Slotomania....This game can be very miss leading. The odds are not good. The ballinko purchase when you spend the extra money is set up to not hit the center ball. Very disappointing, it's like stealing money from your customers. One day you'll do real well, the next day nothing. It doesn't matter what you bet or play, it's like they flip a switch. Save your money.
Kimberly M
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PLAYTIKA Ripoff Reports, Complaints, Reviews, Scams, Lawsuits and Frauds Reported Your Search: Playtika. There may be more reports for 'Playtika'. Playtika Slotomania Internet. Computer Fraud: Playtika Internet. Author: Irving, Texas. 12, Report #1243657. Jul 22 2015 09:02 PM.
Tanialle G
• Oct 02, 2020
This game has the absolute WORST customer service. I would buy a few 24.99 packages on payday and would play the credits and then play the extra games to get extra credits. So I go to bed Sept. 11th and woke up to 39 charges that I didn't do. The game was also reset and when I finally get ahold of a game developer they send a screenshot saying I played all of these credits out which my game was reset from scratch the minute I sent in all of the fraudulent charges to Google Play. So ive been dealing with this for over 20 days the developers get ahold of me and say nope you made these charges no refund stay safe. They said this 3 times. There screenshot said that I played these credits out even though on the 12th the game was reset. It says I played these credits for like 3 days straight without sleeping even and while I was working a 16 hour shift. I mean, who do we talk to if nobody wants to take blame for their glitches on there *** games?
Jessie M
• Sep 04, 2020
I paid for credits and did not receive the credits.
On 09/01/2020 I paid *** for what is called a 'Golden Spin' which was to credit my game with *** credits. I did not receive these credits. My credit card was charged. I then contacted customer service at Playtika and they told me I have to wait that there was a glitch in the system. At that point I asked for a refund of the money and they told me no. At which point they tell me that all sales are final. Which is fine I have no issue with that as long as I got the product I paid for, I did not. I have a copy of receipt. I can show on my bank statement that I was charged. Purchase Number*** Purchase Date Sep 01, 2020 0:51:40 PM GMT (08:51:40 EST) Item 'Golden Spin' Payment Method VISA ending in
I would like delivery of the *** trillion credits to my account as soon as possible. I would also like for a supervisor or manager to contact me by phone as soon as possible.X-XXX-XXX-XXXX.
Stacy C
• Sep 03, 2020
I have several unauthorized purchases and no one will help me.
I have contacted the company several times and they refuse to help. My phone and other items were taken from my car. They told me it was my problem and I should have blocked these purchases. Well, without my phone, I was unable to do so.
I just want a refund on the purchases I did not make.
Vicki M
• Aug 04, 2020
Playtika games collect tons of money for playing their apps Slotomania and House of Fun. Minimal wins and you have to continue buying coin packs.
I have purchased mult coin packages from this company and the game takes my coins constantly. I have shown proof and reached out to support. 0 help I have purchased coin packages on 8/27,/18 thru 7//2020 multiple packages totaling well over thousand $$. I have followed instructions by support to uninstall and reinstall the game. I have sent emails and chats with screen shots showing the problem and how coins I have purchased with my hard earned money are being taken and I have gotten no assistance at all. I have had a rep email me and pretty much make me feel like a liar and chat reps blow off my issue with no resolve at all!! I play online games made by Playtika Slotomania and House of Fun. I've learned that Playtika charges their players different prices for the same item. Also I've requested all my money back from lost coins that I have spent since 2018. I am a Senior Citizen; My requests are ignored. Organized greed is very evident with this company -' please support the people who have been exploited by PLAYTIKA. Thank you.
I would like a refund of all purchasesfrom 8/XX XXXX-zJuly2020.please support the people who have been exploited by PLAYTIKA. Thank you.
Tenaya E
• Jul 13, 2020
I purchased a holiday special package and have not received it. I have sent over a dozen inquiries. On
On July 3 2020 I paid $99.99 for a 4th of July special on Bingo Blitz. I should have received 4800 credits and 16 dice. I did not receive and so I contacted customer support. I had to send them my purchase history as well as my apple receipt. At this time July 6 2020 I have submitted over a dozen support requests for this matter. I have sent them my purchase history and my apple receipt both of which confirm my purchase on 7/3/20. At this point the dice game is over so the 16 dice are useless. I have not received a reply I'm the last 48 hours. This is ridiculous. I submitted what they requested and still received nothing.
I just want my money back. They can't compensate me for the game that's no longer available and as for bingo credits I don't want the ***. I want my money back and then I am done with playtika and bingo blitz.
Brenda C
• Jun 25, 2020
Playtika Slotomania Complaints Games
Fraud no way to stop addicted people from spending
I have begged them to block my spending to no avail. Game freezing making me loose spent so much in my stress after flooding 2 daughter's getting no sleep up all night have my 3 grandkids they won't give option to stop spending. 3 days ago getting no internet non stop causing losses. Case manager said delete cookies files so did still not working tried system restore now my all in one not working at all!! Played free games Sunday on my phone and same message!!! Now I have no computer and again wasn't my computer. Problems have been non stop they always say it's my computer but when I do nothing it works fine later so was their game!!! I have to bankrupt because of this! It has to be illegal speaking to my lawyer today. Playtika Games On Facebook
I want refund for every time I was double charged or told it was my computer when it wasn't. Also for all times I asked to block my spending and was ignored. They get rich on vulnerable seniors that are highly stressed it has to stop!!! Also I need my all in one replaced
Jed L
• Jun 17, 2020
Product is bug-filled. Product is manipulative. Service is near-non-existent. After a week reporting dozen bugs, finally get Cookie-cutter response.
