Why a top IOC executive is coming to Utah
The organizers of Utah's next Olympics are in 'a very unusual situation,' IOC Olympic Games Executive Director Christophe Dubi told the Deseret News Tuesday in a virtual interview from the organization's Swiss headquarters.
'We have a 10 years' life span. We have very little to do on the fundamentals for the Games, that is, the venues,' since the facilities from the 2002 Winter Games are set to be used again. 'We have what you know is a perfect situation.'
'What are the first programs we're going to tackle and deliver, so that we start involving the communities and kids in particular?'
— IOC Olympic Games Executive Director Christophe Dubi
So what's there to talk about during his two-day visit that follows a stop in Los Angeles, the host of the 2028 Summer Games?
Plenty, it turns out.
Utah has yet to announce an organizing committee for the Olympic Games, even though the host contract signed by Gov. Spencer Cox after last year's July 24 IOC vote set a Christmas Eve deadline for putting what's known as an OCOG in place.
That's coming 'pretty soon,' Dubi said. 'We're having now regular conversations in every shape and form.'
But he also wants to know how Utah will use the time it's been given under the new, less formal bid process to organize another Winter Games. Previously, organizers had just seven years to get ready for one of the world's largest sporting events.
There needs to be a decision 'on the priorities in what is the land of opportunity,' Dubi said. 'What are the first programs we're going to tackle and deliver, so that we start involving the communities and kids in particular?'
Detailed planning, he said, can wait.
'It's urgent to wait with respect to Games organization,' Dubi said, the same advice he offered nearly a year ago during an inspection tour of Utah's Olympic venues, citing the advances to come in artificial intelligence and other technology.
He said preparation also need to get underway to ensure Utah's Olympic organizers get the most out of the 2026 Winter Games in Milan-Cortina, Italy, just a year away. That includes figuring out who needs to go, Dubi said.
'It sounds a long time, a year, except that we are operating over a very large territory. The plans have to be extremely well designed' for the Utah observers in Italy, he said. 'It has to be planned now.'
Unlike Utah's compact Olympics, where every venue is within an hour of the athlete housing at the University of Utah in Salt Lake City, the Milan-Cortina Games are spread across a wide swath of Italy.
That means the lessons there for Utah organizers won't be about logistics like transporting athletes from Point A to Point B, Dubi said.
'The geographical distribution is so different that this is absolutely not what they're going to be looking at,' he said. Instead, Dubi suggested Utahns focus instead on what Italians are bringing to the Olympics.
'It's the way the Italians will deliver in each and every venue,' he said, bringing the spirit of the Games to the streets just as Paris' 2024 Summer Games did. 'It's the experience you can deliver if your are generous enough to have not only the venues hosting the best sport.'
Closing streets, providing gathering places for the public and 'offering the best possible hospitality outside of the best possible field of play. This is where Italians will be really, really good,' Dubi said. 'You have to be part of the best of what winter sports can offer.'
In Utah, he said, 'it will have a different flavor, different color, different music, different everything. But what you're looking for as a participant is that warmth, and that feeling of being part of something very special.'
Whether felt as an athlete, a volunteer or a spectator, that's 'a once in a lifetime experience.'
Fraser Bullock, president and CEO of the Salt Lake City-Utah Committee for the Games that was behind the bid, said he's looking forward to the visit by Dubi and his team, calling the IOC executive 'a great friend going back to our partnership together in 2002.'
Bullock said they'll 'begin the early phase of outlining our integrated planning process. They have deep knowledge in many areas that will help us ensure we put on the best Games possible.'
He stopped short of saying the organizing committee will be announced during Dubi's visit, set for Feb. 13 and 14. Bullock, who's 69, is expected to be named the leader of the OCOG while setting up a successor.
A new bill introduced this session at the Utah Legislature would require the governor and legislative leaders to sign off on the head of the organizing committee. Utah taxpayers are the guarantor of the privately funded Games expected to cost a total of $4 billion.
'I really like the way that is being approached,' Dubi said, since 'an organizing committee is always a public-private partnership' that needs the 'consent of those backing and those that will support the Games.'
