Utah Becomes Hotspot for Sweepstakes Casino Class Actions as Lawsuits Top 100 Nationwide

Utah is emerging as a hotspot in the nationwide surge of class actions targeting sweepstakes casinos, with 15 lawsuits now filed in the state recently —12 of them on Sunday, November 2 alone, according to gaming attorney Daniel Wallach.

According to Wallach, the Sunday complaints name operators including ARB Gaming (Modo), Blazesoft (Zula, Sportzino), B2Services (McLuck and Hello Millions), VGW (Chumba Casino and LuckyLand Slots), KHK Games (Clubs Poker), Sunflower Limited (Crown Coins), A1 Development (NoLimitCoins), Gold Coin Group (Punt and Chanced), Play Spree (Spree Casino), Baba Entertainment (Baba Casino), and KICKR Games (Kickr).

These 12 suits join three others from last week against Yellow Social Interactive (Pulsz), the Money Factory, and FSG Digital (Jefebet).

The filings underscore how the state’s strict anti-gambling laws and double-damages statute are drawing increased attention from plaintiffs’ attorneys targeting the dual-currency sweepstakes model.

Why Utah?

Wallach highlighted Utah’s sudden prominence on X. He noted that the state’s combination of stringent gambling laws and its statutory two-times-damages remedy makes it an attractive state for new filings.

Under Utah Code § 76-10-1113, anyone who loses money or property through an illegal gambling activity may sue “to recover twice the amount of the economic loss, and reasonable attorney fees and costs of suit.”

Utah law defines gambling broadly. Utah Code § 76-10-1101(4)(a) states: “‘Gambling’ means risking anything of value upon the outcome of a contest, game, gaming scheme, or gaming device when the return or outcome is based upon an element of chance.”

Because Utah bans all forms of gambling, including lotteries, raffles, and charitable gaming, there is little room for ambiguity.

Sweepstakes casinos argue that free-play mechanisms or promotional “Sweeps Coins” don’t fall under this definition. However, a state court could determine that the virtual coins, or tokens, constitute a “thing of value.”

The double-damages statute amplifies the risk, as a successful plaintiff can recover twice their losses. That could create powerful financial incentives for class-action attorneys to test the model in Utah’s courts.

Rapidly Expanding Litigation Map

Litigations against sweepstakes casinos are expanding exponentially. In July, approximately 50 class action lawsuits were filed nationwide. By the end of October, that number reached 80. In early November, more than 100 are active across the country, with Utah becoming an epicenter.

The complaints generally accuse sweepstakes casinos, such as Chumba Casino, Stake.us, High 5, and WOW Vegas, of violating state gambling laws by selling virtual coins that players can redeem for cash prizes. Plaintiffs argue the dual-currency model mirrors traditional online casinos but operates without licensing or oversight.

Utah is one of only two states (the other being Hawaii) that have no legal gambling, including a lottery. This complete ban, combined with the 2x civil recovery provision, explains the dozen new filings on the same day.

Arbitration Clauses: The Operators’ Shield

Sweepstakes casinos often include arbitration clauses and class-action waivers in their terms of service. Those provisions have proven highly effective in many cases. Courts in several states have dismissed class-action suits or sent them to arbitration due to the presence of these clauses.

Still, the protection isn’t absolute. Some courts have ruled such agreements to be excessive. That’s because they appear to limit statutory remedies or bind consumers under “take-it-or-leave-it” contracts.

In one recent example, a California judge denied High 5 Casino’s motion to compel arbitration. The court found the clause unfair to players bringing claims related to illegal gambling.

In Utah, sweepstakes casinos will likely rely on arbitration as a key line of defense. However, as the state explicitly authorizes civil actions with double damages, plaintiffs are likely to challenge the enforceability of those clauses more aggressively.

Google Policy Adds Fuel to Fire

A recent Google update could play a significant role going forward. On October 28, Google amended its Gambling and Games Advertising Policy. It removed sweepstakes casinos from its “social casino games” category and reclassified them as gambling products.

The changes mean that sweepstakes casinos that want to advertise on Google must comply with the same regulations as licensed gambling operators.

In its update, Google cited “online gambling games played with virtual currencies or items that have real-world value” as examples of gambling products. That phrasing mirrors the “thing of value” argument central to many lawsuits.

The October 28 revision closes a loophole that allowed sweepstakes casinos to advertise under the broader “social games” rules. With the change, Google aligns with many state regulators. It effectively reinforces the claim that these platforms operate as de facto real-money casinos.

Mounting Pressure on Contested Model

Between Utah’s double-damages statute, the surge of class actions, and Google’s tightening of ad definitions, sweepstakes-casino operators are confronting pressure on several fronts.

The dual-currency model, intended to circumvent gambling by claiming entertainment play, is facing growing legal and reputational challenges. Plaintiffs are increasingly targeting consumer-friendly jurisdictions while major tech platforms are narrowing their national footprint.

Meanwhile, many state lawmakers are paying closer attention to the gap between “social gaming” and gambling. Several states have already banned the platforms this year.

Arbitration clauses may still block many cases, but the legal gray area that once allowed sweepstakes casinos to flourish is closing rapidly.
Utah’s emergence as a lawsuit hotspot could further contribute to the nationwide market contraction.