Problem date: last few years. I attempted to close my account over 1 year ago. Despite many attempts, they refused to close my account. Unfortunately I started playing Slotomania again a few months ago. Guess that's their plan. I had been in contact with them for along time in regards to their games being completely skewed and would never line up with their terms or what support/website would say. Their own terms say they can't do what they are doing. Yet bringing this to their attention reaches deaf ears. Also, Apple is worthless when trying to lodge a complaint against an app developer. They deny nearly as much as Playtika does. Recently, their game is quite glitchy and buggy. Tell them about a bug that cost me $10 or $20 worth of chips and in a week, they'd send me $.50 worth of chips with an explanation that their game gets more challenging the further along you get. That's an example of support trying to line up a response with an inquiry - clearly not related but that's what they do. I could go on with dozens of specific instances, but will leave it with a new feature they introduced: The code was so skewed to the house that I went over 30 tries without picking a prize in a feature with near 50/50 odds. They swore up and down that it was all random, said so in all their doc. I had an MIT professor friend work out the math with me and odds were ***, which is equivalent to 54 instances every quadrillion or 1 in 18.54 trillion attempts. He just chuckled when I asked him if this could ever be considered an anomoly as Playtika support had called it. The odds were so remote they really couldn't happen and this was commonplace while playing their game.
Would like my money back from Playtika. A full refund plus my account closed for good (thought companies had to abide by requests like that these days?)
April H
• Jun 10, 2020
Fraudulent gaming practices.
I have requested for purchase refunds that have been made thru this gaming for well over 2 years you can see as soon as you make that first purchase you automatically start to loose until they get it all back, it's like a switch is turned on to loose only. I have all documents of purchases and refunds requested thru this site also have pictures to prove that it is the same individuals that are winning the games Everytime I have sent dozens of complaints for the unfairness of the game with no response. There has to be some responsibility held for the dishonest practices of this site. Once I make this complaint I expect they will lock my account out of retaliation. I will continue to talk to my bank and Google about these charges. Until it is resolved.
Refund of all purchases made from 2019 til now they have a list of them if needed I will get a print out from the bank for all purchases.
Dawn K
• Jun 03, 2020
I was asked for proof and gave it. It didn't matter because *** would not honor the difference Iam clearly owed
I finished a set worth almost 133B it only paid 88B. When I contacted live chat I was asked for proof I sent it but I was told 'NO I wont do that' as in credit my acct the difference owed. She tried to give me 3 different excuses but the screen shots are time stamped so whatever she was lying to me about did not apply
I just want the difference owed
Tawanda L
• May 20, 2020
I have purchased mult coin packages from this company and the game takes my coins constantly. I have shown proof and reached out to support. 0 help
I have purchased coin packages on 05/06, 05/07 and multiple packages in April totaling well over 300. I have followed instructions by support to uninstall and reinstall the game. I have sent emails and chats with screen shots showing the problem and how coins I have purchased with my hard earned money are being taken and I have gotten no assistance at all. I have had a rep email me and pretty much make me feel like a liar and chat reps blow off my issue with no resolve at all!! This is completely unacceptable and I will not just donate my money to this company!
I would like every dime that I have spent on this game during the months of April and May to be returned and I will never play this game ever again.
Shelly A
• May 19, 2020
BB promotes their inapp purchases with big rewards in which are impossible to win!The ammount of game play & progress for your purchases is a scam!
I have been playing BB almost 8 yrs & spent thousands of $ to do so! I've spent $*** in the last month and the game play time and progress is absolutely not worth it! It's like paying *** for a *** gumball! I've submitted many complaints and all I receive is an automated message in return! They need to be investigated for their scam! It's getting worse every day! Considering the pandemic the world is going threw right now I feel they have made it impossible to play and win or make any progress!
I would like a refund for my most recent purchases from april 1st threw may 5th 2020! I will gladly remove the app and never play bingo blitz again!
Becky D
• May 11, 2020
Playtika games are awful. They treat players horribly. Why nothing has been done about this company and it's practices absolutely amazes me. I have asked them many times why my game play is so bad and they say it's all random. Who controls the level of randomness for each player and what do they base those guideline off? They should not be allowed to treat players the way they do.
shawna h
• Apr 18, 2020
Worst game ever don't buy chips it's a rip off
Annessia X
• Mar 12, 2020
BingoBlitz has taken so much of my money. It hooks you and is not worth the addiction. They do not have reasonable bundles and always freeze up.
Bingo Blitz was super fun and then it got addicting and unreasonable. I have had so many times where the game freezes and would email and never get refunded the tokens back. They have rooms that are *** tokens to play yet they only give you 70 or so free tokens. The customer service is horrible and they are cheating their way through to people. I would like a refund of all purchase from May 2019-March 2020. I spent more than *** bucks on tokens and yet I sit here unlucky and not fair that I'm sitting at single digit tokens. They ask for so much but gives so little. You can't benefit from their constant scam of coins.
I would like to receive a refund for all purchases made from may 2019 to March 2020.
Kim B
• Mar 11, 2020
I play an online game made by playtika. They charge their players different prices for the same item. I don't think this is a good sales practise.