The IOC would also expect to be 'consulted, and comfortable with the choice,' he said, describing Bullock as 'someone I always very much admire and consider as a friend. He's a very special individual, for sure.'
Dubi said Utah's organizing committee will likely be similar to the one that oversaw the 2002 Winter Games. Unlike in the rest of the world, the organization responsible for staging a Games in the United States is entirely privately financed.
The 2030 Winter Games in the French Alps, for example, already has funding committed from regional and national authorities, but the 'economic capacity' of the United States is much larger compared to the European market, he said.
'It's incredible, the support you have' for sport, Dubi said, including from wealthy donors. 'It's only in the U.S.' He said there's 'dynamism' that comes from a private organization that has the backing of public authorities.
That includes U.S. President Donald Trump. Just days before being sworn in, Trump pledged his support for the Los Angeles Games during a meeting at his Mar-a-Lago estate in Florida with Casey Wasserman, LA28's president and chairman.
'These are America's Olympics,' Trump told Wasserman, according to a report in Axios based on an unnamed source. 'These are more important than ever to L.A. and I'm going to be supportive in every way possible and make them the greatest Games.'
Dubi said that 'shows the commitment of Washington to what for sure will be extraordinary Games' in a city that has seen more than 10,000 homes destroyed and at least 29 lives lost in the recent wildfires.
'Our hearts and minds go to all those that have been affected. But at the same time, with this very American spirit, which is in such adversity, fight back and demonstrate that we can come back stronger,' Dubi said. 'This is something cultural deep-rooted in the U.S.'
The Olympics being held twice in the United States within a six-year span reflects the IOC's level of trust and the quality of the relationship, he said. To him, the United States means opportunities.
'What do we invent in Los Angeles in what is the most buzzing of the entertainment and sports market,' Dubi asked, before returning to the site of the 'extraordinary' 2002 Winter Games, in 2034.
'What do we invent for these Games,' he said, calling Utah a place 'where the conditions are perfect.'
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Among the key findings: 90% of sweepstakes casino users consider the activity to be gambling; 68% say their primary reason for playing is to win real money; and 69% describe sweepstakes casinos as platforms to wager real money. As the California Court of Appeals appropriately observed in Lockyer v. Pacific Gaming Technologies, in referring to a slot machine-style sweepstakes promotion, 'if it looks like a duck, walks like a duck, and sounds like a duck, it is a duck. And so it is with this duck.' 2. Perpetual duration A traditional sweepstakes promotion 'is a limited-term event designed to attract consumer attention to a product or a business, and ordinarily expires after a few weeks or months.' For sweepstakes casinos, on the other hand, the sweepstakes games run perpetually. This distinction has been cited by courts and state attorneys general as a critical factor in determining that a sweepstakes promotion was in fact a guise for illegal gambling. For example, in Barber v. Jefferson County Racing Assoc., Inc., the Alabama Supreme Court found that the perpetual duration of a slot machine-style sweepstakes promotion was indicative of its 'true purpose,' which was to legitimize illegal gambling. As the Barber Court explained, 'the duration of 'promotional sweepstakes occasionally offered by fast food chains, or in connection with candy, sodas, miscellaneous food or other established retail products,' is typically 'limited,' as opposed to the duration of the MegaSweeps, which is indefinite.' Likewise, in a 2001 opinion, the South Carolina Attorney General described perpetual game promotions connected with the sale of two-minute phone cards as 'mere ruses' to avoid state gambling laws since the cards were never sold without the attached game pieces, suggesting that 'the consumer was really buying the opportunity to win a prize.' 'True promotional games, such as those offered by McDonald's and other legitimate business concerns,' the Attorney General observed, 'are always brief or temporary in duration, and the vast majority of the consumer product or service is always sold with no game of chance involved.' More recently, the Louisiana Attorney General pointed to the 'perpetual duration' and 'ongoing nature' of the games as an indication that the 'true purpose' of online sweepstakes casinos was to promote illegal gambling. Based in part on this characteristic, the Louisiana Attorney General concluded that 'online businesses offering casino-style games—purporting to be sweepstakes or social gaming platforms—are operating in violation of Louisiana law.' 3. High Payout Percentages The typical payout percentage for a temporary promotional sweepstakes