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Yet Another Value Podcast · · 58 分钟

为什么 DraftKings 可能并非一场大赌局:Aganju 的 Tolu Bukola 谈 $DKNG

Andrew WalkerTolu Bukola

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TL;DR
  • Tolu Bukola 将 DraftKings($DKNG,股价约25美元,相比30多美元以及8月底45-50美元的水平大致腰斩)定义为未来2-3年翻倍的基准情景;Walker 表示,他认为这套观点在 SumZero 2026 年度股票评选中排名第3。 他的判断是:以数据为驱动的短线交易者看到预测市场成交量“不断上升”,却看到 DKNG 营收增速放缓,很多人并没有把视线放到2-3年后的终局经济模型。
  • 市场低估的资产是 iGaming:收入占比超过20%、增速20%-25%;按 Bukola 对成本的拆分假设,iGaming 现实中已经能贡献3亿-5亿美元 EBITDA,而体育博彩业务大致盈亏平衡。 iGaming 目前仅在覆盖11%人口的州合法,体育博彩的覆盖率则为60%;如果合法覆盖率达到50%,且 DraftKings 保持市场份额,“这会是一个50亿美元的业务”,其价值可能足以覆盖整个企业价值。
  • 对于预测市场威胁是否被夸大,Bukola 的核心证据是 Betfair:这家博彩交易所已在英国存在20多年,市场份额稳定在约5%。 卖方机构估计 Kalshi 占美国体育博彩市场10%,但其中包含了其在加州、得州及其他非法州接近100%的份额——“这实际上并不意味着它在正面竞争的市场中造成了多大影响”。
  • 他坦承,预测市场目前享有“巨大的不公平优势”:无需缴纳州博彩税(平均约20%,总额接近100亿美元)、18岁即可下注而非21岁、覆盖全国,且不用承担昂贵的赛事诚信和问题赌博合规成本。 Kalshi 的交易费约为7%,而体育博彩还要承担结构性价差和税负,包括伊利诺伊州新增的单笔投注费用。
  • 他最倚重的法律路径是:州层面的诉讼“基本注定会打到最高法院”——他此前认为会在2028年,现在则认为2027年也有可能;预测市场的法律主张“其荒谬程度几乎等同于违反美国100年的法律”。 CFTC 针对选举合约的案件认定选举不属于博彩,但同时默认其可以监管博彩合约,并以 Super Bowl 为例;而在委员会只剩1名委员、且这名委员是前加密货币律师的情况下,执法基本处于缺位状态。
  • 估值测算是:今年60亿美元营收按12%-15%复合增长,到2029年约为90亿美元;即便只按15%-20%的 EBITDA 利润率测算(低于投资者日给出的30%指引,也低于英国、澳大利亚的先例),EBITDA 仍有15亿-20亿美元,按15倍估值,即便采用15%的利润率情景,股价也能“进入40多美元”。 如果最高法院作出有利裁决,重估会更快——Walker 表示 DraftKings 会“一夜之间翻倍”。
  • 最诚实的看空情景是:如果预测市场继续不受监管并拿下约50%的市场份额,“我想不出任何一种情况下不会把这看成一场灾难”——交易所是依赖网络效应的业务,DraftKings 已经落后,也没有理由押注它能进入行业前3或前4。
  • Walker 指出了这套论点的非对称性:它依赖政府打击预测市场,却不打击掠夺性的20腿串关;Bukola 的解释是,两者背后的动机不同:“这是收入,对吧? 就是收入”,而不是道德恐慌;“既然这是美国,而我们连枪支在杀死幼儿园孩子时都拒绝监管”,他不认为监管会走向极端,包括打击串关。
摘要 · 为研究而整理的核心内容

1. 一只腰斩的股票、放缓的营收增速与一个生死攸关的论点

  • Bukola 的切入点是:DraftKings 是一家线上体育博彩运营商,2020年通过 SPAC 上市,此前多年一直被当作“超高增长”的圈地故事;但过去6个月股价已经“被彻底砸烂”——年初还在30多美元,如今约25美元,预测市场引发恐慌前的8月底一度交易在45-50美元。部分下跌是增长指标自然进入成熟期,剩下的则来自围绕预测市场的“重大生存论点”。
  • 他的机制解释是:体育博彩公司接收所有人的投注,而预测市场是一个交易所,“合约价格代表二元事件发生的概率”——以30美分买入、50美分卖出,不必等到事件落地就能锁定利润。Kalshi 于2018年成立,Polymarket 于2020年成立;两者在过去1年快速起量,起点是 Kalshi 向 CFTC 注册并主张自己是衍生品交易所而非博彩平台,“这让它绕过了大量监管”。
  • 在 Bukola 看来,错误定价的原因是:“市场越来越由短线交易者主导。”他们交易的是数据点——私人预测市场的成交量每天都在上升,而 DKNG 的增速正在放缓——“他们未必在看2年或3年之后”,也没有把预测市场自身面临的风险纳入考量。

2. iGaming:没人建模、却是业务中最好的部分

  • 由于所有人都盯着体育博彩,Bukola 认为市场忽视了 iGaming:收入占比略高于20%,增速20%-25%;而且“绝大多数成本”——包括应对预测市场的投入——都在体育博彩一侧,因此在收入已超过10亿美元的体量上,iGaming “现实中已经能贡献3亿-5亿美元 EBITDA”。
  • Bukola 的结构性判断是,体育博彩公司需要复杂的风险管理,风险定价错误就可能造成重大损失。Walker 补充说,体育博彩公司还是价格接受者——“DraftKings 不可能把 Eagles 赢得 Super Bowl 的赔率设在与所有其他人完全不同的位置”。桌面游戏则自带庄家优势——“人们说经营赌场不可能亏钱时,他们其实不是在说体育博彩”。在线上,这种优势可以“即时、自动”调整,而且客户会自我筛选:如果你在玩老虎机,“你未必是想赢钱的人”。
  • 规模上的关键增量是:iGaming 目前只在覆盖11%人口的州合法,体育博彩的覆盖率则为60%。他不认为 iGaming 最终能达到体育博彩80%以上的覆盖率,但“如果达到50%,那就是这个业务的5倍”——对应一个50亿美元的业务,“其盈利能力已经显著高于体育博彩”,理论上足以支撑整个企业价值。

3. Walker 的质疑:iGaming 真的是寡头市场吗?

  • Walker 的担忧是:线上体育博彩(OSB)的多头逻辑原本是“理性寡头”——2021年圈地潮中其他玩家烧光资金后,剩下 FanDuel、DraftKings 和 MGM;但 iGaming 在每个合法州看起来有7-10个玩家,市场规模更小,用户画像也不匹配:“我妈妈和奶奶喜欢去实体店拉老虎机。她们不会在手机上赌博。”
  • Bukola 的反驳值得保留:“你完全可以、而且当时确实有人,用同样的逻辑围绕 Caesars 质疑体育博彩。”但事实证明,那基本上只是“争抢客户注册的金融圈地”。客户一旦获取,iGaming 客户的盈利能力高得多——账户已经属于平台,“你只需要把他们变现”,不必为每一场赛事争夺用户钱包。
  • Walker 自己在3月投资者日上的让步是:DraftKings 从零开始自研游戏——“你觉得谁能做出更有创意的游戏……是连拉斯维加斯自有物业都更新不了的 Caesars,还是这家原生线上业务?”实际结果也在一定程度上证明了这一点:在已经开放的州,DraftKings 的表现非常好。