There are millions of online players in this game slotomania made by playtika. Each player has a diff level and different play habits. We are required (every player) to complete a weekly series know as the daily dash. The goals vary by level. For example I may have to spin 6billion coins in 100 spins....where as a lower level player may have to only spin 2 b in 100 spins. This I can understand being diff depending on your level etc. However I do not agree that equal items each player can purchase the same for example a weekly wildcard for completing all the daily dashes, should be a diff price. We all are getting the same item. However mine for example was 1.99 when they came out with the weekly wildcard idea a couple of months ago. Now it's changed to 5.99 now up to 11.99.....all the players I spoke to still only pay 1.99 but mine is gone up to four times that amount. And we all are paying for the same thing. So why do some people pay more. I spoke to other in an social Media group who play the same game and there are people there paying up to 65$ for it. This is insane and I don't think it is a.fair sales practise at all. When I contact support about this issue at least 10 times because they tell me it rotates and everyone's will change eventually. But no one I know in my group has changed. Regardless of level etc. They all still pay 1.99 No one in the customer service section can properly answer my question.I am continually given generic answers like I cannot compare accounts etc. All I know is regardless of anything, we as players are required to complete weekly tasks ..and for doing that our reward is the option to purchase a daily dash plus it's called. And in there you are given a wild card .and I think it should be the same price for all players. Very poor and unfair sales practise
I would like all players to have to pay the same fee for equally accessible items.
Jerri W
• Feb 25, 2020
Charges were made by this company to my debit card and paypal account for the same transactions. I was charged double the past four months.
Charged double for same transactions. My debit card and PayPal account was charged for the exact transactions. I want a refund. Contacting this company has been impossible.
I want a refund for the double charges.
Angela M
• Feb 24, 2020
This company targeted me as a senior citizen and has rigged software! They ripped me off for $***!!! I want my money returned!
I had no chance of winning and they ripped me off on purpose! They stole my money and refuse to answer me when first I complained because they were double billing me and later they just stole my money instantly. And as I spent $*** I got to a point where they won't e em let me play unless the ante is over a billion coins which allows them to steal even more money but even faster! The last 3 days specifically they have been on a rigged rampage! Everyone in the game Is talking About it and They refuse to respond to my emails! They are cheating me specifically because I'ma senior citizen. I am filing a claim to the fbi also for Internet fraud!
$*** + cash money!! ASAP!!
Andrew B
• Jan 06, 2020
Daughter of *** Promo 12/7
Hello, I am a Diamond member of this online community for Slotomania. On 12/7 there was a promo advising triggering 4 scatters in the game would award your highest win to be matched. I accomplished this but was never awarded my coins. I reached out and submitted a ticket (***) and was advised I did not complete the 4 scatters. I sent the screenshot proving and kept getting push back. After 2 weeks of trying to get a resolution there was no help. They kept coming up with excuses to avoid giving me what I won. This has happened NUMEROUS times to me and each time even with proof they do nothing to make it right. I am writing this in hopes it will wake someone up at this company and have them realize systems do make mistakes and it is their job to make it right. I even tried compromising and getting half of what I should have received and they declined. I hope this finds someone at the company and they do something to make these experiences better for other people in the future. Hate for others to have to go through what I have.
I would like the company to honor their promo and at least meet me half way as I indicated in my ticket submitted to them. I am tired of this happening and want them to at least show they care and try to help. They have the proof and desire they honor their side.
Kenneth S
Playtika Slotomania Complaints Bonus
Their games blatently cheat and do not pay out what they promise, when confronted with the issue they play dumb and try to bribe with a coin gift
It was the cash or smash game. I chose my case at the beginning of the game. In round 2 or 3 the *** point case was picked and then she smashed it with the hammer giving it back to me. At the very end of the game when I was down to the final 2 cases it asked me if I wanted to keep my original case or trade it for the only remaining case. I knew that the *** point case was the only one left so I selected switch case. But instead of giving me the *** points case it gave me a 2. That means that if the game was correct, I would have selected the *** point case originally before the game started. But I didnt because the *** point case was selected in the 2nd or 3rd round and then smashed and given back to me. This is clearly wrong. There are only 2 reasons for this: it was an actual mistake or the game clearly cheats its customers. my apyout should have been *** x
coins
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Playtika Slotomania Complaints New
Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 1 of 19