is 'a trivial share of the revenue earned by the company.' For example, the grand prize for McDonald's annual Monopoly-themed sweepstakes is usually about $1 million, which is a tiny fraction of the billions of dollars that McDonald's earns each year. By contrast, online sweepstakes casinos claim to pay out in prize money between 80-96% of their revenues; notably, slot machines at commercial casinos typically pay out between 80 to 95 percent (depending on the state). The highest courts of two states have pointed to the high payout percentage of a sweepstakes as indicative of a gambling scheme. In Barber, the Alabama Supreme Court noted that the 92% payout rate for the MegaSweeps promotion 'coincides with the industry standard for casino-style slot machines, which 'typically pay back 90% to 98% of all money played. By contrast, the typical payout percentage for a 'temporary promotional sweepstakes' is 'one half of one percent.'' The Barber Court found that 'the payout percentage and duration of the operation are indicative of 'the true purpose of the game,' which is to promote gambling. Likewise, in Midwestern Enterprises, Inc. v. Stenehjem, the North Dakota Supreme Court addressed a telephone card vending machine that dispensed a two-minute telephone card, plus a chance to win up to $500 in cash for every dollar paid. The telephone card vending machine incorporated visual and audio 'gambling features,' and randomly dispensed a chance for cash prizes with each dollar risked, with a pay-out rate of 65%. The North Dakota Supreme Court characterized this 'high payout rate' as 'a distinguishing feature because it goes to the true purpose of the game,' which, again, was to promote gambling. 4. Sweeps Coins correspond nearly 1:1 with dollars spent The pricing structure also makes clear that the primary subject of the transaction is to facilitate the sale of Sweeps Coins. While players can receive a limited number of Sweeps Coins for free through mail-ins, giveaways and other promotions, by far the most common way to obtain Sweeps Coins beyond a nominal amount is by purchasing Gold Coins. The more Gold Coins that a player purchases, the more Sweeps Coins the player also receives. Critically, the number of Sweeps Coins received as a 'free' bonus corresponds with the amount of real money spent. As the Louisiana Attorney General noted, there is essentially a 1:1 correlation between the number of dollars spent and the number of Sweeps Coins provided in each purchase. So, for example, if someone buys a coin bundle for $30, they will typically receive 30 Sweeps Coins in addition to thousands of Gold Coins. The 1:1 equivalency between dollars spent and Sweeps Coins received — coupled with their redeemability into dollars on a 1:1 basis following successful play — indicates that, at least from the customers' perspective, they are paying in large part to acquire Sweeps Coins to engage in real-money gambling. This is the same artifice that was used by 'Internet sweepstakes cafés' over a decade ago to offer real money casino-style gaming under the guise of a sweepstakes promotion. These gambling operations – often located in suburban strip malls – would claim to sell Internet access time to consumers and, as part of an alleged 'sweepstakes promotion,' consumers would receive a corresponding number of 'sweepstakes points' for each dollar spent on the service. These 'points' – which were redeemable for cash – would then be used to wager on casino-style games that were played on computer terminals provided at the Internet cafés. Courts throughout the country have repeatedly determined that such tactics were an obvious pretext and cover for illegal gambling. For example, in Telesweeps of Butler Valley, Inc. v. Kelley, a Pennsylvania federal district court held that the purchase of a long-distance telephone card that comes with a commensurate number of free entries to participate in a 'casino-style' sweepstakes constituted 'indirect consideration' to participate in the sweepstakes, even though (like here) no purchase was necessary and several alternative methods of free entry were available. In rejecting the defendant's argument that the customer was simply paying for long-distance telephone calling minutes and not the sweepstakes entries, the Court declared that 'plaintiff's attempt to separate the consideration from the chance to win by inserting a step between the two elements is clever, but it merely elevates form over substance. At bottom, what Telesweeps is doing constitutes gambling.' A similar sweepstakes scheme was addressed by an Ohio appellate court in Cleveland v. Thorne, where patrons received 100 sweepstakes points for every $1 spent on network access time and could use those points to play simulated 'casino-style' games at the defendants' internet sweepstakes cafés, and, following successful play, could exchange their 'winning points' for cash at a value of one cent per point. On appeal following a criminal conviction for operating a gambling house in violation of Ohio's anti-gambling laws, the defendants argued that the network