next Covid wave, and future SEC commissioners. Worst-case scenario
On Election Day 2020, two young entrepreneurs received a call from the CFTC chairman. Luana Lopes Lara and Tarek Mansour spent 18 months trying to start a new type of financial exchange. Instead of betting on stock prices or commodity futures, people could trade instruments tied to real-world events, such as legislation, the weather, or the Oscar winner.
Heath Tarbert, a Trump appointee, shouted "Congratulations." "You're competing with 1840s-era markets. I'm sure you'll become a powerhouse too."
Companies had tried to introduce similar event markets in the US for years, but Tarbert's agency, the CFTC, said no, arguing they were gambling and prone to cheating. Now the agency has reversed course, approving two 24-year-olds who will have first-mover advantage in what could become a huge new asset class. Kalshi Inc. raised $30 million from venture capitalists within weeks of Tarbert's call, his representative says. Mansour, 26, believes this will be bigger than crypto.
Anyone who's read The Wisdom of Crowds knows prediction markets' potential. Well-designed markets can help draw out knowledge from disparate groups, and research shows that when money is at stake, people make better predictions. Lopes Lara calls it a "bullshit tax." That's why Google, Microsoft, and even the US Department of Defense use prediction markets internally to guide decisions, and why university-linked political betting sites like PredictIt sometimes outperform polls.
Regulators feared Wall Street-scale trading would encourage investors to manipulate reality. If the stakes are high enough, traders could pressure congressional staffers to stall a bill or bet on whether Kanye West's new album will drop this week. When Lopes Lara and Mansour pitched the CFTC, senior regulators raised these issues. Politically appointed commissioners overruled their concerns, and one later joined Kalshi's board.
Will Kanye’s new album come out next week? Yes or no?
Kalshi's victory was due more to lobbying and legal wrangling than to Silicon Valley-style innovation. Lopes Lara and Mansour didn't invent anything; they changed a well-established concept's governance. The result could usher in a new era of market-based enlightenment or push Wall Street's destructive tendencies into the real world.
If Kalshi's founders lacked experience to bolster their CFTC application, they had comical youth success. Lopes Lara studied ballet at the Brazilian Bolshoi before coming to the US. Mansour won France's math Olympiad. They bonded over their work ethic in an MIT computer science class.
Lopes Lara had the idea for Kalshi while interning at a New York hedge fund. When the traders around her weren't working, she noticed they were betting on the news: Would Apple hit a trillion dollars? Kylie Jenner? "It was anything," she says.
Are mortgage rates going up? Yes or no?
Mansour saw the business potential when Lopes Lara suggested it. He interned at Goldman Sachs Group Inc., helping investors prepare for the UK leaving the EU. Goldman sold clients complex stock-and-derivative combinations. As he discussed it with Lopes Lara, they agreed that investors should hedge their risk by betting on Brexit itself rather than an imperfect proxy.
Lopes Lara and Mansour hypothesized how a marketplace might work. They settled on a "event contract," a binary-outcome instrument like "Will inflation hit 5% by the end of the month?" The contract would settle at $1 (if the event happened) or zero (if it didn't), but its price would fluctuate based on market sentiment. After a good debate, a politician's election odds may rise from 50 to 55. Kalshi would charge a commission on every trade and sell data to traders, political campaigns, businesses, and others.
In October 2018, five months after graduation, the pair flew to California to compete in a hackathon for wannabe tech founders organized by the Silicon Valley incubator Y Combinator. They built a website in a day and a night and presented it to entrepreneurs the next day. Their prototype barely worked, but they won a three-month mentorship program and $150,000. Michael Seibel, managing director of Y Combinator, said of their idea, "I had to take a chance!"
Will there be another moon landing by 2025?
Seibel's skepticism was rooted in America's historical wariness of gambling. Roulette, poker, and other online casino games are largely illegal, and sports betting was only legal in a few states until May 2018. Kalshi as a risk-hedging platform rather than a bookmaker seemed like a good idea, but convincing the CFTC wouldn't be easy. In 2012, the CFTC said trading on politics had no "economic purpose" and was "contrary to the public interest."
Lopes Lara and Mansour cold-called 60 Googled lawyers during their time at Y Combinator. Everyone advised quitting. Mansour recalls the pain. Jeff Bandman, a former CFTC official, helped them navigate the agency and its characters.
When they weren’t busy trying to recruit lawyers, Lopes Lara and Mansour were meeting early-stage investors. Alfred Lin of Sequoia Capital Operations LLC backed Airbnb, DoorDash, and Uber Technologies. Lin told the founders their idea could capitalize on retail trading and challenge how the financial world manages risk. "Come back with regulatory approval," he said.