1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 11 SEAN WILSON, individually and on behalf of all others similarly situated, 12 Plaintiff, 13 COMPLAINT—CLASS ACTION v. 14 15 16 17 Case No. PLAYTIKA, LTD an Israeli limited company, PLAYTIKA HOLDING CORP., a Delaware corporation, and CAESARS INTERACTIVE ENTERTAINMENT, LLC, a Delaware limited liability company, JURY DEMAND 18 Defendants. 19 20 21 22 23 24 25 Plaintiff Sean Wilson brings this case, individually and on behalf of all others similarly situated, against Defendant Playtika Ltd., Playtika Holding Corp. (collectively “Playtika”), and Caesars Interactive Entertainment, LLC (“CIE”) (collectively “Defendants”) to enjoin their operation of illegal online casino games. Plaintiff alleges as follows upon personal knowledge as to himself and his own acts and experiences, and upon information and belief, including investigation conducted by his attorneys, as to all other matters. NATURE OF THE ACTION 26 27 1. Playtika owns and operates a leading video game development company in the so- COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC -1- 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 2 of 19 1 called “casual games” industry—that is, computer games designed to appeal to a mass audience 2 of casual gamers. Playtika owns and operates a host of popular online slot machine games 3 including, inter alia, Caesars Slots, Slotomania, House of Fun, and Vegas Downtown Slots. 4 2. Playtika provides visitors of its online slot machines a bundle of free “coins” that 5 can be used to wager on its games. After consumers inevitably lose their initial allotment of 6 coins, Playtika attempts to sell them additional coins starting at $2.99 for 20,000 coins. Without 7 coins, consumers cannot play Defendant’s online slot machines. 8 9 3. Freshly topped off with additional coins, consumers wager to win more coins. The coins won by consumers playing Playtika’s games of chance are identical to the coins that it 10 sells. Thus, by wagering 20,000 coins that were purchased for $2.99, consumers have the chance 11 to win hundreds of thousands of additional coins that they would otherwise have to purchase. 12 4. By operating its online slot machines, Playtika has illegally profited from tens of 13 thousands of consumers. Accordingly, Plaintiff Wilson, on behalf of himself and the Classes of 14 similarly situated individuals, brings this lawsuit to recover their losses, as well as costs and 15 attorneys’ fees. 16 PARTIES 17 5. Plaintiff Sean Wilson is a natural person and a citizen of the state of Washington. 18 6. Defendant Playtika Ltd. is a limited company incorporated and existing under the 19 laws of Israel, with its principal place of business at 8 HaChoshlim Street, Herzliya 4672408, 20 Israel. Playtika Ltd. conducts business throughout this District, Washington State, and the United 21 States. 22 7. Defendant Playtika Holding Corp. is a corporation incorporated and existing 23 under the laws of Delaware, with its principal place of business at 2225 Village Walk Drive 24 #240, Henderson, Nevada 89052. Playtika Holding Corp. conducts business throughout this 25 District, Washington State, and the United States. 26 27 8. Defendant Caesars Interactive Entertainment, LLC is a limited liability company organized and existing under the laws of Delaware, with its principal place of business at One COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC -2- 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 3 of 19 1 Caesars Palace Drive, Las Vegas, Nevada 89109. Caesars Interactive conducts business 2 throughout this District, Washington State, and the United States. 3 JURISDICTION AND VENUE 4 9. Federal subject-matter jurisdiction exists under 28 U.S.C. § 1332(d)(2) because 5 (a) at least one member of the class is a citizen of a state different from Defendant, (b) the 6 amount in controversy exceeds $5,000,000, exclusive of interests and costs, and (c) none of the 7 exceptions under that subsection apply to this action. 8 9 10 10. business in this District, and because the wrongful conduct occurred in and emanated from this District. 11 12 The Court has personal jurisdiction over Defendants because they conduct 11. Venue is proper in this District under 28 U.S.C. § 1391(b) because a substantial part of the events giving rise to Plaintiff’s claims occurred in this District. 13 14 FACTUAL ALLEGATIONS I. 15 Free-to-Play and the New Era of Online Gambling 12. The proliferation of internet-connected mobile devices has led to the growth of 16 what are known in the industry as “free-to-play” videogames. The term is a misnomer. It refers 17 to a model by which the initial download of the game is free, but companies reap huge profits by 18 selling thousands of “in-app” items that start at $0.99 (purchases known as “micro-transactions” 19 or “in-app purchases”). 20 13. The in-app purchase model has become particularly attractive to developers of 21 games of chance (e.g., poker, blackjack, and slot machine mobile videogames, amongst others), 22 because it allows them to generate huge profits. In 2017, free-to-play games of chance generated 23 over $3.8 billion in worldwide revenue, and they are expected to grow by ten percent annually.1 24 Even “large land-based casino operators are looking at this new space” for “a healthy growth 25 26 1 GGRAsia – Social casino games 2017 revenue to rise 7pct plus says report, http://www.ggrasia.com/socialcasino-games-2017-revenue-to-rise-7pct-plus-says-report/ (last visited Apr. 6, 18) 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC -3- 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 4 of 19 1 potential.”2 2 14. With games of chance that employ the in-game purchase strategy, developers 3 have begun exploiting the same psychological triggers as casino operators. As one respected 4 videogame publication put it: “If you hand someone a closed box full of promised goodies, many will happily pay you for the crowbar to crack it open. The tremendous power of small random packs of goodies has long been known to the creators of physical collectible card games and companies that made football stickers a decade ago. For some … the allure of a closed box full of goodies is too powerful to resist. Whatever the worth of the randomised [sic] prizes inside, the offer of a free chest and the option to buy a key will make a small fortune out of these personalities. For those that like to gamble, these crates often offer a small chance of an ultra-rare item.”3 5 6 7 8 9 15. 10 “Games may influence ‘feelings of pleasure and reward,’ but this is an addiction to the games themselves; micro-transactions play to a different kind of addiction that has existed long before video games existed, more specifically, an addiction similar to that which you could develop in casinos and betting shops.”4 11 12 16. 