access time was a 'valuable product that patrons paid for and received' and 'the sweepstakes points were given free as a promotion and had no actual value.' In affirming the defendants' convictions, the Ohio Court of Appeals memorably stated that 'the justice system is not some lumbering oaf who must ignore the patently obvious gambling scheme apparent here simply because of a contrived separation between consideration and the scheme of chance.' The Ohio appellate court declared that '[t]he law in this arena serves no purpose to elevate form to such a high degree that the nature of the transaction should be ignored,' adding that 'there is no justification for ignoring the nature of the transaction simply because the system is designed in such a way as to artificially isolate one part of the illegal transaction from another. The justice system is not so blinded by chicanery.' Online sweepstakes casinos 'are utilizing the same concept,' the Louisiana Attorney General wrote. Just like the Internet sweepstakes cafés found to be illegal gambling businesses in Telesweeps and Thorne, online sweepstakes casinos artificially separate the consideration from the chance to win real money by claiming that the payment is for a 'product' (i.e., Gold Coins) and the sweepstakes entries (i.e., Sweeps Coins) are 'free,' while conveniently providing the purchaser with an allotment of Sweeps Coins that is equivalent in value to the amount of money spent. The nearly 1:1 ratio of Sweeps Coins to dollars spent sends a clear and unmistakable message to consumers interested in real-money casino gambling – i.e., that they can just ignore the Gold Coins and focus instead on the Sweeps Coins allotment (in essence, paying $30 for 30 Sweeps Coins). As to those customers, the 'controlling inducement' for the transaction is clearly 'the lure of an uncertain prize' – a characteristic which the Texas Attorney General has declared is synonymous with an illegal lottery. 5. Restrictions on the ability to redeem prizes Conditions designed to keep customers playing longer are indicative that the true purpose of the sweepstakes is to promote gambling, as opposed to a good or service. Unlike traditional sweepstakes where prizes can be claimed immediately, most online sweepstakes casinos have a 'minimum permitted redemption' threshold that limits a user's ability to redeem prizes unless their Sweeps Coins balance is above a certain amount. In most cases, the withdrawal threshold is 100 Sweeps Coins. Thus, if a customer never reaches 100 Sweeps Coins won, they can never redeem anything. This causes consumers to continue playing and eventually lose their remaining Sweeps Coins balance, leading them to purchase more Gold Coin packages just to get an additional allotment of 'free' Sweeps Coins in order to continue playing. This is further compounded by a 'playthrough requirement,' which refers to the number of times that a user must play through his or her allotted Sweeps Coins before they become eligible for redemption. For example, if a user receives 100 Sweeps Coins and those Sweeps Coins have a playthrough requirement multiplier of 2x, a user must play games totaling 200 Sweeps Coins prior to those coins being eligible for redemption as a prize. Many online sites have a 2x or greater playthrough requirement multiplier, with the discretion to increase the multiplier up to a maximum of 20x. This requires users to continue playing – even after a successful first spin – and increases the likelihood that they will gamble – and lose – all of their remaining Sweeps Coins, leading them to purchase even more Gold Coins (just to get an additional allotment of 'free' Sweeps Coins as a bonus) in an effort to try to satisfy both the playthrough requirement and a restarted minimum permitted redemption threshold. The Fifth Circuit has declared that conditions designed to keep patrons playing longer are indicative of the 'true purpose' of the transaction being the promotion of the sweepstakes, not the purported 'product' or 'service.' In United States v. Davis, the Fifth Circuit, applying Texas law, found the evidence established that 'the defendants' true purpose for the cafés was to create a place where people would be comfortable staying for a long time, purchasing Internet time and playing the sweepstakes' in a 'casino-like atmosphere.' Thus, the Fifth Circuit concluded that 'the main purpose and function' of the business 'was to induce people to play the sweepstakes, and that the Internet time sold by the cafés—albeit at fair market value—was not the primary subject of the transaction, but instead mere subterfuge.' 