4. “被夸大”的威胁,以及那个把一切转到 Kalshi 的朋友

  • Walker 用一位多头的故事反驳“预测市场威胁被夸大”的说法:一份 Trotter 文字稿里的多头开场就说“预测市场被夸大了”,紧接着却承认:“我是体育博彩玩家,我已经把所有体育投注从 FanDuel 和 DraftKings 转到了 Kalshi。”Walker 的判断是:一个更好、更具流动性、成本更低的产品,“在我看来,这简直是在大声告诉我,只要政府不出手,它就会把这些公司干掉”。
  • Bukola 不否认产品更好——他是 Intrade 的老用户,还“为 Intrade 难民运营过一个 Google 群组”,并认为可交易赔率是“毋庸置疑的好主意”;但这恰恰是陷阱:“这类产品非常迎合最终做出投资决策的人自身的偏见。”在金融从业者看来,逻辑会变成“哥们,把这些体育博彩公司扔进垃圾桶吧,结束了”——这与经典的中西部零售商交易正好相反:投资者讨厌消费者喜欢的东西。
  • 他最依赖的证据是:Betfair 已与英国体育博彩公司共存20多年,份额约5%;而 Kalshi 估计10%的美国份额,叠加了其在体育博彩非法州的接近100%份额,而这些州覆盖全国40%的人口——数据中“很难真正看到”正面竞争下的份额替代,尽管 BetMGM 的 CFO 已公开将份额损失归咎于预测市场。Bukola 对 Betfair 天花板的解释是,它规模太小、没有足够资本匹配竞争对手的营销投入;如果监管环境平等,竞争就会回到常规的 LTV/CAC、促销和营销规模圈地。他原话中的保留是:“人们总是倾向于随便编一个数字,而我不会……我们真的不知道”;交易已经成为一种文化潮流,因此英国先例未必适用。
  • 如果监管永远不来,也存在一个微妙的对冲因素:如果预测市场能够在加州和得州运营,“那基本上就保证这些州会立即把 OSB 合法化,这样至少还能收税”——不受监管的竞争,反而可能成为推动合法化的力量。

5. 不公平优势,以及不断累积的丑闻

  • 成本结构上,交易所没有价差(赢家拿到的正是输家支付的金额,扣除 Kalshi 约7%的费用),没有体育博彩公司在定价技术和风险管理上的负担,没有21岁以上的年龄门槛(18岁即可),没有平均约20%、区间从5%-10%到50%的州博彩税——合计规模接近100亿美元——也没有州委员会要求的成瘾赌博监测和赛事诚信合规。Walker 提醒说,税收影响是实打实的:他认为伊利诺伊州单方面加税,导致 DraftKings 和 FanDuel 每笔投注加收5美分,并撤掉了促销活动。
  • Bukola 认为,正在引发立法者关注的包括:美国和以色列军方人员利用内幕信息下注伊朗和委内瑞拉行动何时开始,“这涉及国家安全风险……太荒谬了”,其中一些人已经入狱;此外还有更荒唐的案例,比如 Bad Bunny 的内部人士下注 Super Bowl 结果,以及 MrBeast 市场。Walker 从博弈论角度补充说,一个不受监控的市场里,1万美元的精准下注就可能让外国政府进入“最高级别、红色警报”的危机状态。

6. 3条法律路径,以及为什么 CFTC 可能是隐藏变量

  • 第1条路径是国会:内华达州等地已经提出禁止预测市场交易体育项目的议案,伊朗内幕下注事件也提高了干预可能性,但“我们的国会有些失灵,所以我不会拿钱去赌他们会怎么做”。第2条路径是法院:预测市场正在与20多个州互相起诉或被起诉,已经出现1个巡回法院分歧,今年还将出现几起“基本注定发生”的案件;最高法院此前看起来要到2028年,现在“2027年也有可能”。
  • 第3条、也是很多人忽略的路径是 CFTC。Bukola 认为,CFTC 之所以纵容现状,是因为特朗普阵营的加密货币捐助者推动监管从 SEC 转向 CFTC;Walker 插话说,这可能是“人们能要求的最佳资金回报之一”。CFTC 有700名员工、250名律师,但 Walker 补充称,其执法部门实际上已经消失,而且目前只剩1名委员,还是一名加密货币前律师。
  • 关键先例是:CFTC 在2024年10月或11月就选举合约起诉 Kalshi 时,法院裁定选举不属于“博彩”;但法院、Kalshi 和 CFTC 都默认,如果这属于博彩,“而且他们举的就是 Super Bowl 这个例子”,CFTC 就可以监管。因此即便法律现状不变,“未来一个民主党执掌的 CFTC 也可以直接说:这一切到此为止。”

7. 估值:把2029年利润正常化,得到翻倍,甚至3倍

  • 估值框架是:英国和澳大利亚等成熟市场最终稳定在约30%的 EBITDA 利润率,与 DraftKings 在投资者日给出的长期指引一致,Bukola 认为这一目标可以实现——iGaming 的利润率已经远超20%,而体育博彩在圈地以及抵御预测市场的投入下几乎盈亏平衡。
  • 数学模型是:今年60亿美元营收按12%-15%增长——考虑到合法化覆盖率将从60%提升至80%,以及 iGaming 的上行空间,这并不是一个激进的增速——到2029年约为90亿美元。将利润率下调至15%-20%,可得到15亿-20亿美元的正常化 EBITDA;即便采用15%的利润率情景,按15倍估值也“轻松进入40多美元”。基准情景是翻倍;如果停止应对预测市场带来盈利改善,同时估值倍数重估,“也存在翻3倍甚至更多的情景”。Walker 表示,如果最高法院明天作出裁决,DraftKings 会“一夜之间翻倍”。
  • 即便接受终局逻辑,Walker 仍担忧抵达终局的过程:主要催化剂要等2-3年,期间预测市场是更好的产品,每家券商都在推出类似产品,更优质的产品可能持续抢走份额。Bukola 的重新表述是:这种每天一点点的压力,“正是你能以这些估值买入它的原因”。