13 14 15 16 The comparison to casinos doesn’t end there. Just as with casino operators, mobile game developers rely on a small portion of their players to provide the majority of their profits. These “whales,” as they’re known in casino parlance, account for just “0.15% of players” but provide “over 50% of mobile game revenue.”5 17. 17 18 Another stated: Game Informer, another respected videogame magazine, reported on the rise (and danger) of micro-transactions in mobile games and concluded: “[M]any new mobile and social titles target small, susceptible populations for large percentages of their revenue. If ninety-five people all play a [free-to-play] game without spending money, but five people each pour $100 or more in to obtain virtual currency, the designer can break even. These five individuals are what the industry calls whales, and we tend not to be too concerned with how they’re being used in the equation. While the scale and potential financial ruin is 19 20 21 22 23 24 25 26 2 Report confirms that social casino games have hit the jackpot with $1.6B in revenue | GamesBeat, https://venturebeat.com/2012/09/11/report-confirms-that-social-casino-games-have-hit-the-jackpot-with-1-6b-inrevenue/ (last visited Apr. 6, 18) 3 PC Gamer, Microtransactions: the good, the bad and the ugly, http://www.pcgamer.com/microtransactions-the-good-the-bad-and-the-ugly/ (last visited Apr. 5, 2018). 4 The Badger, Are micro-transactions ruining video games? | The Badger, http://thebadgeronline.com/2014/11/micro-transactions-ruining-video-games/ (last visited Apr. 5, 2018). 5 Id. (emphasis added). 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC -4- 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 5 of 19 of a different magnitude, a similar profitability model governs casino gambling.”6 1 18. Academics have also studied the socioeconomic effect games that rely on in-app 2 purchases have on consumers. In one study, the authors compiled several sources analyzing so3 called free-to-play games of chance (called “casino” games below) and stated that: 4 “[Researchers] found that [free-to-play] casino gamers share many similar sociodemographic characteristics (e.g., employment, education, income) with online gamblers. Given these similarities, it is perhaps not surprising that a strong predictor of online gambling is engagement in [free-to-play] casino games. Putting a dark line under these findings, over half (58.3%) of disordered gamblers who were seeking treatment stated that social casino games were their first experiences with gambling.” 5 6 7 8 … 9 “According to [another study], the purchase of virtual credits or virtual items makes the activity of [free-to-play] casino gaming more similar to gambling. Thus, micro-transactions may be a crucial predictor in the migration to online gambling, as these players have now crossed a line by paying to engage in these activities. Although, [sic] only 1–5% of [free-to-play] casino gamers make microtransactions, those who purchase virtual credits spend an average of $78. Despite the limited numbers of social casino gamers purchasing virtual credits, revenues from micro-transactions account for 60 % of all [free-to-play] casino gaming revenue. Thus, a significant amount of revenue is based on players’ desire to purchase virtual credits above and beyond what is provided to the player in seed credits.”7 10 11 12 13 14 15 16 17 18 19 20 21 19. The same authors looked at the link between playing free-to-play games of chance and gambling in casinos. They stated that “prior research indicated that winning large sums of virtual credits on social casino gaming sites was a key reason for [consumers’] migration to online gambling,” yet the largest predictor that a consumer will transition to online gambling was “micro-transaction engagement.” In fact, “the odds of migration to online gambling were approximately eight times greater among people who made micro-transactions on [free-to-play] casino games compared to [free-to-play] casino gamers who did not make micro-transactions.”8 22 23 24 25 26 6 Game Informer, How Microtransactions Are Bad For Gaming - Features - www.GameInformer.com, http://www.gameinformer.com/b/features/archive/2012/09/12/how-microtransactions-are-bad-forgaming.aspx?CommentPosted=true&PageIndex=3 (last visited Apr. 5, 2018) 7 Hyoun S. Kim, Michael J. A. Wohl, et al., Do Social Casino Gamers Migrate to Online Gambling? An Assessment of Migration Rate and Potential Predictors, Journal of gambling studies / co-sponsored by the National Council on Problem Gambling and Institute for the Study of Gambling and Commercial Gaming (Nov. 14, 2014), available at http://link.springer.com/content/pdf/10.1007%2Fs10899-014-9511-0.pdf (citations omitted). 8 Id. (emphasis added). 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC -5- 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 6 of 19 1 20. The similarity between micro-transaction based games of chance and games of 2 chance found in casinos has caused governments across the world to intervene to limit their 3 availability.9 Unfortunately, such games have eluded regulation in the United States. As a result, 4 and as described below, Defendants’ online slot machine games have thrived and thousands of 5 consumers have spent millions of dollars unwittingly playing Defendants’ unlawful games of 6 chance. 7 II. 8 9 A Brief Introduction to Playtika 21. In December 2010, Playtika launched an online casino game called Slotomania. Over the years, Playtika expanded its online casino game offering and developed a host of online 10 slot machine games including, inter alia, House of Fun, Caesars Slots, and Vegas Downtown 11 Slots. 12 22. Playtika has been through a series of mergers and acquisitions by some the largest 13 social gaming companies and casinos. In 2011, Caesars Interactive Entertainment—one of the 14 largest online, mobile, and social gaming companies with long ties to traditional casino 15 gaming—purchased Playtika. Later in 2016, Giant Interactive Group acquired Playtika and its 16 entire offering of casino games for $4.4 billion.10 17 18 23. like Facebook and on mobile devices such as Android phones and Apple iPhones. 