[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"blog-post-sweepstakes-casinos-four-states-four-routes":3},{"post":4,"related":272},{"id":5,"slug":6,"title":7,"excerpt":8,"body_markdown":9,"category":10,"tags":11,"hero_image_url":14,"author_id":15,"author_name":16,"read_minutes":17,"published":18,"published_at":19,"view_count":20,"meta_description":8,"meta_keywords":15,"created_at":21,"updated_at":22,"source":12,"external_url":15,"blocks":23,"sources":251,"canonical_url":271,"current_to":237},"07a12ed6-7708-4fce-ae6d-a5c18388ed48","sweepstakes-casinos-four-states-four-routes","Sweepstakes casinos: four states, four ways past the free method of entry","New York defined the product, California counted the free coin, Tennessee called it a lottery and Illinois called it internet gambling — read in the statutes’ own words, and against the operators’ own terms.","Every state that has acted on sweepstakes casinos has had to deal with the same argument: that a free way to get the prize currency removes the payment a lottery requires. New York, California, Tennessee and Illinois each dealt with it differently, and the route a state took decides what an operator, or a vendor serving one, has to answer.\n\n## The argument each state had to meet\n\nStake.us, the sweepstakes brand of the Stake group, states the operators’ position in its own terms. The paid currency is Gold Coins; the prize currency is Stake Cash, which is never sold:\n\n> 2.4. THE PLATFORM AND GAMES DO NOT OFFER REAL MONEY GAMBLING, AND NO ACTUAL MONEY IS REQUIRED TO PLAY.\n>\n> — [Stake.us Terms & Conditions v18.0, cl. 2.4](https:\u002F\u002Fstake.us\u002Fpolicies\u002Fterms)\n\n> b) YOU CANNOT PURCHASE STAKE CASH.STAKE CASH CAN BE OBTAINED ONLY THROUGH FREE, PROMOTIONAL OFFERS. … iii) Post Card – Customers can receive 5 free Stake Cash by sending a standard postcard on the terms set out in the clause 8.3.\n>\n> — [Stake.us Terms & Conditions v18.0, cl. 8.1(b), 8.2(a)](https:\u002F\u002Fstake.us\u002Fpolicies\u002Fterms)\n\nThe prize currency is never sold, and a postcard yields five of it. That is the free-entry argument in two clauses. Each state below reads the product differently.\n\n[Video: Stake.us’s Terms & Conditions at clause 8, with the site’s chat panel hidden: Stake Cash used only for Promotional Play, “YOU CANNOT PURCHASE STAKE CASH”, and the free routes in 8.2, from the daily login bonus to five Stake Cash by postcard.](https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fsweeps-stake-us-terms-stake-cash.mp4)\n\n| State | Instrument | Date | How it answers the free method of entry |\n| --- | --- | --- | --- |\n| New York | Statute: S5935-A (L. 2025, ch. 605), Racing, Pari-Mutuel Wagering and Breeding Law § 912 | Signed December 5, 2025 | Defines the game by its structure. The definition contains no consideration test, so the free route is never reached. |\n| California | Statute: AB 831 (Stats. 2025, ch. 623), Penal Code § 337o | Approved October 11, 2025 | Keeps the element and counts the free coin as “indirect consideration”. |\n| Tennessee | Cease-and-desist letters under existing law | December 29, 2025 | Treats the model as an illegal lottery prohibited by the Tennessee Constitution. |\n| Illinois | Cease-and-desist letters under existing law | February 5, 2026 | Treats internet games of chance that award money or items of value as a crime. Consideration is not mentioned. |\n\n## New York: define the product, skip the element\n\n> (a) \"Online sweepstakes game\" shall mean any game, contest, or promotion that is available on the internet and\u002For accessible on a mobile phone, computer terminal, or similar access device, that utilizes a dual-currency system of payment allowing the player to exchange the currency for any cash prize, cash award or cash equivalents, or any chance to win any cash prize, cash award or cash equivalents, and simulates casino-style gaming, including but not limited to, slot machines, video poker, table games, lottery games, bingo, or sports wagering.