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The group highlighted potential risks posed by Google’s organic search features beyond paid advertising, which include autocomplete and suggested queries. 

Using data collected primarily through Chrome’s incognito mode to exclude personalised search histories, the KVA identified several autocomplete and pre-fill search queries that directly suggested illegal gambling platforms to users.

Examples included phrases like “online casino zonder Cruks” (online casino without CRUKS, the Dutch self-exclusion registry for problem gamblers) and “beste online casino buitenland” (best online casino abroad).

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In April, a federal jury sided with Skillz (now operating as Firy Inc.) on its claims that Papaya deceived consumers by utilizing computer bots in its head-to-head mobile games.

Three months later, Judge Denise Cote ordered Papaya to pay Skillz $719 million in damages for poaching players from its skill gaming platform on the belief that Papaya had more players and therefore facilitated considerably faster peer-to-peer pairing times.

Papaya, headquartered in Israel, quickly secured a temporary stay of proceedings from the Tel Aviv District Court and filed a Chapter 15 petition with Delaware’s U.S. Bankruptcy Court. The Chapter 15 petition seeks to prevent Skillz from initiating collection efforts until its appeals play out.

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Below the largest exchanges, he sees numerous operators competing for relatively small shares of a fast-growing category. “If you get 1% of this market, I think it’s a huge opportunity,” Patel said. “There are a lot of people fighting to get 1%.”

Jefferies estimates exchanges can retain approximately 65% of explicit transaction fees, with the balance distributed across clearinghouses, brokers and liquidity providers. It therefore expects more operators to bring parts of the infrastructure in-house.

For the independent suppliers growing alongside them, however, the opportunity expands with every new exchange, contract and market maker. The consumer-facing platforms may attract the users, but their products cannot trade at scale without the data, liquidity and operational machinery developing behind the screen.