19 20 Consumers can play Playtika’s online slot machines through numerous websites 24. Defendants have made large profits through their online gambling games. In 2014 alone, Playtika generated almost $280 million in revenue.11 The revenue Defendants receive 21 9 22 23 24 25 26 In late August 2014, South Korea began regulating “social gambling” games, including games similar to Defendant’s, by “ban[ning] all financial transactions directed” to the games. PokerNews.com, Korea Shuts Down All Facebook Games In Attempt To Regulate Social Gambling | PokerNews, https://www.pokernews.com/news/2014/09/korea-shuts-down-facebook-games-19204.htm (last visited Apr. 5, 2018). Similarly, “the Maltese Lotteries and Gambling Authority (LGA) invited the national Parliament to regulate all digital games with prizes by the end of 2014.” Id. 10 China's Giant leads consortium to buy Playtika for $4.4 billion, Game Beat, https://venturebeat.com/2016/07/30/chinas-giant-leads-consortium-to-buy-playtika-for-4-4-billion/ (last visited Apr. 6, 18). 11 Caesars Acquisition Company, Form 10-K, at 27, 53, http://files.shareholder.com/downloads/AMDA-26XRVU/108250871x0x816171/7DEB3AB6- 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC -6- 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 7 of 19 1 from Playtika’s online casino games are the result of operating unlawful games of chance 2 camouflaged as innocuous videogames. 3 III. 4 Defendants’ Online Casino Contains Unlawful Games of Chance 25. As explained above, Playtika owns and operates a host of online slot machine 5 games. Each game functions in a substantially similar fashion. That is, consumers purchase and 6 wage real money on games of chance. 7 26. Consumers visiting Playtika’s online casino for the first time are awarded a 8 bundle of coins. For example, Playtika gives away 20,000 “coins” to new Slotomania players. 9 These free sample coins offer a taste of gambling and are designed to encourage players to get 10 11 hooked and buy more coins for real money. 27. After they begin playing, consumers quickly lose their initial allotment coins. 12 Immediately thereafter, Playtika informs them via a “pop up” screen that they have insufficient 13 coins to place a wager. See e.g., Figures 1 and 2. Once players run out of their allotment of free 14 coins, they cannot continue to play the game without buying more coins for real money. 15 16 17 18 19 20 21 22 23 (Figure 1, showing Defendants’ Slotomania game on Facebook.) 24 25 26 64B5-46D9-80CC-FAE83E09DC48/CACQ-2014_Q4_Form_10-K.PDF (last visited Apr. 5, 2018). 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC -7- 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 8 of 19 1 2 3 4 5 6 7 8 9 10 (Figure 2, showing Defendants’ House of Fun game on iOS.) 28. Concurrently with that warning, Playtika provides a link to consumers, allowing 11 them to purchase coins with real money at its electronic store. Playtika’s Slotomania online 12 casino, for example, sells coins from $2 for 7,500 coins to $50 for 320,000 coins. See Figure 3. 13 14 15 16 17 18 19 20 21 22 23 24 (Figure 3, showing Defendants’ Slotomania coin prices) 29. Similarly, Playtika sells coins from $2 for 131,250 coins to $50 for 4,375,000 coins on its Facebook Caesar’s Casino slot game. See Figure 4. 25 26 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC -8- 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 9 of 19 1 2 3 4 5 6 7 8 9 10 11 12 13 (Figure 4, showing Defendants’ Caesars Casino slot game coin prices) 30. The decision to sell coins by the thousands isn’t an accident. Rather, Playtika 14 attempts to lower the perceived cost of the coins (costing just a fraction of a penny per coin) 15 while simultaneously maximizing the value of the award (awarding millions of coins in 16 jackpots), further inducing consumers to bet on its games. 17 31. To begin wagering, players select the “BET/LINE” (i.e., bet per played line) that 18 will be used for a spin, as illustrated in Figure 5, which illustrates Playtika’s Caesar’s Slots 19 game. Playtika allows players to multiply their bet by changing the number of “lines” (i.e., 20 combinations) on which the consumer can win, shown in Figure 5 as the “LINE” button. 21 22 23 24 25 (Figure 5, showing Defendants’ Caesars Slots game.) 32. The bet amount multiplied by the number of lines comprises the “Total Bet” 26 shown in Figure 5. Thus, in the example shown in Figure 5, the player is attempting to bet 2,000 27 coins, or approximately $0.03, for one spin of the slot machine. COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC -9- 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 10 of 19 1 33. Once a consumer spins the slot machine by pressing the “SPIN” button, Playtika 2 does not allow (or call for) any additional user action by the player on any of its slot machine 3 games. Instead, the consumer’s computer or mobile device communicates with and sends 4 information (such as the “Total Bet” amount) to Playtika’s servers. Playtika’s servers then 5 execute the game’s algorithms that determine the spin’s outcome. Notably, none of Defendants’ 6 games depend on any amount of skill to determine their outcomes—all outcomes are based 7 entirely on chance. 8 34. 9 Consumers can continue playing with the coins that they won, or they can exit the game and return at a later time to play because Playtika maintains win and loss records and 10 account balances for each consumer. Indeed, once Playtika’s algorithms determine the outcome 11 of a spin and Playtika displays the outcome to the consumer, it adjusts the consumer’s account 12 balance. Playtika keeps records of each wager, outcome, win, and loss for every player. 13 14 FACTS SPECIFIC TO PLAINTIFF WILSON 35. Since at least 2012, Plaintiff Wilson has been playing Playtika’s online slot 15 machines. Specifically, Wilson has played “House of Fun” and “Slotomania Slots” on his iOS 16 devices, and “Slotomania” and “Caesars Slots” on Facebook. 17 18 19 36. After Plaintiff lost the balance of his initial allocation of free coins, he began purchasing coins from Defendants for use in its online slot machine games. 