\n>\n> — [N.Y. Racing, Pari-Mutuel Wagering & Breeding Law § 912(1)(a), added by S5935-A](https:\u002F\u002Fnyassembly.gov\u002Fleg\u002F?default_fld=&leg_video=&bn=S05935&term=2025&Summary=Y&Actions=Y&Text=Y)\n\nNo part of the definition asks whether a free entry exists. A postcard route changes nothing under this text.\n\n## California: count the free coin\n\n> (1) “Direct consideration” means a coin, token, or other representation of value that may be purchased by a player or received through a bonus or promotion and that is used for playing or participating in the online sweepstakes game. (2) “Indirect consideration” means a coin, token, or other representation of value that may be exchanged for a prize, award, cash, or cash equivalents or a chance to win a prize, award, cash, or cash equivalents. Indirect consideration is provided for free through a promotion, bonus, or with the purchase of a related product, service, or activity. As used in this paragraph, “related product, service, or activity” includes a coin, token, or other representation of value that may be used for direct consideration.\n>\n> — [Cal. Penal Code § 337o(c)(1)–(2), added by AB 831](https:\u002F\u002Fleginfo.legislature.ca.gov\u002Ffaces\u002FbillTextClient.xhtml?bill_id=202520260AB831)\n\nA prize coin handed out “as a bonus upon the purchase of specifically marked packs” of the paid coin is the pattern this definition describes, and the paid coin is itself named as the “related product”.\n\n[Video: Chumba’s public Promotions page: a top banner offering GC10M for $10 “plus FREE SC30”, then the Purchase offers section with a welcome offer of GC 2,000,000 + SC 2. A paid Gold Coin pack with Sweeps Coins added is the pairing this definition describes.](https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fsweeps-chumba-purchase-offers.mp4)\n\n## Tennessee and Illinois: existing law, two theories\n\nNeither state needed a new statute. Tennessee reads its constitution as a lottery ban and addresses consideration directly:\n\n> The promotional sweepstakes model used by these casinos constitutes an illegal lottery prohibited by the Tennessee Constitution and violates Tennessee gambling and consumer-protection laws.\n>\n> — [Tennessee Attorney General, press release PR25-61 (Dec. 29, 2025)](https:\u002F\u002Fwww.tn.gov\u002Fattorneygeneral\u002Fnews\u002F2025\u002F12\u002F29\u002Fpr25-61.html)\n\nIllinois reads its criminal law as an internet-gambling ban, and the free method of entry is never reached:\n\n> Offering games of chance that award money or other items of value via the internet violates Illinois criminal law.\n>\n> — [Illinois Gaming Board, press release (Feb. 5, 2026)](https:\u002F\u002Fwww.illinois.gov\u002Fcontent\u002Fdam\u002Fsoi\u002Fen\u002Fweb\u002Fillinois\u002Fiisnewsattachments\u002F32173-020526-igb-r-cease-and-desist-online-casinos-final-25025.pdf.pdf)\n\n## The supply chain is inside the statutes\n\nBoth statutes reach past the operator. California requires a state of mind:\n\n> (b) It is unlawful for any entity, financial institution, payment processor, geolocation provider, gaming content supplier, platform provider, or media affiliate to knowingly and willfully support directly or indirectly the operation, conduct, or promotion of an online sweepstakes game within this state.\n>\n> — [Cal. Penal Code § 337o(b)](https:\u002F\u002Fleginfo.legislature.ca.gov\u002Ffaces\u002FbillTextClient.xhtml?bill_id=202520260AB831)\n\nNew York does not:\n\n> (b) It shall be unlawful for any applicant, licensed entity, financial institution, payment processor, geolocation provider, gaming content supplier, platform provider, or media affiliate to support the operation, conduct, or promotion of online sweepstakes games within the state of New York.