8. 灾难情景、串关的非对称性,以及最高法院为何应当出手

  • 对尾部风险不作粉饰:如果预测市场继续不受监管并拿下约50%的市场份额,DraftKings 入场也救不了自己——“我想不出任何一种情况下不会把这看成一场灾难”。交易所是网络效应业务,用户数量就是护城河;“它们已经领先”,而且没有理由押注 DraftKings 能进入行业前3。
  • 对于 Walker 提到的串关问题——20腿长赔率投注在网络上走红、庄家每增加一腿就叠加抽成,以及要求禁止这类掠夺性产品的呼声——Bukola 除了一般性的监管风险外并不担心:“绝大多数人做体育博彩都会输钱……完全可以说整个行业都具有掠夺性。”但“既然这是美国,而我们连枪支在杀死幼儿园孩子时都拒绝监管”,他不认为会出现极端监管。Walker 指出,想打击一方却不打击另一方存在讽刺意味;Bukola 的区分是,政府反对预测市场的动机不是道德恐慌,而是收入:“是收入,对吧?就是收入(It's revenue, right? It's revenue.)政府把体育博彩公司当作获取收入的渠道。”
  • 他最后强调,预测市场的法律主张“荒谬得近乎离谱”——它试图把一套经过100多年形成的监管体系交给“基本上只有 CFTC 的1个人”处理,而案件面对的又是一个曾在2018年重新审视体育博彩问题的最高法院。再加上所有职业联赛、各州总检察长,以及一个强大的利益相关方——原住民部落——提交的意见书;后者的论点“更加直接”,因为不存在联邦优先占用,而且法律解释中存在有利于部落的解释原则。“如果它能通过,我会非常意外。”
完整逐字稿
Andrew Walker

So, Tolu, the company we're going to talk about is one that I have looked at a lot personally, professionally, and all sorts of things. It's DraftKings, ticker DKNG. Obviously, there are lots of things to talk about here, but I'll turn it over to you. What is DraftKings, and why are they so interesting right now?

Tolu Bukola

Yep. DraftKings is an OSB, an online sports betting operator. Though I will point out pretty soon that I actually think there's much more to it than sports betting. It's basically an online gambling company. They've been around since 2012, and they SPACed in 2020.

Historically, for most of its life as a public company, it's been a super-high-growth name. There were questions about quality of earnings, and it's kind of been in this land-grab phase of the growth of the U.S. online sports betting industry. Over the last 6 months or so, the stock has gotten absolutely trashed; it's been roughly cut in half. I started looking into it kind of late last year and started getting involved, and unfortunately, it's become even more of a value name since then. It's had a pretty tough year.

I think it started the year in the 30s and is at roughly $25. Essentially, what's happened is one of these things where I think there's a natural slowdown for the company in terms of some of the fundamental metrics, in particular the growth metrics. That's just a natural part of the market reaching a level of maturation. But then I think a big thing that's happened is there's this big existential thesis out there. The existential thesis is mostly about these things called prediction markets.

I'm sure many of our listeners have heard of these. A prediction market, unlike a sportsbook, which is a centralized entity that takes everyone's bets, is just an exchange. Instead of making a bet and then, 6 months later—or maybe days later, depending on your bet—cashing in or out depending on whether you won or lost, this is a place where you trade contracts.

The contracts will go between 0 and 100, or 0 to 1, essentially. Basically, the value of a contract represents the probability of a binary event happening. You can buy something for 30 cents, or 30%, and then maybe tomorrow it goes up to 50% and you sell and lock in a profit. You don't have to wait around. Unlike a sportsbook, you're not just making a bet and waiting it out. It's a lot more active. Some people would argue it's a lot more interesting.

These things have been around for a while. They've never really taken off in the United States because they've always been illegal, because they've been considered gambling. But several of them—in particular, Kalshi, which launched in 2018, and Polymarket, which launched in 2020—are really taking off over the last year. That's because Kalshi registered with the CFTC and is claiming that, instead of being a betting venue, it is a derivatives exchange, which has allowed it to bypass a lot of regulation.

That's the high level. There are a lot of things to discuss, as you said. We can start with the fundamentals, and I'm sure we'll spend a lot of time discussing the legal angles and things like that.

Andrew Walker

That's a great overview. It's funny to just say, “Explain DraftKings,” because if anyone has ever watched any sporting event, I'm sure they have an idea of what DraftKings and FanDuel are. But you hit the nail on the head: the big risk here is prediction markets, and we can start with those.

I should also mention one other thing. You entered the SumZero Stock of the Year 2026 competition, and I believe your DraftKings pitch came in third. Coming in third in any stock-pitch competition is great, but I believe there were hundreds of entries, so awesome work on that. This is an award-winning—or near-award-winning—pitch, depending on how you want to define coming in the top 3.

We'll get to prediction markets in a second, but let me start with this: You bought a position in DraftKings. There are a lot of things to talk about, and we're going to talk about them, but the market is a really competitive place. What do you think you're seeing that the market is missing? Do you think the market is just overblown on the prediction-market threat? Do you think the market is underlooking the fact that DraftKings is launching prediction markets, and maybe their history suggests they're going to take it? Or do you think it's something else entirely that the market is missing here?

Tolu Bukola

There are 2 things. One is that I think the market is increasingly dominated by short-term traders. So what happened is that when you have a company where the top line is slowing and you have this thesis out there, the prediction markets are growing really fast. You also have a lot of data-driven traders. If you just look at the data, the prediction markets are private, so you can't buy them; every day, they show up and go up, up, up. And the data for this other thing is slowing.

There are a lot of people who mostly trade data points now. They're not necessarily looking out 2 or 3 years, so I think that's a big part of it. A lot of these people are also not considering the risks to the prediction markets, which is a lot of what we'll discuss and get to.

But in terms of DraftKings, I think because people are so focused on the sports betting business, they're ignoring what I think is the best part of the business, which is iGaming. To give you some perspective, iGaming is a little bit more than 20% of the revenue, and it's growing 20% to 25%. They don't really make it possible to do an easy sum-of-the-parts breakout, but they do give a lot of detail on costs. It's safe to say that the overwhelming majority of the costs—and a lot of the incremental costs of marketing and the prediction-market costs that they're incurring this year—all of that is on the sports-betting side.

So iGaming, even at a scale above $1 billion, I think—and once again, you kind of have to make some of your own assumptions about the cost breakout—I think it's realistically already doing $300 million to $500 million in EBITDA, right?

Andrew Walker

Let me ask there. iGaming—I do hear you—is growing quickly, and a lot of that is rollout and all that sort of stuff. But I think the thing people liked about the core DraftKings business, right, is: “Hey, there are a lot of fixed costs in the core DraftKings business.” There was the land rush in 2021, and basically everyone other than MGM, FanDuel, and DraftKings kind of gave up because the fixed costs and everything were too high. They were just incinerating money.

So I think people really liked the online sports betting business because they said, “Hey, it's evolved into this rational oligopoly, right? You've got 3 competitors. And yes, there's still some promos, but you've got this rational oligopoly in this thing that's probably going to be pretty recession-resistant, growing, margins blowing up as everybody starts doing crazier and crazier parlays.” You could see that.

I hear you on iGaming when it's growing, but when I look at iGaming, I say, “Oh, that's not an oligopoly, right?” Every casino has one. Caesars has one, MGM has one. Every state has 7 to 10 players if it's legalized. So yes, it's growing nicely, but it's hard to imagine that's going to have the same kind of nice oligopoly economics. It feels like that's going to be a big competition, and your customer acquisition costs are really going to eat into what the overall returns of that business are.

I hear you that it's there, but is it real when you're talking about switching the bull thesis from, “Hey, we've got an oligopoly in sports betting,” to, “Hey, and also iGaming is much smaller,” right? There is something about people loving to gamble, but there is something about my mom and grandma loving going and pulling the slot physically. They don't gamble on their phones. It's a much different game. It's like, “I want to sit at home and just press and tap slots and gamble.” So it's a smaller market. It's a more competitive market. Is that really a great, “Hey, this is what I'm resting the thesis on?”

