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The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.
The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.
Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.
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Other clubs that hold agreements with unlicensed operators include Chelsea (8XBet), Tottenham Hotspur (VSBet) and Nottingham Forest (FUN88).
Entain highlighted data from H2 Gambling Capital that warned black market stakes in the UK are expected to nearly double from £17 billion ($22.7 billion) in 2025 to over £33 billion by 2028.
Entain emphasised offshore operators do not employ the same player protection measures and anti-money laundering standards that licensed companies must.
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Papaya concedes that it cannot immediately pay the $719 million judgment, arguing that allowing the company to pay the penalty over multiple years would “preserve … the rights of all parties.”
Papaya games consist of Solitaire Cash, Bingo Cash, and Bubble Cash.
Skillz argues in its court petition that Chapter 15, which governs cross-border insolvency proceedings involving foreign companies operating in the U.S., shouldn’t apply.