\n>\n> — [N.Y. Racing, Pari-Mutuel Wagering & Breeding Law § 912(2)(b)](https:\u002F\u002Fnyassembly.gov\u002Fleg\u002F?default_fld=&leg_video=&bn=S05935&term=2025&Summary=Y&Actions=Y&Text=Y)\n\nThere is no “knowingly and willfully” in New York’s text. A vendor’s knowledge is not an element of the prohibition.\n\nThe penalties differ in the same direction. California makes a violation a misdemeanor, with a fine of $1,000 to $25,000, up to a year in county jail, or both. New York sets a fine of $10,000 to $100,000 for each violation and puts a gaming license at risk.\n\n## How operators have adapted\n\nThe operators’ exclusion lists follow the routes. Stake.us’s terms now exclude 22 states, New York, California, Tennessee and Illinois among them, and its own change log records ten versions adding states between February 20, 2025 and July 10, 2026. The latest four:\n\n> Version 15.0 30\u002F12\u002F2025 Addition of further State to \"Excluded Territories\". Version 16.0 19\u002F05\u002F2026 Addition of further State to \"Excluded Territories\". Version 17.0 01\u002F07\u002F2026 Addition of further State to \"Excluded Territories\". Version 18.0 10\u002F07\u002F2026 Addition of further State to \"Excluded Territories\".\n>\n> — [Stake.us Terms & Conditions, version history](https:\u002F\u002Fstake.us\u002Fpolicies\u002Fterms)\n\n[Video: Stake.us’s lobby as it loads in New York without an account: most games read “Not available in your state.”](https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fstake-us-lobby.mp4)\n\nStake.us told California customers it would leave from December 30, 2025. Chumba’s and High 5’s current rules both exclude New York, California and Tennessee.\n\n## What a builder does with this\n\n- Sort states by route, not by count. A state that defines the product by its structure cannot be answered with an entry method.\n- Treat the free method of entry as one part of the compliance case, not the whole of it. New York’s definition does not reach it, Illinois’s release does not mention it, and California counts the free coin as consideration.\n- Check every vendor in the stack, from payments to geolocation to content to platform, against the states that name suppliers. New York’s supplier provision has no knowledge requirement, so vendor diligence carries more weight there.\n\nA free method of entry answers one element of one test. The route a state took decides whether it matters at all.\n\n## Sources\n\n- [New York S5935-A (L. 2025, ch. 605): adds Racing, Pari-Mutuel Wagering and Breeding Law § 912](https:\u002F\u002Fnyassembly.gov\u002Fleg\u002F?default_fld=&leg_video=&bn=S05935&term=2025&Summary=Y&Actions=Y&Text=Y)\n- [California AB 831 (Stats. 2025, ch. 623): adds Penal Code § 337o; amends Business and Professions Code § 17539.1](https:\u002F\u002Fleginfo.legislature.ca.gov\u002Ffaces\u002FbillTextClient.xhtml?bill_id=202520260AB831)\n- [Tennessee Attorney General’s Office, press release PR25-61 (Dec. 29, 2025)](https:\u002F\u002Fwww.tn.gov\u002Fattorneygeneral\u002Fnews\u002F2025\u002F12\u002F29\u002Fpr25-61.html)\n- [Illinois Gaming Board, press release: cease-and-desist letters to illegal online casino and sweepstakes operators (Feb. 5, 2026)](https:\u002F\u002Fwww.illinois.gov\u002Fcontent\u002Fdam\u002Fsoi\u002Fen\u002Fweb\u002Fillinois\u002Fiisnewsattachments\u002F32173-020526-igb-r-cease-and-desist-online-casinos-final-25025.pdf.pdf)\n- [Stake.us, Terms & Conditions, version 18.0 (July 10, 2026)](https:\u002F\u002Fstake.us\u002Fpolicies\u002Fterms)\n- [SweepsKings, “Stake.us and Rolling Riches