Tolu Bukola

So I would say it's part of the thesis, but yes, here's my argument for why I actually think you're underestimating the iGaming business a little bit.

Sports betting, like running a sportsbook, actually takes a bit of sophistication, right? It doesn't happen that frequently, but we do see sportsbooks blow up because they mispriced their risks. In terms of the LTV-to-CAC dynamics, where you do have to advertise a lot to get customers, it's essentially the same, right? But once you get someone into iGaming, they're a lot more profitable. There are a few reasons for that.

The sportsbook has the dynamic that the marketing goes on not just to onboard people, but also, to some extent, it's an event thing. Part of why they're difficult to run is that you can't have completely different odds from everyone else in a sportsbook.

In iGaming, people come onto this, it becomes their account, and you just monetize them, right? There will always be people offering bonuses and stuff, but that's no different from the sportsbook. It's a lot easier to monetize because you're not competing for people on an event-by-event basis, where people are going to go from, “I'm playing slots here,” to, “I'm playing slots somewhere else,” right?

The nature of the business itself is excellent from the perspective of the operator. In iGaming, these are just table games—slots, blackjack, for people who don't know. When people say that you can't lose money running a casino, they're not actually talking about sportsbooks, right? I told you, people have blown up money in sportsbooks. They're really talking about the table games, and that's because you have a built-in edge for the house. You just dump as many customer dollars on that as possible, and you essentially print whatever the edge is.

I think that dynamic is even better when it's online, right? I think about the slots in Vegas, where people are mad because they think they've slightly increased their win rate over the years. But when we're talking about online, you can do that instantly and automatically, and the kind of people who want to do this mostly don't know it's rigged, right? You can think they're some sophisticated sports bettors or whatever, but by definition, if you're playing a game like slots, where you're literally just pressing buttons and shiny things show up, you're not necessarily someone who's trying to win money.

The other thing, in terms of the size, is that iGaming right now is only legal in 11% of the states, containing 11% of the population. Sports betting is legal in states containing 60% of the population. I don't necessarily think iGaming is going to get there, but I think ultimately sports betting will be legal in the vast majority of the country, like 80%+. But if iGaming gets to 50%, that's 5 times the business, right?

So if we're talking about a $1 billion business now, and they keep market share, that's a $5 billion business that I think is already dramatically more profitable than the sportsbook. I think it's very easy to conceive of the iGaming business being worth easily the entire enterprise value right now.

Andrew Walker

No, look, I certainly hear you. I just worry about their customer book. Let's choose a state where it's not legal right now but where it opens up: Chicago. If it opens up in Chicago, who has a better bead on rolling out an iGaming business? Is it DraftKings, with its probably male-, youth-heavy sports betting business, or is it Bally's Casino in downtown Chicago, which probably has a bunch of older people who actually want to play the slots in its customer list? I don't know.

Tolu Bukola

But just to say, though, you could have made that same argument—and I think people did make that same argument—about sports betting with respect to Caesars or something, and it turns out that it's mostly going to be a financial land grab to get the customers onboarded, and then you just execute it the same way.

Andrew Walker

It's a great point, and I know DraftKings just had an investor day. I was reading through the company's investor day presentation from early March of this year that I referenced, and that's what they said, right? They said, “Hey, we are DraftKings. We were daily fantasy sports.” And when this was legalized, everybody was like, “Oh, these guys are going to get murdered.” But guess what? We have the best systems, we have the best marketing, all this sort of stuff. We know how to do this.

It's not lost on me, as you're saying, that with their iGaming, they come out and say, “Look, we built everything from scratch. We built our own games.” Who do I think is going to make more creative games that appeal to iGaming better? Is it going to be Caesars, which can't even update its own properties in Vegas, or is it going to be this online-native business that's doing its own thing? By the way, the proof is somewhat in the pudding: they're doing very, very well in the states where they've already deployed it. So it's not like they're struggling to gain traction, right?

Let's move to prediction markets, because I think that is where the real bull-bear debate on this comes in, right? I will just straw-man and posit 2 things. When I hear bulls talk—I mainly hear bulls—and when I read the company's investor day presentation from early March of this year that I referenced, I hear them say the prediction market threat is overblown. Then I hear them say, “Hey, even if it's not overblown, in the next year or 2, SCOTUS is going to save us from prediction markets.” We can put the legal issue to the side for a second. I'd love to just talk about “overblown,” because I'll give an anecdote, and then I'll give a bull point.

One of my best friends, who's also an avid podcast listener—shout-out, Logan—and I text all the time about sports bets. It used to be that we would share DraftKings stuff, and now we share Kalshi stuff.

I was reading the Trotter transcript to prep for this, and I hear a guy who's a bull say, “Hey, I think the prediction markets are overblown.” That's the first sentence. Then in the second sentence he says, “To play devil's advocate, I'm a sports bettor, and I've moved all my sports betting from FanDuel and DraftKings to Kalshi.” I'm like, man, you just said it's overblown, and then you said you switched over.

It just seems to me that the prediction markets product is more liquid. It's a lot cheaper, largely because there are no gaming taxes, right? It just seems like a better, more liquid product. It's screaming to me that it's going to murder these people unless—we'll talk about the legal side—unless the government steps in. So let's talk about whether prediction markets are overblown.

Tolu Bukola

Okay, so in terms of the product experience, I'm not going to disagree that it's better, but I think we have a bias, right? We are professional investors. This stuff innately appeals to us.

I’m not a big sports betting guy. To give you a hint of my background with prediction markets, I’ve probably been playing with them longer than just about anyone. I used to be on Intrade back when they allowed sports, and then they obviously faced a bunch of regulatory challenges. I actually ran a Google group for Intrade refugees.

I’m a big prediction-markets guy. To me, from a product perspective, it’s a no-brainer. Why would you not be able to trade your odds?

I do think one of the reasons I think maybe the market is overreacting to this is that it’s one of those things that happens to play very well to the bias of the people who end up making the investments. One of my favorite trades is when there’s something that’s really popular in the Midwest and the New York elite look down on it. I think it’s gotten overblown, but I do remember all the times that would happen.

Andrew Walker

That was such a great trade, because the guys who actually buy the stocks don’t like it, but if you just call up 10 customers, they’re like, “This is the best thing ever. I can’t wait for them to open a new store.”

Tolu Bukola

It’s not only retail where it happens, but I agree with you: that’s a really great trade when all the finance people hate it, but the actual customers love it.

I think there’s a bit of the opposite bias here, where, obviously, to people in finance, this is just like, “Dude, throw these sportsbooks in the trash. It’s over.” But that’s, to some extent, non-disprovable. I will say that some of the evidence I lean on is that, as I said, prediction markets are not new.

Flutter’s Betfair, which is a prediction market, has existed in the UK for 20-plus years. It’s hard to get the exact data, but the best data we have is that they have about 5% of the market. They coexist with online sportsbooks, real-life casinos, and so on. The best evidence we have is that they’ve been able to get about 5%.