In the US, even small bets on most events were once illegal. Under the Commodity Exchange Act, the CFTC can stop exchanges from listing contracts relating to "terrorism, assassination, war" and "gaming" if they are "contrary to the public interest," which was often the case.
Will subway ridership return to normal? Yes or no?
In 1988, as academic interest in the field grew, the agency allowed the University of Iowa to set up a prediction market for research purposes, as long as it didn't make a profit or advertise and limited bets to $500. PredictIt, the biggest and best-known political betting platform in the US, also got an exemption thanks to an association with Victoria University of Wellington in New Zealand. Today, it's a sprawling marketplace with its own subculture and lingo. PredictIt users call it "Rules Cuck Panther" when they lose on a technicality. Major news outlets cite PredictIt's odds on Discord and the Star Spangled Gamblers podcast.
CFTC limits PredictIt bets to $850. To keep traders happy, PredictIt will often run multiple variations of the same question, listing separate contracts for two dozen Democratic primary candidates, for example. A trader could have more than $10,000 riding on a single outcome. Some of the site's traders are current or former campaign staffers who can answer questions like "How many tweets will Donald Trump post from Nov. 20 to 27?" and "When will Anthony Scaramucci's role as White House communications director end?"
According to PredictIt co-founder John Phillips, politicians help explain the site's accuracy. "Prediction markets work well and are accurate because they attract people with superior information," he said in a 2016 podcast. “In the financial stock market, it’s called inside information.”
Will Build Back Better pass? Yes or no?
Trading on nonpublic information is illegal outside of academia, which presented a dilemma for Lopes Lara and Mansour. Kalshi's forecasts needed to be accurate. Kalshi must eliminate insider trading as a regulated entity. Lopes Lara and Mansour wanted to build a high-stakes PredictIt without the anarchy or blurred legal lines—a "New York Stock Exchange for Events." First, they had to convince regulators event trading was safe.
When Lopes Lara and Mansour approached the CFTC in the spring of 2019, some officials in the Division of Market Oversight were skeptical, according to interviews with people involved in the process. For all Kalshi's talk of revolutionizing finance, this was just a turbocharged version of something that had been rejected before.
The DMO couldn't see the big picture. The staff review was supposed to ensure Kalshi could complete a checklist, "23 Core Principles of a Designated Contract Market," which included keeping good records and having enough money. The five commissioners decide. With Trump as president, three of them were ideologically pro-market.
Lopes Lara, Mansour, and their lawyer Bandman, an ex-CFTC official, answered the DMO's questions while lobbying the commissioners on Zoom about the potential of event markets to mitigate risks and make better decisions. Before each meeting, they would write a script and memorize it word for word.
Will student debt be forgiven? Yes or no?
Several prediction markets that hadn't sought regulatory approval bolstered Kalshi's case. Polymarket let customers bet hundreds of thousands of dollars anonymously using cryptocurrencies, making it hard to track. Augur, which facilitates private wagers between parties using blockchain, couldn't regulate bets and hadn't stopped users from betting on assassinations. Kalshi, by comparison, argued it was doing everything right. (The CFTC fined Polymarket $1.4 million for operating an unlicensed exchange in January 2022. Polymarket says it's now compliant and excited to pioneer smart contract-based financial solutions with regulators.
Kalshi was approved unanimously despite some DMO members' concerns about event contracts' riskiness. "Once they check all the boxes, they're in," says a CFTC insider.
Three months after CFTC approval, Kalshi announced funding from Sequoia, Charles Schwab, and Henry Kravis. Sequoia's Lin, who joined the board, said Tarek, Luana, and team created a new way to invest and engage with the world.
The CFTC hadn't asked what markets the exchange planned to run since. After approval, Lopes Lara and Mansour had the momentum. Kalshi's March list of 30 proposed contracts caused chaos at the DMO. The division handles exchanges that create two or three new markets a year. Kalshi’s business model called for new ones practically every day.
Uncontroversial proposals included weather and GDP questions. Others, on the initial list and later, were concerning. DMO officials feared Covid-19 contracts amounted to gambling on human suffering, which is why war and terrorism markets are banned. (Similar logic doomed ex-admiral John Poindexter's Policy Analysis Market, a Bush-era plan to uncover intelligence by having security analysts bet on Middle East events.) Regulators didn't see how predicting the Grammy winners was different from betting on the Patriots to win the Super Bowl. Who, other than John Legend, would need to hedge the best R&B album winner?