6. Customers value sweepstakes entries more than the product The degree to which customers valued the sweepstakes entries over the promoted product is also indicative of whether the true purpose of the transaction is to promote sweepstakes play. In United States v. Davis, the Fifth Circuit recited the following evidence as indicia that consideration fueled the sweepstakes: A review of customers' account activity and game-play history can shed important light on this factor. There are two obvious time horizons at which the customers' account activity and game play should be assessed: (1) following the customer's initial purchase of Gold Coins; and (2) when Sweeps Coins balances are depleted following unsuccessful play. First, as to customers who purchased Gold Coins and received an allotment of 'free' Sweeps Coins as a bonus, to what extent are they playing the Sweeps Coins over the Gold Coins? If a significant percentage of purchasing customers continually bypass their ample supply of Gold Coins in favor of playing Sweeps Coins, that would be a clear indication that the Sweeps Coins, and not the supposedly promoted product (Gold Coins), are the 'primary subject' of the transaction. For example, in People ex rel. Green v. Grewal, the California Supreme Court found that the element of consideration was satisfied by evidence showing that the customers 'who bought Internet time seemed to spend more time playing the games than using the Internet' and that 'two-thirds of the purchased telephone time' was never used. Based on this disparity of sweepstakes play to actual product use, the California Supreme Court concluded that the internet café's customers were 'clearly paying, at least in part, and, it appears in large part, for the opportunity to play the casino-style sweepstakes games and win cash prizes.' Second — and perhaps even more telling — what typically happens when customers with an abundance of Gold Coins in their online accounts run out of Sweeps Coins following unsuccessful sweepstakes play? Do they go back to their stockpile of Gold Coins and switch to the social casino games (where such coins cannot be redeemed for cash or any prizes) purely for the entertainment value? Or do they seek to immediately replenish their Sweeps Coins balances – and continue playing real money casino-style games – by purchasing additional Gold Coin packages that are bundled with a 'bonus' allotment of 'free' Sweeps Coins? If a significant percentage of users opted to replenish their depleted Sweeps Coin balances by purchasing additional Gold Coin packages – despite already having a large cache of Gold Coins in their online accounts (even relatively small purchases can garner 'hundreds of thousands' of Gold Coins) – that would be compelling evidence that users valued the sweepstakes entries (i.e., Sweeps Coins) more than the promoted product (i.e., Gold Coins), justifying a finding that the Sweeps Coins were the 'primary subject' of the transaction. There is strong anecdotal evidence that online sweepstakes casino spenders are far more interested in the 'free' Sweeps Coins included as a 'bonus' when they purchase Gold Coin packages. An online survey conducted by the American Gaming Association in June 2025 found that, among players who spend money on these platforms, 67% said that they were 'primarily interested' in obtaining the Sweeps Coins rather than Gold Coins, emphasizing the appeal of the virtual tokens with redeemable cash value. Of these spenders, 76% said Sweeps Coins were either 'very' or 'extremely important' in deciding whether to buy a package. While this type of account-level review may ultimately require some degree of fact-gathering and investigation – in contrast to other above-described factors that are evident on their face – these details are within the possession and control of the sweepstakes companies and can readily be subpoenaed and/or demanded through the civil litigation discovery process. 7. Alternative methods of free entry do not negate consideration Sweepstakes laws do not allow operators to bypass strict anti-gambling laws merely by offering free ways to enter. As several Texas courts have recognized, 'the mere pretense of free prizes designed to evade the law, [will] not negate the element of consideration.' For example, in Jester, the Texas Court of Appeals found consideration was present in a sweepstakes even though players could obtain free entries by sending in a postage-paid request form. The Court explained that, notwithstanding the availability of free entries: Thus, where the 'primary subject of the transaction' is to promote sweepstakes play, the existence of alternative methods of free entry will not negate the element of consideration. As discussed above, the following characteristics indicate that the online sites' true purpose is to promote sweepstakes play: (1) the 'casino-themed' environment which allows users to readily switch between non-redeemable 'standard mode' and real money 'promotional sweepstakes mode,' along with information about the user's Sweeps Coins balance constantly displayed near the top of the screen; (2) the perpetual duration of the real-money games; (3) the high payout percentages; (4) the nearly 1:1 correlation between dollars spent and Sweeps Coins received; (5) conditions designed to ensure that customers spend more time playing the real-money games; and (6) customers valuing Sweeps Coins more than the promoted product. In addition, the alternative methods of free entry utilized by many online sweepstakes casino