Now, you could argue that there are 2 possibilities. One is U.S. cultural exceptionalism, but the other is simply changes over time. Kids these days are a lot more online and a lot more comfortable with crypto and gambling. It strikes me that, when I was growing up, I was like, “Oh, I’m too scared.” But kids these days know, and it spreads through TikTok and Snapchat. If you’re doing something suboptimal, they’re going to spread it real fast, and you’re going to know.

Coinbase has been super popular—everyone trades, right? Trading has become part of the cultural zeitgeist over the last 5 years. I wouldn’t naively insist that we’re going to be limited to 5% like the UK is. It’s possible that it’s a lot more popular here, but the evidence does seem to suggest that it’s not something that, at least very quickly, replaces the sportsbooks.

If we look at the evidence of what has actually happened so far, it’s been really hard to see it in the data. The data released by DraftKings and other American operators is not to say there isn’t some displacement going on. I will tell you that one of the sell-side sources I used estimated that Kalshi already has 10% share of sports betting.

But you have to remember that 40% of the country’s sports betting is illegal, whereas Kalshi does not respect those limitations. We’ve been at war with them for a long time. They basically should have 100% share in California and 100% share in Texas, and there are all these places where they essentially have 100% share. When that rolls up to a 10% combined share, it doesn’t actually mean that they’re making a big impact in places where they compete head-to-head with sportsbooks. So far, we just haven’t really seen it.

The numbers DraftKings has released recently—given their growth, it’s naive to think that they’re not making any impact. They’re definitely making some, but we’re certainly not in a place where we can start to underwrite the thesis that these things are going to dominate the market or even be 20%. I’d say there’s still a significant amount of uncertainty there.

Andrew Walker

No, that’s great. BetMGM came out and reported earlier this week, and I subscribe to a lot of the gaming publications. Their CFO is not dancing around the issue. He says, “Our results were okay. They would have been much better if it wasn’t for prediction markets. They’re taking share,” all this sort of stuff.

Let me actually back up. As we sit here, you’re saying, “I agree with you. It’s California, Texas, Utah—these places where sports betting is just completely outlawed. It’s crazy to me that they only have 10% share, given that they probably have 100% share in those places.”

If we roll this forward and there’s no regulatory pushback, how much do you think prediction-market share stabilizes at in markets where they share with DraftKings and FanDuel—markets where sports betting is legal?

Tolu Bukola

This is one of those things where there’s a tendency to make up a number, and I’m just not going to, right? We really just don’t know. As I said, the only real evidence we have is the UK and a few other markets where they’ve stabilized at single-digit percentages. But, as I said, different generation, different country. In the case where they do not face any kind of regulatory pushback, it’s hard to say.

I will say, though—and we’ll get into this more when we discuss the regulation—that in that case, there are actually things that will also benefit online sportsbook operators. When we’re talking about regulatory pushback, we’re not talking about pushback to put prediction markets at a disadvantage. We’re talking about pushback to put them on par.

If prediction markets are not prevented from operating in California, for example, or in Texas, that pretty much guarantees that those states will immediately legalize online sports betting so that they can at least collect taxes from the fact that people are already betting. In that case, we actually have this offsetting dynamic of maybe they become the thing that pushes for further legalization.

As to that core question, no one can predict the future that way. We can only hang our hats on the data we already have.

Look, it’s one of the reasons why I ultimately think the legal case does win. We can talk about the legal case in a second, but you just look at it and you’re like, “Okay, so we have unregulated gambling.” Governments generally do not like unregulated gambling. They don’t like the unregulated part.

But then, oh, by the way, DraftKings is generating tens of millions in tax revenue for many of these states. It’s unregulated gambling that’s not generating tax revenue. I just can’t believe that the government, even if the Supreme Court rules, “Hey, this is legal,” isn’t going to change the law.

If you make it completely unregulated, to me it clearly takes up a huge share, and it’s not generating any tax revenue. So even if you ignore the “Hey, we’re going to create a bunch of gambling addicts” argument—which I’m not sure whether governments care about or not—they certainly care about, “Hey, we legalized gambling to get 25 million in extra tax revenue every year, and now we’re getting zero.” I think they’re going to care about that.

Andrew Walker

Betfair was one of the really interesting pieces you shared—the piece that you came in third in SumZero with. You said, “Betfair, which is a bet exchange, stabilized at below 5% market share in Great Britain.”

We’ve already talked a little bit about how, 20 years ago, the people who were betting might have been a little less financially sophisticated. But even if you said that right now in the U.S. it’s 10% market share for prediction markets, and probably lower in places where they compete head-to-head, that seems crazy low to me.

Why did Betfair only stabilize at 5%? It seems like so much of a better model. I know Betfair has advertised one of its advantages as, “Hey, we’re 20% cheaper than all the alternatives.” Prediction markets might be 95% cheaper than DraftKings here because they don’t pay taxes, but why did Betfair stabilize below 5%? Why wasn’t it 25%, 30%, 50%, or 90%?

Tolu Bukola

There are 2 things. One is what we’ve already discussed. I think there’s a cultural bias among traders like us to think, “Oh, this is an obviously superior product, so it should win.” Even with the whole idea that it’s cheaper, I’m not really sure. Most bettors are not sharp bettors, right? They’re not necessarily all about maximizing their edge, or they probably wouldn’t bet anyway.

Andrew Walker

So I think this assumption that this is an inherently better product and therefore should gain more market share is just kind of false, right? But, number 2, I actually think that in a world where there were no regulatory differentials or anything of that sort, to some extent it just reverts to the same thing in terms of competition. It ultimately comes down to LTV/CAC: who can do the most advertising?

How much money was Betfair able to invest beyond getting people to the product? Well, until they were bought by Flutter, they were a pretty small operation. They were bought by Flutter, so Flutter, obviously, relative to where they were, has effectively infinite money. But it's a little bit of a self-fulfilling dynamic: they didn't have enough money to pour billions and billions and billions into marketing the way the competition could.

In the scenario where we were on an even regulatory footing—which, once again, we'll discuss what that even means, because I don't think people understand the extent to which it's not just that we're not even; it's that prediction markets have massive unfair advantages right now—then, to some extent, it would also just be the usual land grab. Who's going to do the most promotions? Who's going to do the most marketing? Who shows up every time you listen to or watch ESPN, or listen to a podcast?

Right now, to some extent, you would expect DraftKings, Flutter, and everyone else to compete against the prediction markets, but also against each other in the exact same way that they already compete: “We're going to own all the podcasts. We're going to spend the marketing dollars.” It becomes a game of marketing scale. Obviously, this podcast is not devoted to sports, so I can understand why, but I am a little insulted that they haven't sponsored my podcast yet.

Tolu Bukola

Just tell them you want DraftKings.

Andrew Walker

Yeah, get that money. You mentioned it. I think this is worth bearing in mind because when I talk to people—people who aren't, I don't want to say financially sophisticated, but people who just don't follow this super closely—a lot of times they don't realize, first, it's funny, sometimes people don't realize that when we talk about bets, the vig is how much the house is taking when you're betting.

They're like, “Oh yeah, of course you bet $100 to win, in a straight-up bet where both sides are even, you bet $100 to win $90.90.” I'm like, “Yeah, well, that $9.10 is the house vig.” But let's talk about the advantage that prediction markets have, because I don't think people who haven't looked at the math really understand why they're so much cheaper.