Announce California Exits” (Nov. 12, 2025), quoting Stake.us’s customer email](https:\u002F\u002Fsweepskings.com\u002Fnews\u002Fstake-rollingriches-announce-california-exits\u002F)\n- [Chumba Casino (VGW), Sweeps Rules, version 26.1 (Sept. 16, 2026)](https:\u002F\u002Fedge.sitecorecloud.io\u002Fvgwholdings89e8-vgw-prod-817c\u002Fmedia\u002F260916_POL_CHU_Sweeps_Rules_26-1.pdf)\n- [High 5 Casino, Sweepstakes Official Rules, version 43.0 (June 26, 2026)](https:\u002F\u002Fhigh5casino.com\u002Fsweepstakes-rules)","regulatory_update",[12,13],"apparently_law","sweepstakes","https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fsweeps-stake-us-terms-stake-cash.jpg",null,"K. Aaron Pasch, CFA, JD",6,true,"2026-09-22T12:00:00+00:00",4,"2026-10-02T02:00:07.3006+00:00","2026-10-03T01:00:01.318+00:00",[24,27,30,32,47,63,72,99,101,119,121,142,149,151,153,166,168,181,183,185,200,202,214,216,218,220,231,239,241,243,249],{"text":25,"type":26},"Every state that has acted on sweepstakes casinos has had to deal with the same argument: that a free way to get the prize currency removes the payment a lottery requires. New York, California, Tennessee and Illinois each dealt with it differently, and the route a state took decides what an operator, or a vendor serving one, has to answer.","p",{"text":28,"type":29},"The argument each state had to meet","h2",{"text":31,"type":26},"Stake.us, the sweepstakes brand of the Stake group, states the operators’ position in its own terms. The paid currency is Gold Coins; the prize currency is Stake Cash, which is never sold:",{"url":33,"kind":34,"note":15,"text":35,"type":36,"source":37,"segments":38,"highlights":46},"https:\u002F\u002Fstake.us\u002Fpolicies\u002Fterms","operator-terms","2.4. THE PLATFORM AND GAMES DO NOT OFFER REAL MONEY GAMBLING, AND NO ACTUAL MONEY IS REQUIRED TO PLAY.","excerpt","Stake.us Terms & Conditions v18.0, cl. 2.4",[39,42,44],{"mark":40,"text":41},false,"2.4. THE PLATFORM AND GAMES ",{"mark":18,"text":43},"DO NOT OFFER REAL MONEY GAMBLING",{"mark":40,"text":45},", AND NO ACTUAL MONEY IS REQUIRED TO PLAY.",[43],{"url":33,"kind":34,"note":48,"text":49,"type":36,"source":50,"segments":51,"highlights":62},"The prize currency is never sold, and a postcard yields five of it. That is the free-entry argument in two clauses. Each state below reads the product differently.","b) YOU CANNOT PURCHASE STAKE CASH.STAKE CASH CAN BE OBTAINED ONLY THROUGH FREE, PROMOTIONAL OFFERS. … iii) Post Card – Customers can receive 5 free Stake Cash by sending a standard postcard on the terms set out in the clause 8.3.","Stake.us Terms & Conditions v18.0, cl. 8.1(b), 8.2(a)",[52,54,56,58,60],{"mark":40,"text":53},"b) ",{"mark":18,"text":55},"YOU CANNOT PURCHASE STAKE CASH",{"mark":40,"text":57},".STAKE CASH CAN BE OBTAINED ONLY THROUGH FREE, PROMOTIONAL OFFERS. … iii) Post Card – Customers can receive ",{"mark":18,"text":59},"5 free Stake Cash by sending a standard postcard",{"mark":40,"text":61}," on the terms set out in the clause 8.3.",[55,59],{"src":64,"url":33,"type":65,"poster":14,"caption":66,"product":67,"seconds":68,"operator":69,"recorded":70,"recordedFrom":71},"https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fsweeps-stake-us-terms-stake-cash.mp4","demo","Stake.us’s Terms & Conditions at clause 8, with the site’s chat panel hidden: Stake Cash used only for Promotional Play, “YOU CANNOT PURCHASE STAKE CASH”, and the free routes in 8.2, from the daily login bonus to five Stake Cash by postcard.","Stake.us Terms & Conditions, clause 8 (Stake Cash)",25,"Stake.us","2026-09-30","Public page, no account; recorded from New York; headless browser",{"head":73,"rows":78,"type":98,"caption":15},[74,75,76,77],"State","Instrument","Date","How it answers the free method of entry",[79,84,89,94],[80,81,82,83],"New York","Statute: S5935-A (L. 2025, ch. 605), Racing, Pari-Mutuel Wagering and Breeding Law § 912","Signed December 5, 2025","Defines the game by its structure. The definition contains no consideration test, so the free route is never reached.",[85,86,87,88],"California","Statute: AB 831 (Stats. 