37. Thereafter, Plaintiff Wilson continued playing Playtika’s slot machines where he 20 would wager coins for the chance of winning additional coins. Starting in September 2016, 21 Plaintiff Wilson wagered and lost (and Defendants therefore won) over $10 at Defendants’ 22 games of chance. 23 24 CLASS ALLEGATIONS 38. Class Definition: Plaintiff Wilson brings this action pursuant to Fed. R. Civ. P. 25 23(b)(2) and (b)(3) on behalf of himself and the Class and Subclass (collectively the “Classes”) 26 of similarly situated individuals, defined as follows: 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC - 10 - 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 11 of 19 1 Class: All persons in the State of Washington who purchased and lost coins playing Defendants’ slot machine games. 2 CIE Subclass All persons in the State of Washington who purchased and lost coins playing Defendants’ slot machine games before October 22, 2016. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 The following people are excluded from the Classes: (1) any Judge or Magistrate presiding over this action and members of their families; (2) Defendants, Defendants’ subsidiaries, parents, successors, predecessors, and any entity in which the Defendants or its parents have a controlling interest and its current or former employees, officers and directors; (3) persons who properly execute and file a timely request for exclusion from the Classes; (4) persons whose claims in this matter have been finally adjudicated on the merits or otherwise released; (5) Plaintiff’s counsel and Defendants’ counsel; and (6) the legal representatives, successors, and assigns of any such excluded persons. 39. Numerosity: On information and belief, tens of thousands of consumers fall into the definition of the Classes. Members of the Classes can be identified through Defendants’ records, discovery, and other third-party sources. 40. Commonality and Predominance: There are many questions of law and fact common to Plaintiff’s and the Classes’ claims, and those questions predominate over any questions that may affect individual members of the Classes. Common questions for the Classes include, but are not necessarily limited to the following: a. 19 20 RCW § 9.46.0237; b. 21 22 c. Whether Plaintiff and each member of the Class lost money or anything of value by gambling; d. 25 26 Whether Defendants are the proprietor for whose benefit the online casino games are played; 23 24 Whether Defendants’ online casino games are “gambling” as defined by Whether Defendants violated the Washington Consumer Protection Act, RCW § 19.86.010, et seq.; and e. Whether Defendants has been unjustly enriched as a result of its conduct. 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC - 11 - 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 12 of 19 1 41. Typicality: Plaintiff’s claims are typical of the claims of other members of the 2 Classes, in that Plaintiff’s and the members of the Classes sustained damages arising out of 3 Defendants’ wrongful conduct. 4 42. Adequate Representation: Plaintiff will fairly and adequately represent and 5 protect the interests of the Classes and has retained counsel competent and experienced in 6 complex litigation and class actions. Plaintiff’s claims are representative of the claims of the 7 other members of the Classes, as Plaintiff and each member of the Classes lost money playing 8 Defendants’ games of chance. Plaintiff also has no interests antagonistic to those of the Classes, 9 and Defendants have no defenses unique to Plaintiff. Plaintiff and his counsel are committed to 10 vigorously prosecuting this action on behalf of the Classes and have the financial resources to do 11 so. Neither Plaintiff nor his counsel have any interest adverse to the Classes. 12 43. Policies Generally Applicable to the Classes: This class action is appropriate for 13 certification because Defendants have acted or refused to act on grounds generally applicable to 14 the Classes as a whole, thereby requiring the Court’s imposition of uniform relief to ensure 15 compatible standards of conduct toward the members of the Classes and making final injunctive 16 relief appropriate with respect to the Classes as a whole. Defendants’ policies that Plaintiff 17 challenges apply and affect members of the Classes uniformly, and Plaintiff’s challenge of these 18 policies hinges on Defendants’ conduct with respect to the Classes as a whole, not on facts or 19 law applicable only to Plaintiff. The factual and legal bases of Defendants’ liability to Plaintiff 20 and to the other members of the Classes are the same. 21 44. Superiority: This case is also appropriate for certification because class 22 proceedings are superior to all other available methods for the fair and efficient adjudication of 23 this controversy. The harm suffered by the individual members of the Classes is likely to have 24 been relatively small compared to the burden and expense of prosecuting individual actions to 25 redress Defendants’ wrongful conduct. Absent a class action, it would be difficult, if not 26 impossible, for the individual members of the Classes to obtain effective relief from Defendants. 27 Even if members of the Classes themselves could sustain such individual litigation, it would not COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC - 12 - 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 13 of 19 1 be preferable to a class action because individual litigation would increase the delay and expense 2 to all parties and the Court and require duplicative consideration of the legal and factual issues 3 presented. By contrast, a class action presents far fewer management difficulties and provides the 4 benefits of single adjudication, economy of scale, and comprehensive supervision by a single 5 Court. Economies of time, effort, and expense will be fostered and uniformity of decisions will 6 be ensured. 7 45. 8 Plaintiff reserves the right to revise the foregoing “Class Allegations” and “Class Definition” based on facts learned through additional investigation and in discovery. FIRST CAUSE OF ACTION Violations of Revised Code of Washington § 4.24.070 (On behalf of Plaintiff and the Classes) 9 10 11 46. Plaintiff incorporates the foregoing allegations as if fully set forth herein. 