Tolu Bukola

In a prediction market, you basically trade against other players. I guess it makes more sense to talk about sportsbooks, because to me they actually look a bit weirder. In a sportsbook, you place a bet, and then you either win or lose.

Sportsbooks have this thing where the total amount of betting is the handle, and they have this thing called hold, which is ultimately how much of the handle they get. It's basically sportsbooks pricing things efficiently, but also having a structural spread, in that if you were to make both sides of the exact same bet, you would actually lose money. That's just the spread that they collect.

By contrast, there is no spread on prediction markets. You're betting against another player. Someone wins exactly as much as someone loses, except for a transaction fee. Who knows where the transaction fees will stabilize? I think right now Kalshi's is about 7%. That's kind of the biggest difference.

Andrew Walker

Yeah, so I think that's a great one. If you just think about that, prediction markets, number 1, have an advantage there because if you and I are running a sportsbook, we have to have all sorts of sophisticated pricing technology. You're not just trying—if it's the Patriots versus the Seahawks in the Super Bowl—to even out the money on the Patriots on one side and the Seahawks on the other.

If people are doing more complex things, like if somebody bets on Drake Maye to throw 2 touchdowns, how do you have the other side of that? These things can get really complicated. So you have to hire lots of computer scientists, probably being replaced by AI right now, but yes, hire lots of people to do that. You have to deal with lots of regulatory stuff, and you have to have a book-building or risk-management process and all that sort of stuff.

Prediction markets, all of that's out the window, right? All you have to do is say, “Hey, we need to match Andrew and Tolu, and have one of them bet on the Patriots and one of them bet on the Seahawks, and just make the odds even where people are willing to trade.”

The other thing that I think I kind of implied earlier that is a challenge for the sportsbook is that you're also somewhat of a price taker. DraftKings can't set the odds of the Eagles winning the Super Bowl at a completely different price from everyone else, because that just creates arbitrage and all kinds of crazy risks.

If DraftKings says, “Hey, we think the Eagles should be 10-point favorites,” and they're 3-point favorites everywhere else, people are going to be betting like crazy everywhere else and then taking the other side of it. It's fairly complex.

Another way prediction markets have a huge advantage right now, which we've alluded to, is that DraftKings, in every state where it operates, faces state-level taxes. I believe it's applied to the hold, not the handle—but no, actually, it might be on the handle. I can't remember. Every bet, basically, they have to give the state government a cut.

Prediction markets, because they're regulated by the CFTC and not at the state level, don't give anything. When one side has to give a cut of everything right off the top to the government and the other side doesn't, that is just a massive tax advantage that prediction markets have.

Tolu Bukola

I think we're getting to some of the legal issues now. Prediction markets claim to be federally regulated, so they don't pay these taxes. The taxes can be really high, by the way; they go all the way from 5% or 10% to 50%.

Andrew Walker

I think Illinois—and this was a big risk over last summer, I thought, for DraftKings—unilaterally changed the taxes on sports betting there. DraftKings and FanDuel were like, “Okay, well, now we have to...” I believe they started instituting, if you're an Illinois bettor, a 5-cent tax, because that's what they did, and they had to pull back all their promotions—everything. So it can be a big number.

That's one of the risks to this business, right? We know how government and taxation works. They'll always be tempted to take more, and a gambling business is something people tend not to be super sympathetic to. Just like you can always increase the taxes on cigarettes and booze, because there won't be as much pushback on that, you can kind of always increase the taxes on gambling.

The prediction markets are not paying these taxes, which I think average out to about 20% across the states, and yearly—I forgot the exact number—but it's getting close to $10 billion, right? They're not paying these taxes. They're also allowing anyone over the age of 18 to bet, whereas most states restrict it to 21.

Obviously, the big one everyone focuses on is that they will allow you to do this in any state, including states where sports betting is illegal, and that includes many of the biggest states—in particular, California and Texas.

State gaming commissions have all kinds of requirements. You have to do all of these things about problem gambling. You have to monitor problem gambling. You have to do all of these sports-integrity rules and make sure that if you see a chance that someone is insider trading or someone is match-fixing, you flag it. All of that stuff is very expensive. Prediction markets currently don't have to do any of that.

We're obviously talking about sports betting, but anyone who's followed any of the news knows that once a week you see, “Hey, someone in the Trump administration made one decision, and 15 minutes before, the prediction markets were lit up with people buying things.” If that's happening in politics, you're probably not going to have a LeBron James gambling on himself in a game, but think about all of the scandals that the NBA had in the past year.

The prediction markets are so anonymous and so easy, and they have just no regulatory infrastructure around stopping insider trading. You could imagine real scandals developing in the prediction markets.

Tolu Bukola

I think we already have, right? And speaking of non-sports things, I think what's actually brought a lot of really negative legislative attention to prediction markets is that, for all of the military operations we've had against Iran and Venezuela...

So, there have been members of both the U.S. and Israeli militaries betting on when these operations would begin based on their insider knowledge, which is a national security risk. It’s absurd. People went to jail; some of the Israeli people went to jail for it.

But I did start wondering: if you didn’t regulate it, could you have the Trump administration say, “All right, we’re going to attack,” and just throw in $10,000 real quick?

Andrew Walker

Or, I said, Trump and any administration. If everybody starts monitoring this, that would create a crisis in another country. We’re actually not going to do anything, but it’d be the cheapest way: $10,000, and you stir up an entire foreign government to go five-alarm, red-alert fire.

It’s kind of interesting to think about the game theory: if the prediction markets aren’t regulated, everybody’s paying attention, and you just throw a little money in, you could cause another government to call up 500,000 reserves or something.

Andrew Walker

Yeah, yeah. There was also the Bad Bunny one, where some Bad Bunny insider was betting on exactly where we would be in a Super Bowl. Some of them have been really stupid. There was a MrBeast one.

I think we’ve talked about this, and I’m going to come back to valuation and fundamentals second, but what is the legal path? I mean, DraftKings, BetMGM, everyone is looking for a legal path to shut this down and get what I would call a fair playing field. What does the legal path to get there look like?

Tolu Bukola

Okay, so there are 3 legal paths, and we’re going to focus on 1. I’ll just explain what the 3 are. The first one is that Congress steps in, makes legislation, and stops prediction markets from doing sports. We’ve had some proposals, as you can predict, from the states they came from—Nevada. We’ve had some congressmen getting on board with banning prediction markets from sports. We’ve also had some calls to basically ban prediction markets altogether.

How likely is this? Honestly, I don’t know. I think some of the stuff, like the insider betting around the Iran attack, is making it much more likely that we see a legislative intervention. That’s something that’s quite possible, but I don’t necessarily focus on it. I think our Congress is kind of dysfunctional, so I don’t bet money on what they’ll do.

The second path, and that’s the one we’ll discuss the most, is that I think there’s a very strong case that what the prediction markets are doing is already just illegal—and illegal in some truly absurd ways that we will go into. The second path is the one that I think is progressing steadily: prediction markets either suing or being sued by 20-plus states. We’ve already had some circuit splits. This is basically guaranteed to get to the Supreme Court.