2025, ch. 623), Penal Code § 337o","Approved October 11, 2025","Keeps the element and counts the free coin as “indirect consideration”.",[90,91,92,93],"Tennessee","Cease-and-desist letters under existing law","December 29, 2025","Treats the model as an illegal lottery prohibited by the Tennessee Constitution.",[95,91,96,97],"Illinois","February 5, 2026","Treats internet games of chance that award money or items of value as a crime. Consideration is not mentioned.","table",{"text":100,"type":29},"New York: define the product, skip the element",{"url":102,"kind":103,"note":104,"text":105,"type":36,"source":106,"segments":107,"highlights":118},"https:\u002F\u002Fnyassembly.gov\u002Fleg\u002F?default_fld=&leg_video=&bn=S05935&term=2025&Summary=Y&Actions=Y&Text=Y","statute","No part of the definition asks whether a free entry exists. A postcard route changes nothing under this text.","(a) \"Online sweepstakes game\" shall mean any game, contest, or promotion that is available on the internet and\u002For accessible on a mobile phone, computer terminal, or similar access device, that utilizes a dual-currency system of payment allowing the player to exchange the currency for any cash prize, cash award or cash equivalents, or any chance to win any cash prize, cash award or cash equivalents, and simulates casino-style gaming, including but not limited to, slot machines, video poker, table games, lottery games, bingo, or sports wagering.","N.Y. Racing, Pari-Mutuel Wagering & Breeding Law § 912(1)(a), added by S5935-A",[108,110,112,114,116],{"mark":40,"text":109},"(a) \"Online sweepstakes game\" shall mean any game, contest, or promotion that is available on the internet and\u002For accessible on a mobile phone, computer terminal, or similar access device, that ",{"mark":18,"text":111},"utilizes a dual-currency system of payment allowing the player to exchange the currency for any cash prize, cash award or cash equivalents",{"mark":40,"text":113},", or any chance to win any cash prize, cash award or cash equivalents, and ",{"mark":18,"text":115},"simulates casino-style gaming",{"mark":40,"text":117},", including but not limited to, slot machines, video poker, table games, lottery games, bingo, or sports wagering.",[111,115],{"text":120,"type":29},"California: count the free coin",{"url":122,"kind":103,"note":123,"text":124,"type":36,"source":125,"segments":126,"highlights":141},"https:\u002F\u002Fleginfo.legislature.ca.gov\u002Ffaces\u002FbillTextClient.xhtml?bill_id=202520260AB831","A prize coin handed out “as a bonus upon the purchase of specifically marked packs” of the paid coin is the pattern this definition describes, and the paid coin is itself named as the “related product”.","(1) “Direct consideration” means a coin, token, or other representation of value that may be purchased by a player or received through a bonus or promotion and that is used for playing or participating in the online sweepstakes game. (2) “Indirect consideration” means a coin, token, or other representation of value that may be exchanged for a prize, award, cash, or cash equivalents or a chance to win a prize, award, cash, or cash equivalents. Indirect consideration is provided for free through a promotion, bonus, or with the purchase of a related product, service, or activity. As used in this paragraph, “related product, service, or activity” includes a coin, token, or other representation of value that may be used for direct consideration.","Cal. Penal Code § 337o(c)(1)–(2), added