websites do not appear to comply with Texas law, which requires, at a minimum, that: (i) free entries be 'readily and conveniently available'; (ii) the number of free entries offered to non-paying customers cannot be 'nominal'; and (iii) paid entries and free entries must be treated equally. The 'overriding issue,' according to the Texas Attorney General, is whether 'customers' and 'non-customers' are treated equally 'in every respect.' If 'any character of favoritism' is shown to paying entrants, the scheme will be treated as a prohibited lottery. Online sweepstakes casinos treat paying customers much more favorably than non-paying customers in several respects. First, there is clear preferential treatment in the awarding of Sweeps Coins. While most online platforms offer several ways to get free entries without requiring a product purchase – such as by mailing a postcard to a P.O. Box address – the number of free entries awarded to non-paying customers is typically a very low amount – usually no more than 5 Sweeps Coins. By contrast, there is no limit to the number of Sweeps Coins that paying customers can obtain. The more Gold Coins that a player purchases, the more Sweeps Coins the player also receives. So, while a paying customer willing to spend $100 on a coin bundle will typically receive around 100 Sweeps Coins as a bonus, the non-paying customer who mails in a postcard is capped at 5 Sweeps Coins – a nominal amount. A second way in which online sweepstakes casinos treat non-paying customers less favorably than paying customers is through the often-lengthy delays that are experienced in claiming a nominal amount of 'free' Sweeps Coins through the mail. Under Texas law, free sweepstakes entries must be 'readily and conveniently available.' The process for obtaining free entries through the mail – one of the most common alternative methods of free entry – is anything but. While paying customers immediately have their accounts credited with Sweeps Coins when they purchase a coin package, non-paying customers who submit a mail-in postcard to a designated Post Office Box address typically have to wait several weeks, and sometimes months, before their accounts are credited with a nominal amount of Sweeps Coins. 8. Legitimacy of the product is doubtful Finally, in addition to all the other characteristics indicating that online sweepstakes casino websites are illegal gambling businesses (i.e., the clear presence of consideration, the casino-like business model, the perpetual nature of the sweepstakes games, and casino-like payouts), there are serious questions over whether the valueless virtual currency promoted by the real-money casino games are even legitimate products for purposes of a sweepstakes promotion. In California, for example, virtual currency is not a bona fide consumer good. Every California court that has considered the issue has held that virtual currency is not a consumer 'good' or 'service' because it is an intangible asset falling outside the scope of the Consumer Legal Remedies Act. Thus, the virtual 'Gold Coins' that are being touted as the product promoted by the sweepstakes games are not even considered bona fide products under California law. Likewise, under Texas law, a promotional sweepstakes must be connected to the purchase of a 'legitimate product.' Products having 'little or no value' are viewed with skepticism by Texas authorities. As the Texas Attorney General explained in a 1997 legal opinion: '[i]f a product of little or no value is being sold in conjunction with a sweepstakes ticket, the consideration may be deemed to have been paid for the privilege of entering the sweepstakes.' Further, Texas law also requires that 'the payment must be made for a non-gaming product; the product cannot be a sham existing to disguise what is actually a payment to the play the game.' Any claim of product legitimacy is belied by the fact that the virtual 'Gold Coins' do not have any monetary value and cannot under any circumstances be redeemed for cash or prizes. Further, the only 'product' offered are casino games – there is no separate 'non-gaming' line of business being promoted by these companies. Unlike legitimate sweepstakes and rewards loyalty programs, such as those offered by McDonald's or Starbucks, online sweepstakes casinos 'are not offered in furtherance of a legitimate business of goods,' Louisiana Attorney General Liz Murrill concluded. The 'persistent, predatory and profit-driven' casino-style sweepstakes platforms bear no resemblance to those legitimate promotions, she added. State AGs are the next legal frontier in the battle over sweeps Murrill's opinion is just the latest example of state attorney general engagement on the issue of online sweepstakes casinos. Earlier this year, New York Attorney General Letitia James sent cease-and-desist letters to 26 online sweepstakes casino operators, ordering them to 'immediately cease all prohibited gambling activity . . . in New York.' The net result – every recipient voluntarily terminated operations in New York. In West Virginia, State