I previously thought it was going to be in 2028. This stuff is moving so fast and has already created so many splits—well, it’s already created 1 split, and it’s basically guaranteed to get several more this year—that I think we could see an acceleration of that timeline. Maybe 2027 is possible.

The third one, which people don’t think about, is that the prediction markets are able to do what they’re doing due to the complicity of the CFTC. The CFTC is historically a commodities regulator, the little brother of the SEC. It only has 700 employees and 250 lawyers—not a very big federal agency.

What happened under the Trump administration is that, essentially, the crypto people donated a ton of money to Trump, and what they wanted was less regulation of crypto. Part of how they achieved this was moving it from the well-resourced SEC to the CFTC. They got what they asked for. It’s some of the best return on money people could ask for.

Andrew Walker

Oh yeah, they got exactly what they asked for. The funny thing is that, aside from not being particularly well-resourced historically—the CFTC typically has 700 employees and 250 lawyers—it’s particularly under-resourced right now because basically the entire enforcement division quit or was pushed out. It has no enforcement division. It’s normally supposed to have 5 commissioners, and it only has 1. The guy is an ex-crypto lawyer, so you can guess how he feels about all these things. He isn’t basically putting his full force behind the prediction markets, right?

Tolu Bukola

But even if you accept the legal status quo—even if the Supreme Court doesn’t really pull back on the CFTC’s ability to regulate these things—a future CFTC would have the right to stop all of this, right?

One of the cases involved Kalshi in October or November 2024. Before it started doing sports, it started doing elections, and the CFTC actually sued it to stop the elections. Kalshi won on the argument that the CEA—the law that created the CFTC—has a special provision giving the CFTC the right to review contracts whose underlying function is gaming.

The court ruled that, because elections are not gaming, it’s not clear that the CFTC has a right to regulate these election contracts. But what’s interesting about that is the implicit assumption by both the court, Kalshi, and the CFTC that if the underlying function were gaming—and they literally used the exact example of the Super Bowl—the CFTC could regulate it.

The point here is that we’ve established that the CFTC can, in fact, regulate sports contracts. The only reason the CFTC isn’t doing so is because it’s kind of bought by these crypto interests, who also happen to be a lot of the same people who are now involved in prediction markets, and so it doesn’t want to.

A future Democratic CFTC could, even under the legal status quo, just say, “All of this is over,” right?

Andrew Walker

Great overview. I want to go to valuation in a second, but let me just lay out my worry here. Again, I have no position here, but if I just laid this out, I think people could probably tell that I fully believe this should be regulated, and I fully think at some point hands are going to get forced just because we’re losing out on tax revenue and all this sort of stuff.

But my worry is that you laid out the Supreme Court probably in 2028, maybe 2027 at this point, and a new CFTC commissioner maybe in 2028. You probably need a change of administration, and probably a Democratic administration. All these things are 2 to 3 years away.

I think listeners could probably tell that, in a righteous world, this should happen, and we should have an even playing field and regulation. But my worry is: Is it 2 years away? In the intervening 2 years, I think both you and I could agree that prediction markets as is are probably a superior product.

I worry that a superior product just takes a lot of share. As we’re waiting for those 2 years, every day there’s this drip, drop, drip of more prediction markets. Look at the prediction-market volumes. Every broker starts launching a prediction market to get in on some of this volume, and this competition is rising.

So, I’m going to pause there, and then we can just talk valuation and everything.

Tolu Bukola

Yeah, look, there’s a little bit of investment philosophy here. To me, this is part of why this is interesting. People are paying so much attention to the dip in the data on the prediction markets and to their increasing volumes. That’s why you get to buy it at these valuations, right?

To me, the investment thesis is the opportunity to look 2 years out and say, “Okay, this would have grown a little bit more.” Their iGaming business would have grown more, and at the same time, we’ll likely be getting 1 of the big existential risks taken off the table. At that point, people will be able to look at more of the underlying end-state economics of this business and say, “Wow, this is really cheap relative to what we think is going to be the long-term profit generation.”

There’s a shorthand way to value this, right? The prediction markets kind of started in August, and I don’t think this is a really AI-able business, but it was trading at 45 to 50 in late August. Then the prediction-market scare really started happening, and it’s trading at 23 now.

Is the right way to think about it that it grows a little bit in 2028 and 2029, there’s some type of regulatory crackdown on prediction markets, and we go right back to 45 to 50? So, you’re kind of looking at a 2- to 3-year double. Or is there any way you want to value it? Is that kind of a fun and easy shorthand way to look at it?

Tolu Bukola

I do think you’re kind of looking at a 2- to 3-year double. The way I think about it is that you have to look at the long-term economics. At their latest investor day, they guided to their long-term 30% EBITDA margins. I think that’s achievable.

But they’re still kind of in the land-grab phase, especially in the sports-betting business. The only way to really think about long-term economics is just looking once again at the example of markets where sports betting has been legal for a while and where we have similar competitive dynamics to what we’re likely to experience, which is a little bit oligopolistic: a few big players, and then a long tail of worse players.

So, if you're looking at both the UK and Australia, these businesses have kind of settled at roughly 30% EBITDA. Like I said, if you break out the iGaming business, it's already well over 20%, and they're basically barely breaking even on sports betting. That's because they're spending all this money to gain share, and they're also now spending a bunch of money to defend themselves against prediction markets.

Let's say you don't want to underwrite the 30%. Let's say you want to think about it like 20%. They did $6 billion this year. If you think they'd grow at just 12% to 15%, they'll be close to $9 billion by 2029. This isn't a very aggressive rate of growth, because even if you're not getting further penetration in sports betting, you're going to get a tailwind from going from 60% of the population to 80% of the population. On the iGaming side, you have a lot more upside, so it's not a super-aggressive rate of growth.

We're talking about being basically 50% bigger than they are right now. You start to adjust what you think could be end-state margins to that. You don't give them credit for the full 30%; let's say you give them 20%, or even 15%. We're talking about $1.5 billion to $2 billion of EBITDA. That's what you would think of as normalized EBITDA in 2029, and then we can apply whatever multiple we want. I think a business like this probably gets 12 to 15 times.

If you put 15 times on even a lower-than-20% mid-cycle margin—let's say a 15% margin in 2029—that easily gets you into the 40s. If we do get a little bit of a dissipation of the prediction-markets thesis, because they've gotten some regulatory pushback and have had to submit to state regulation, you could imagine that these companies get a profitability bump from not having to spend money to compete in that space. You could also imagine that they'll get a multiple bump. In the base case, I think you basically get a double, and then there are cases where you get a triple or more.

Andrew Walker

Right. I mean, I will say, I think if there was a Supreme Court ruling tomorrow that said prediction markets were illegal, DraftKings would double overnight, to be honest with you. But let me ask 2 last questions, and then I'll give it to you for last thoughts, and then we can wrap up prediction markets.

We talked about it a little bit at the beginning, but let's say we continue living in the world we're in right now, and prediction markets, for whatever reason, don't get regulated, or get light-touch regulation—whatever you want to call it. DraftKings is moving into prediction markets as well. We had talked about how DraftKings has a history of winning in these spaces. You and DraftKings both mentioned that no one thought you could win in sports betting.