by AB 831",[127,129,131,133,135,137,139],{"mark":40,"text":128},"(1) “Direct consideration” means a coin, token, or other representation of value that ",{"mark":18,"text":130},"may be purchased by a player or received through a bonus or promotion",{"mark":40,"text":132}," and that is used for playing or participating in the online sweepstakes game. (2) “Indirect consideration” means a coin, token, or other representation of value that may be exchanged for a prize, award, cash, or cash equivalents or a chance to win a prize, award, cash, or cash equivalents. ",{"mark":18,"text":134},"Indirect consideration is provided for free through a promotion, bonus, or with the purchase of a related product, service, or activity",{"mark":40,"text":136},". As used in this paragraph, “related product, service, or activity” ",{"mark":18,"text":138},"includes a coin, token, or other representation of value that may be used for direct consideration",{"mark":40,"text":140},".",[130,134,138],{"src":143,"url":144,"type":65,"poster":145,"caption":146,"product":147,"seconds":68,"operator":148,"recorded":70,"recordedFrom":71},"https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fsweeps-chumba-purchase-offers.mp4","https:\u002F\u002Fwww.chumbacasino.com\u002Fpromotions","https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fsweeps-chumba-purchase-offers.jpg","Chumba’s public Promotions page: a top banner offering GC10M for $10 “plus FREE SC30”, then the Purchase offers section with a welcome offer of GC 2,000,000 + SC 2. A paid Gold Coin pack with Sweeps Coins added is the pairing this definition describes.","Chumba Casino Promotions page","VGW",{"text":150,"type":29},"Tennessee and Illinois: existing law, two theories",{"text":152,"type":26},"Neither state needed a new statute. Tennessee reads its constitution as a lottery ban and addresses consideration directly:",{"url":154,"kind":155,"note":15,"text":156,"type":36,"source":157,"segments":158,"highlights":165},"https:\u002F\u002Fwww.tn.gov\u002Fattorneygeneral\u002Fnews\u002F2025\u002F12\u002F29\u002Fpr25-61.html","attorney-general","The promotional sweepstakes model used by these casinos constitutes an illegal lottery prohibited by the Tennessee Constitution and violates Tennessee gambling and consumer-protection laws.","Tennessee Attorney General, press release PR25-61 (Dec. 29, 2025)",[159,161,163],{"mark":40,"text":160},"The promotional sweepstakes model used by these casinos ",{"mark":18,"text":162},"constitutes an illegal lottery prohibited by the Tennessee Constitution",{"mark":40,"text":164}," and violates Tennessee gambling and consumer-protection laws.",[162],{"text":167,"type":26},"Illinois reads its criminal law as an internet-gambling ban, and the free method of entry is never reached:",{"url":169,"kind":170,"note":15,"text":171,"type":36,"source":172,"segments":173,"highlights":180},"https:\u002F\u002Fwww.illinois.gov\u002Fcontent\u002Fdam\u002Fsoi\u002Fen\u002Fweb\u002Fillinois\u002Fiisnewsattachments\u002F32173-020526-igb-r-cease-and-desist-online-casinos-final-25025.pdf.pdf","regulator","Offering games of chance that award money or other items of value via the internet violates Illinois criminal law.","Illinois Gaming Board, press release (Feb. 5, 2026)",[174,176,178],{"mark":40,"text":175},"Offering ",{"mark":18,"text":177},"games of chance that award money or other items of value via the internet",{"mark":40,"text":179}," violates Illinois criminal law.",[177],{"text":182,"type":29},"The supply chain is inside the statutes",{"text":184,"type":26},"Both statutes reach past the operator. California requires a state of mind:",{"url":122,"kind":103,"note":15,"text":186,"type":36,"source":187,"segments":188,"highlights":199},"(b) It is unlawful for any entity, financial