Event contracts raised new questions for the DMO's product review team. Regulators could block gaming contracts that weren't in the public interest under the Commodity Exchange Act, but no one had defined gaming. It was unclear whether the CFTC had a right or an obligation to consider whether a contract was in the public interest. How was it to determine public interest? Another person familiar with the CFTC review says, "It was a mess." The agency didn't comment.
CFTC staff feared some event contracts could be cheated. Kalshi wanted to run a bee-endangerment market. The DMO pushed back, saying it saw two problems symptomatic of the asset class: traders could press government officials for information, and officials could delay adding the insects to the list to cash in.
The idea that traders might manipulate prediction markets wasn't paranoid. In 2013, academics David Rothschild and Rajiv Sethi found that an unidentified party lost $7 million buying Mitt Romney contracts on Intrade, a now-defunct, unlicensed Irish platform, in the runup to the 2012 election. The authors speculated that the trader, whom they dubbed the “Romney Whale,” may have been looking to boost morale and keep donations coming in.
Kalshi said manipulation and insider trading are risks for any market. It built a surveillance system and said it would hire a team to monitor it. "People trade on events all the time—they just use options and other instruments. This brings everything into the open, Mansour says. Kalshi didn't include election contracts, a red line for CFTC Democrats.
Lopes Lara and Mansour were ready to launch kalshi.com that summer, but the DMO blocked them. Product reviewers were frustrated by spending half their time on an exchange that represented a tiny portion of the derivatives market. Lopes Lara and Mansour pressed politically appointed commissioners during the impasse.
Tarbert, the chairman, had moved on, but Kalshi found a new supporter in Republican Brian Quintenz, a crypto-loving former hedge fund manager. He was unmoved by the DMO's concerns, arguing that speculation on Kalshi's proposed events was desirable and the agency had no legal standing to prevent it. He supported a failed bid to allow NFL futures earlier this year. Others on the commission were cautious but supportive. Given the law's ambiguity, they worried they'd be on shaky ground if Kalshi sued if they blocked a contract. Without a permanent chairman, the agency lacked leadership.
To block a contract, DMO staff needed a majority of commissioners' support, which they didn't have in all but a few cases. "We didn't have the votes," a reviewer says, paraphrasing Hamilton. By the second half of 2021, new contract requests were arriving almost daily at the DMO, and the demoralized and overrun division eventually accepted defeat and stopped fighting back. By the end of the year, three senior DMO officials had left the agency, making it easier for Kalshi to list its contracts unimpeded.
Today, Kalshi is growing. 32 employees work in a SoHo office with big windows and exposed brick. Quintenz, who left the CFTC 10 months after Kalshi was approved, is on its board. He joined because he was interested in the market's hedging and risk management opportunities.
Mid-May, the company's website had 75 markets, such as "Will Q4 GDP be negative?" Will NASA land on the moon by 2025? The exchange recently reached 2 million weekly contracts, a jump from where it started but still a small number compared to other futures exchanges. Early adopters are PredictIt and Polymarket fans. Bets on the site are currently capped at $25,000, but Kalshi hopes to increase that to $100,000 and beyond.
With the regulatory drawbridge down, Lopes Lara and Mansour must move quickly. Chicago's CME Group Inc. plans to offer index-linked event contracts. Kalshi will release a smartphone app to attract customers. After that, it hopes to partner with a big brokerage. Sequoia is a major investor in Robinhood Markets Inc. Robinhood users could have access to Kalshi so that after buying GameStop Corp. shares, they'd be prompted to bet on the Oscars or the next Fed commissioner.
Some, like Illinois Democrat Sean Casten, accuse Robinhood and its competitors of gamifying trading to encourage addiction, but Kalshi doesn't seem worried. Mansour says Kalshi's customers can't bet more than they've deposited, making debt difficult. Eventually, he may introduce leveraged bets.
Tension over event contracts recalls another CFTC episode. Brooksley Born proposed regulating the financial derivatives market in 1994. Alan Greenspan and others in the government opposed her, saying it would stifle innovation and push capital overseas. Unrestrained, derivatives grew into a trillion-dollar industry until 2008, when they sparked the financial crisis.
Today, with a midterm election looming, it seems reasonable to ask whether Kalshi plans to get involved. Elections have historically been the biggest draw in prediction markets, with 125 million shares traded on PredictIt for 2020. “We can’t discuss specifics,” Mansour says. “All I can say is, you know, we’re always working on expanding the universe of things that people can trade on.”
Any election contracts would need CFTC approval, which may be difficult with three Democratic commissioners. A Republican president would change the equation.