What do you think it looks like if prediction markets don't get regulated and DraftKings has to move into them? Do you think they stand a chance against Kalshi and Polymarket? What do you think the end-state economics look like if this becomes more of a prediction-market business than a betting business?

Tolu Bukola

I don't think there's any situation where I wouldn't see that as a disaster. I just don't think they necessarily have an advantage in this space. Prediction markets are actually much more of a network-effects business.

Sportsbooks are a scale business in terms of marketing scale to attract customers. But in prediction markets, the absolute number of customers on the platform makes a big difference, which is why it's also important that they're able to avoid manipulation, be nationwide, and allow cross-border betting. Who knows where they settle, but they're already behind. I'm not sure there's any reason to suggest that they would be one of the top 3 or 4, in which case I'm not sure there's anything to suggest that they would be able to build a substantial business.

In the prediction-markets world, that means both that prediction markets don't undergo any kind of regulation to bring them under state control and that they become 50% of the market. That is the bear case. I don't see a world where that happens and somehow DraftKings is still on top. That is the ultimate bear case.

Andrew Walker

Last question. If we were recording this podcast in mid-2023, I think the main question would have been: What are the economics of DraftKings, FanDuel, and everything in U.S. sports betting? People would have suggested, as you did, that we could look to the mature markets—Australia, England, and so on—and say, "These are the margins." But I think people would have said, "DraftKings has kind of had 3 years. It's looking a little bit more competitive, margins are lower, and parlays really started exploding."

For those who don't know, on your average bet, I think the house take is around 10%. As you start layering in more and more parlays, the house take just goes up and up, because they exponentially increase all of the house odds. You combine 2 bets that are at 10%, and all of a sudden you're at 18%, whatever. I think margins really exploded with parlays, and I just want to ask you about that.

I would say parlay culture is driving that. Every advertiser is pitching parlays. You see these 20-leg parlays where 1 person bets $1 and wins tens of thousands of dollars, and those always go viral. I know I do it: every now and then I'll watch a game and say, "Let's throw an 8-leg parlay on for $1 just to make this game more interesting."

You hear people say parlays are predatory. The odds are so long, they favor the house so much, and they're sucking in younger kids. Do you worry about crackdown risk on parlays at all? I know there are people out there who say, "Let's just eliminate them. It's better for safer gambling. Let's take some of these long-shot odds out." Do you worry about that, because it would materially change the economics of these businesses?

Tolu Bukola

No, I don't. I don't worry about crackdown risk on parlays in particular any more than I worry about the broader regulatory risk for these businesses. Part of the risk case for these businesses is that they get heavily regulated. There might be a focus on parlays right now, with people saying they're predatory, but the vast majority of people are going to lose money sports betting. There's a case that the entire thing is predatory.

To the extent that I'm worried, it's more about whether taxes keep going up. With Kalshi and prediction markets being so aggressive and bringing more attention to the space, we're also seeing a general sense that they've unleashed this terror around sports betting—a little bit of a moral panic. Given that this is the United States, and we refuse to regulate guns when they kill kindergarteners, I don't think we're going to get super regulation, but it is a risk.

There's an extent to which every type of gambling is a fundamentally predatory business, in the sense that it's intended for the customers to lose money. The counterargument is that it's just entertainment.

Andrew Walker

Yeah, no, well said. I guess the other argument I could have made was that there are 1% of the population who are ruining their lives with these things, but we've shown no desire to crack down on or hit those people. I think you're right—it's a really interesting case.

I think people can get this through the podcast: both you and I believe the prediction-markets thing is insane, but you've got this huge risk. If the government does not step in to shut down prediction markets, maybe the future is fine for DraftKings. Maybe they become a big prediction-market player, but they lose this oligopoly they've got.

On one hand, you're relying on the government to crack down on this side. On the other hand, you've got parlays and all these long-shot bets that are pretty darn predatory. You hear in some corners, "Maybe they should have banned them," but you're relying on the government to say, "No, we're not going to touch this, but we're definitely coming after that." And guess what?

Tolu Bukola

I will say that it's a little bit different, because I don't think the reason the government is going after prediction markets is the moral-panic aspect. No, it's revenue. The reason we allow you to do things that people consider morally more exploitative is that now the government is using the sportsbook as a conduit. It's just revenue.

Andrew Walker

We're on the same page, my friend. We're on the same page. I was just saying it's funny that you want the government to crack down here but not over there, you know. This has been really fun.

I thought you did a great job walking through all this sort of stuff. As you saw, I'm pretty passionate about this. Is there anything else you think we should have hit that we didn't hit, or should have hit harder, that we kind of lost along the way?

Tolu Bukola

I will say, though, that I'll find a place to put up the thesis so people can read it.

Andrew Walker

Oh, send me a link. I didn't want to say, “Hey, I've got the secret thesis,” but if you send me a link, I'll include it in the show notes and everything so people can look at it.

Tolu Bukola

I will say, though, I guess the part we didn't spend as much time on, but that I wanted to emphasize, is that I think the Supreme Court angle is really strong in terms of the case against the prediction markets being legal and being able to avoid state regulation. I think what the prediction markets are claiming from a legal perspective kind of borders on the absurd in the way that it violates 100 years of American law, including laws that the Supreme Court addressed previously, and in the way it's basically an argument for handing over regulation that we spent all these years crafting to what is, basically at this point, just 1 guy at the CFTC. I would be shocked if it flies.

Andrew Walker

Right. I'm completely with you. And look, the Supreme Court—you can look back—sports gambling became legal, what, 10 years ago?

Tolu Bukola

2018. Yeah, so they've addressed this recently. We know how they think about these things. It would just be completely shocking. And by the way, not just that, but you're going to have every league—every sports league—is going to file a brief with the Supreme Court that says, “Hey, we need this regulated for integrity of the game,” and all this sort of stuff. Every—you mentioned 20. It's probably going to be—

Andrew Walker

Basically every state, yeah, is going to say, “Hey, for financial reasons, for safety reasons, all this sort of stuff.”

Tolu Bukola

Also, the last constituency that's really powerful here is the Native American tribes, right? So they've had special interests in gambling for a long time, and as a result, a lot of them actually do have a pretty substantial amount of money. Aside from all the state attorneys general that are suing and being sued by Kalshi, the Native American tribes are also going to be suing the prediction markets directly, and I actually think their case is even more straightforward, right? Because there's no federal preemption, right? There are all of these statutes that basically give Native Americans special rights, and there's even this Indian canon of construction that basically means that you're supposed to construe laws in a way that favors the tribes. And so what the prediction markets are trying to pull, which is to draw some ambiguity in the law and use it to seize all this power, fails even harder when you start considering the Native American tribes.

Andrew Walker

Perfect, perfect. Cool. Well, hey, this has been awesome. If you send me Dropbox links or whatever to the write-up, I can include it in the show notes so everybody can go read it. He breaks down a lot of the different legal arguments in full detail in the write-up, so I'll include it there. And Tolu, this has been great. A great first appearance. I'd love to have you on for a second one. We'll follow up and get you back on here in the near future.

Tolu Bukola

Awesome, thanks. It was great coming on the show.