institution, payment processor, geolocation provider, gaming content supplier, platform provider, or media affiliate to knowingly and willfully support directly or indirectly the operation, conduct, or promotion of an online sweepstakes game within this state.","Cal. Penal Code § 337o(b)",[189,191,193,195,197],{"mark":40,"text":190},"(b) It is unlawful for any entity, financial institution, ",{"mark":18,"text":192},"payment processor, geolocation provider, gaming content supplier, platform provider, or media affiliate",{"mark":40,"text":194}," to ",{"mark":18,"text":196},"knowingly and willfully",{"mark":40,"text":198}," support directly or indirectly the operation, conduct, or promotion of an online sweepstakes game within this state.",[192,196],{"text":201,"type":26},"New York does not:",{"url":102,"kind":103,"note":203,"text":204,"type":36,"source":205,"segments":206,"highlights":213},"There is no “knowingly and willfully” in New York’s text. A vendor’s knowledge is not an element of the prohibition.","(b) It shall be unlawful for any applicant, licensed entity, financial institution, payment processor, geolocation provider, gaming content supplier, platform provider, or media affiliate to support the operation, conduct, or promotion of online sweepstakes games within the state of New York.","N.Y. Racing, Pari-Mutuel Wagering & Breeding Law § 912(2)(b)",[207,209,211],{"mark":40,"text":208},"(b) It shall be unlawful for any applicant, licensed entity, financial institution, ",{"mark":18,"text":210},"payment processor, geolocation provider, gaming content supplier, platform provider, or media affiliate to support",{"mark":40,"text":212}," the operation, conduct, or promotion of online sweepstakes games within the state of New York.",[210],{"text":215,"type":26},"The penalties differ in the same direction. California makes a violation a misdemeanor, with a fine of $1,000 to $25,000, up to a year in county jail, or both. New York sets a fine of $10,000 to $100,000 for each violation and puts a gaming license at risk.",{"text":217,"type":29},"How operators have adapted",{"text":219,"type":26},"The operators’ exclusion lists follow the routes. Stake.us’s terms now exclude 22 states, New York, California, Tennessee and Illinois among them, and its own change log records ten versions adding states between February 20, 2025 and July 10, 2026. The latest four:",{"url":33,"kind":34,"note":15,"text":221,"type":36,"source":222,"segments":223,"highlights":230},"Version 15.0 30\u002F12\u002F2025 Addition of further State to \"Excluded Territories\". Version 16.0 19\u002F05\u002F2026 Addition of further State to \"Excluded Territories\". Version 17.0 01\u002F07\u002F2026 Addition of further State to \"Excluded Territories\". Version 18.0 10\u002F07\u002F2026 Addition of further State to \"Excluded Territories\".","Stake.us Terms & Conditions, version history",[224,226,228],{"mark":40,"text":225},"Version 15.0 30\u002F12\u002F2025 ",{"mark":18,"text":227},"Addition of further State to \"Excluded Territories\"",{"mark":40,"text":229},". Version 16.0 19\u002F05\u002F2026 Addition of further State to \"Excluded Territories\". Version 17.0 01\u002F07\u002F2026 Addition of further State to \"Excluded Territories\". Version 18.0 10\u002F07\u002F2026 Addition of further State to \"Excluded Territories\".",[227],{"src":232,"url":233,"type":65,"poster":234,"caption":235,"product":236,"seconds":68,"operator":69,"recorded":237,"recordedFrom":238},"https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fstake-us-lobby.mp4","https:\u002F\u002Fstake.us\u002Fcasino\u002Fhome","https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch-media\u002Fstake-us-lobby.jpg","Stake.us’s lobby as it loads in New York without an account: most games read “Not available in your