Underdog / Aristotle Exchange
Fantasy-sports operator that bought PredictIt's affiliated DCM and now runs its own exchange, clearinghouse and FCM.
Regulatory posture
- Owns a full regulated stack: the Aristotle Exchange DCM and DCO (CFTC-approved September 5, 2025) plus its own FCM registration through UDM LLC (NFA, January 13, 2026).
- Trades federally regulated event contracts on UDX, its own venue, rather than routing order flow to a third-party exchange.
- Surrendered daily-fantasy-sports licences in seven states rather than give up the exchange, then began suing state attorneys general on the same CEA-preemption theory Kalshi is litigating, from an initial five-state wave on September 8, 2026 to Connecticut a week later.
- IG Group agreed in July 2026 to acquire the company for up to roughly $1.3 billion, which would put a listed UK broker behind a US DCM and DCO.
Licensing
- DCM
- Approved (Aristotle Exchange DCM, Inc., September 5, 2025)
- FCM
- Approved (UDM LLC, NFA, January 13, 2026)
- State coverage
- Surrendered daily-fantasy-sports licences in Massachusetts, Maryland, Michigan, Mississippi, New Jersey, Pennsylvania and Ohio in September 2026 to keep the exchange business; preemption suits pending against Massachusetts, New Mexico, Ohio, Washington, Wisconsin and Connecticut
Filings on the tracker (2)
Licensing Tracker- DCMAristotle Exchange DCM, Inc.ApprovedMar 9, 2026
- FCMUnderdog Predict (UDM LLC)ApprovedJan 13, 2026
Products
Development timeline
Dated developments compiled for this operator, newest first. Select an entry for the full detail.
- September 16, 2026
Named in Missouri's six-operator cease-and-desist order
Missouri AG Catherine Hanaway ordered Underdog, alongside five other operators, to stop offering sports event contracts to Missouri residents within 30 days or obtain a license from the Missouri Gaming Commission, saying she expects a settlement effort before any lawsuit (enf-mo-ag-six).
- September 15, 2026
Sued Connecticut over its cease-and-desist order
Underdog Exchange DCM, Inc. sued Connecticut AG William Tong and DCP Commissioner Bryan Cafferelli, docketed September 15, 2026 (3:26-cv-01499, D. Conn.), seeking declaratory and injunctive relief that the CEA preempts the state's gambling laws as applied to its sports event contracts, responding to Connecticut's September 10 cease-and-desist order (enf-ct-dcp-nine).
- September 10, 2026
Named in Connecticut's nine-operator cease-and-desist order
Connecticut's Department of Consumer Protection ordered Underdog Predict, alongside eight other operators, to stop offering sports event contracts to Connecticut residents and to let existing customers withdraw funds, part of a nearly-30-subpoena escalation of the state's enforcement campaign (enf-ct-dcp-nine).
- September 8, 2026
Sued five state attorneys general the same day on a CEA-preemption theory
Underdog Exchange DCM, Inc., the CFTC-registered subsidiary formerly named Aristotle Exchange DCM, filed federal suits against the attorneys general of Massachusetts, New Mexico, Ohio, Washington and Wisconsin, docketed September 8, 2026, seeking declaratory judgments and injunctions that the Commodity Exchange Act preempts state gambling laws as applied to its CFTC-designated event contracts. The Ohio and Massachusetts filings follow directly from the daily-fantasy-sports surrender days earlier; the specific claims are not yet detailed in public reporting.
- September 5, 2026
Surrendered daily-fantasy-sports licences in seven states to protect the exchange business
Founder and CEO Jeremy Levine announced on September 5, 2026 that Underdog will shut its Drafts daily-fantasy-sports contests in Massachusetts, Maryland, Michigan, Mississippi, New Jersey, Pennsylvania and Ohio, surrendering the DFS licences around the NFL's September 9 kickoff, after each state took the position that it cannot offer DFS contests and CFTC-registered event contracts at once.
Show 6 earlier developmentsCollapse earlier developments
- July 30, 2026
IG Group agreed to acquire Underdog for up to about $1.3 billion
IG Group agreed to acquire Underdog, owner of the CFTC-registered Aristotle Exchange DCM and DCO, for up to roughly $1.3 billion (about $1.1 billion upfront, mostly IG shares plus about $380 million cash, plus a roughly $200 million earnout), days after Underdog's own exchange went live. Underdog was described as the third-largest US prediction-market venue by regulated volume, behind Kalshi and Robinhood.
- March 9, 2026
Underdog Fantasy announced the acquisition of the Aristotle Exchange DCM and DCO
- January 13, 2026
NFA granted FCM and swap-firm status to UDM LLC after a roughly nine-month review
- December 11, 2025
CFTC issued Aristotle one of four coordinated no-action letters on swap data reporting
The Division of Market Oversight issued coordinated no-action letters to Polymarket US, Aristotle, Gemini and LedgerX/MIAX, granting relief from certain swap data reporting and recordkeeping rules for fully collateralized binary option transactions; two of the letters also removed prior prohibitions on FCM intermediation.
- October 15, 2025
Aristotle Exchange opened for trading
- September 5, 2025
CFTC approved Aristotle Exchange as both a DCM and a DCO
Aristotle, affiliated with PredictIt's operator, received CFTC approval to operate as both a Designated Contract Market and a Derivatives Clearing Organization, offering a compliant successor venue to PredictIt's contested 2014 no-action letter.
Regulatory history
No enforcement actions matching this operator by name.
Recent activity
Sia Insights
Sia's analysis from broader market, trading, and industry-press signals. Not a primary regulatory source and not legal advice.
- Sep 14, 2026underdogaristotle-exchangehandleig-groupearnings
Founder and CEO Jeremy Levine told Bank of America's Gaming & Lodging Conference this week that Underdog's customer handle is climbing rapidly as its prediction-markets exchange scales, contrasting it with the company's old fantasy-only model, whose handle he put at roughly a quarter of a traditional sportsbook's. That tracks IG Group's own disclosure that prediction markets already made up 54% of Underdog's handle in the first half of 2026, up from 14% in 2025, with parlays now over half of exchange volume. It is a live read on the bet Underdog made in surrendering seven states' daily-fantasy licenses on September 5 to protect the exchange business (UDX): the trading dynamic Levine describes is the same one the company is now defending in court against five state attorneys general.
Scoring is illustrative and based on public information. SiaPredict does not provide legal advice.