Attorney General John McCuskey issued 47 subpoenas to many of the same companies. Although none have responded formally, more than 20 platforms have since withdrawn from West Virginia. What does that tell you? That these companies will back down when challenged by state officials. Over the last 18 months, ten states – New York, New Jersey, Pennsylvania, Michigan, Delaware, Connecticut, Louisiana, Maryland, Mississippi, and Arizona – have collectively sent over 100 cease-and-desist letters to the operators of dozens of sweepstakes casino websites. Notably, not a single lawsuit was filed challenging the validity of any of those letters. Contrast that with the recent C&D letters that were sent to prediction market platform Kalshi, which responded in nearly every instance by filing a lawsuit against the state issuing the demand. To put it in proper perspective, one company (Kalshi) challenged every single cease-and-desist letter whenever the issuing state demanded immediate compliance. By contrast, not a single one of the dozens of sweepstakes casino platforms which received over 100 cease-and-desist letters in the aggregate were willing to challenge even one of those demands in court. The failure of the sweeps industry to challenge even so much as one cease-and-desist letter is almost tantamount to an admission of illegality. What were they so afraid of? Apparently, the law. Which is one reason why attorney general opinions can be so extraordinarily helpful. Unlike cease-and-desist letters which are directed only against specific companies, a legal opinion from a state attorney general has much broader application, and, in contrast to the legislative process, does not require a formal process or notice before an opinion is issued. Importantly, it can serve as legal precedent and provide the foundation for future civil and criminal enforcement actions against companies which operate in defiance of the opinion. And the timing could not be more perfect. Earlier this week, a coalition of 50 state attorneys general submitted an unprecedented letter to U.S. Attorney General Pamela Bondi requesting the federal government's assistance in curbing 'the rampant spread of illegal offshore gaming operations across the United States.' Specifically, the State AGs asked Bondi to 'deploy robust legal tools' available under federal law, specifically mentioning the Unlawful Internet Gambling Enforcement Act and the Illegal Gambling Business Act, which empower the DOJ to block access to illegal websites and 'seize assets—including servers, domains, and proceeds—that illegal gambling operations use.' However, each of these federal anti-gambling statutes is triggered by a violation of state law. In other words, to prove a violation of the IGBA (which allows seizure of the domains), the DOJ would have to demonstrate that there was a violation of state anti-gambling laws. The DOJ's federal case would be aided immeasurably by a state attorney general formal legal opinion declaring that the online sweepstakes casino business model is illegal under state law. That would certainly go a long way towards helping the Justice Department help the States. And if 'collaboration' is the goal, this is the best way for State AGs to set the table for the feds. But state attorneys general should also pursue civil enforcement remedies under state law. As I have previously written in Forbes, the most effective and efficient way to combat the proliferation of online sweepstakes casinos may be through the vast civil enforcement powers of state attorneys general, who are typically authorized under state law to seek wide-ranging remedies such as injunctive relief, restitution, disgorgement of profits, sequestration of assets, and civil penalties to address illegal activity. Additionally, State AGs can pursue action against other actors who materially assist, aid, abet, or promote illegal gambling operations. Unlike legislation, which is usually forward-looking, civil enforcement actions can look back and address prior misconduct. Without question, an injunction requiring the illegal operator to cease doing business in the state, combined with the forced payment of tens (or even hundreds) of millions of dollars to injured consumers and state treasury in the form of restitution and civil penalties, can serve as a powerful deterrent to other companies violating state gambling laws. It can accomplish in just one case what dozens of cease-and-desist orders cannot possibly achieve in what is fast becoming an endless game of 'whack-a-mole.' Either way, Murrill's opinion – the first one issued by any state attorney general on the subject – will likely prompt closer examination of the issue by other State AG's offices.
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Projecting Team USA's 2026 Olympic Roster
The NHL's 2025-26 season is fast approaching, as are the 2026 Olympic Winter Games. With that in mind, we're analyzing each prominent team's projected rosters. We started the process by looking at Team Canada on Tuesday. And today, it's Team USA's turn to be examined.