state.”","Casino lobby","2026-09-28","Public page, no account; recorded from New York",{"text":240,"type":26},"Stake.us told California customers it would leave from December 30, 2025. Chumba’s and High 5’s current rules both exclude New York, California and Tennessee.",{"text":242,"type":29},"What a builder does with this",{"type":244,"items":245},"ul",[246,247,248],"Sort states by route, not by count. A state that defines the product by its structure cannot be answered with an entry method.","Treat the free method of entry as one part of the compliance case, not the whole of it. New York’s definition does not reach it, Illinois’s release does not mention it, and California counts the free coin as consideration.","Check every vendor in the stack, from payments to geolocation to content to platform, against the states that name suppliers. New York’s supplier provision has no knowledge requirement, so vendor diligence carries more weight there.",{"text":250,"type":26},"A free method of entry answers one element of one test. The route a state took decides whether it matters at all.",[252,254,256,258,260,262,265,268],{"url":102,"title":253},"New York S5935-A (L. 2025, ch. 605): adds Racing, Pari-Mutuel Wagering and Breeding Law § 912",{"url":122,"title":255},"California AB 831 (Stats. 2025, ch. 623): adds Penal Code § 337o; amends Business and Professions Code § 17539.1",{"url":154,"title":257},"Tennessee Attorney General’s Office, press release PR25-61 (Dec. 29, 2025)",{"url":169,"title":259},"Illinois Gaming Board, press release: cease-and-desist letters to illegal online casino and sweepstakes operators (Feb. 5, 2026)",{"url":33,"title":261},"Stake.us, Terms & Conditions, version 18.0 (July 10, 2026)",{"url":263,"title":264},"https:\u002F\u002Fsweepskings.com\u002Fnews\u002Fstake-rollingriches-announce-california-exits\u002F","SweepsKings, “Stake.us and Rolling Riches Announce California Exits” (Nov. 12, 2025), quoting Stake.us’s customer email",{"url":266,"title":267},"https:\u002F\u002Fedge.sitecorecloud.io\u002Fvgwholdings89e8-vgw-prod-817c\u002Fmedia\u002F260916_POL_CHU_Sweeps_Rules_26-1.pdf","Chumba Casino (VGW), Sweeps Rules, version 26.1 (Sept. 16, 2026)",{"url":269,"title":270},"https:\u002F\u002Fhigh5casino.com\u002Fsweepstakes-rules","High 5 Casino, Sweepstakes Official Rules, version 43.0 (June 26, 2026)","https:\u002F\u002Fwww.apparentlylaw.com\u002Fresearch\u002Fsweepstakes-casinos-four-states-four-routes",[273,279,285],{"slug":274,"title":275,"excerpt":276,"published_at":277,"read_minutes":278},"prediction-markets-conflicts-and-affiliations","Prediction markets: the CFTC’s proposal on affiliated market makers","The CFTC has proposed rules for exchanges whose own affiliate trades on them, and it names prediction markets as the place the question matters most. What the proposal would require, what one exchange’s rulebook says today, and how to comment by October 5, 2026.","2026-10-02T12:00:00+00:00",5,{"slug":280,"title":281,"excerpt":282,"published_at":283,"read_minutes":284},"sweepstakes-casinos-florida-sues-operators-and-payment-processors","Sweepstakes casinos: Florida sues the operators and their payment processors","On August 19, Florida’s Attorney General sued VGW and Stake.us, and named five payment companies as co-defendants under a 1951 gambling-loss statute. What the complaints allege, what they do not, and what it changes for vendors.","2026-09-25T12:00:00+00:00",7,{"slug":286,"title":287,"excerpt":288,"published_at":289,"read_minutes":284},"sweepstakes-casinos-founders-checklist","Sweepstakes casinos: a founder’s checklist","Eight questions to answer before launch, in the order the answers depend on each other — each with the statute that makes it matter and an operator’s own written answer.","2026-09-24T12:00:00+00:00"]