12 47. Plaintiff, members of the Classes, and Defendants are all “persons” as defined by 13 RCW § 9.46.0289. 14 48. The state of Washington’s “Recovery of money lost at gambling” statute, RCW 15 4.24.070, provides that “all persons losing money or anything of value at or on any illegal 16 gambling games shall have a cause of action to recover from the dealer or player winning, or 17 from the proprietor for whose benefit such game was played or dealt, or such money or things of 18 value won, the amount of the money or the value of the thing so lost.” 19 49. “Gambling,” defined by RCW § 9.46.0237, “means staking or risking something 20 of value upon the outcome of a contest of chance or a future contingent event not under the 21 person's control or influence.” 22 23 24 50. Defendants’ “coins” sold for use in Defendants’ online casino “thing[s] of value” under RCW § 9.46.0285. 51. Defendant’s online casino games are illegal gambling games because they are 25 online games at which players wager things of value (the coins) and by an element of chance 26 (e.g., by spinning an online slot machine) are able to obtain additional entertainment and extend 27 gameplay (by winning additional coins). COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC - 13 - 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 14 of 19 1 52. Defendants are the proprietors for whose benefit the online gambling games are 2 played because they own (or owned) the Playtika online casino games and operate those games 3 for their own profit. Specifically, CIE was the proprietor who received the benefit from the 4 Classes when it owned and operated Playtika between 2011 and October 2016. 5 53. As such, Plaintiff and the Classes gambled when they purchased coins to wager at 6 Playtika’s online gambling games. Plaintiff and each member of the Classes staked money, in the 7 form of coins purchased with money, at Playtika’s games of chance (e.g., Playtika’s online slot 8 machines) for the chance of winning additional things of value (e.g., coins that extend gameplay 9 without additional charge). 10 11 54. In addition, Playtika’s online slot machines are not “pinball machine[s] or similar mechanical amusement device[s]” as contemplated by the statute because: 12 a. the games are electronic rather than mechanical; 13 b. the games confer replays but they are recorded and can be redeemed on 14 separate occasions (i.e., they are not “immediate and unrecorded”); and 15 c. 16 free games or the number of free games which may be won (e.g., the games allow 17 for different wager amounts and some allow for the player to win on multiple 18 “lines”). 19 55. the games contain electronic mechanisms that vary the chance of winning RCW § 9.46.0285 states that a “‘Thing of value,’ as used in this chapter, means 20 any money or property, any token, object or article exchangeable for money or property, or any 21 form of credit or promise, directly or indirectly, contemplating transfer of money or property or 22 of any interest therein, or involving extension of a service, entertainment or a privilege of 23 playing at a game or scheme without charge.” 24 56. The “coins” Plaintiff and the Classes had the chance of winning in Playtika’s 25 games are “thing[s] of value” under Washington law because they are credits that involve the 26 extension of entertainment and a privilege of playing a game without charge. 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC - 14 - 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 15 of 19 1 57. Playtika’s games are “Contest[s] of chance,” as defined by § RCW 9.46.0225, 2 because they are “contest[s], game[s], gaming scheme[s], or gaming device[s] in which the 3 outcome[s] depend[] in a material degree upon an element of chance, notwithstanding that skill 4 of the contestants may also be a factor therein.” Playtika’s games are programmed to have 5 outcomes that are determined entirely upon chance and a contestant’s skill does not affect the 6 outcomes. 7 58. RCW § 9.46.0201 defines “Amusement game[s]” as games where “The outcome 8 depends in a material degree upon the skill of the contestant,” amongst other requirements. 9 Playtika’s games are not “Amusement game[s]” because their outcomes are dependent entirely 10 upon chance and not upon the skill of the player and because the games are “contest[s] of 11 chance,” as defined by RCW § 9.46.0225. 12 59. As a direct and proximate result of Defendants’ gambling games, Plaintiff Wilson 13 and each member of the Classes have lost money wagering at Defendants’ games of chance. 14 Plaintiff Wilson, on behalf of himself and the Classes, seeks an order (1) requiring Defendants to 15 cease the operation of the gambling games; and/or (2) awarding the recovery of all lost monies, 16 interest, and reasonable attorneys’ fees, expenses, and costs to the extent allowable. 17 18 SECOND CAUSE OF ACTION Violations of the Washington Consumer Protection Act, § RCW 19.86.010, et seq. (On behalf of Plaintiff and the Classes) 19 60. Plaintiff incorporates the foregoing allegations as if fully set forth herein. 20 61. Washington’s Consumer Protection Act, RCW § 19.86.010 et seq. (“CPA”), 21 protects both consumers and competitors by promoting fair competition in commercial markets 22 for goods and services. 23 62. To achieve that goal, the CPA prohibits any person from using “unfair methods of 24 competition or unfair or deceptive acts or practices in the conduct of any trade or commerce. . . .” 25 RCW § 19.86.020. 26 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC - 15 - 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 16 of 19 1 63. The CPA states that “a claimant may establish that the act or practice is injurious 2 to the public interest because it . . . Violates a statute that contains a specific legislative 3 declaration of public interest impact.” 4 64. 5 “The public policy of the state of Washington on gambling is to keep the criminal element out of gambling and to promote the social welfare of the people by limiting the nature and scope of gambling activities and by strict regulation and control. 6 It is hereby declared to be the policy of the legislature, recognizing the close relationship between professional gambling and organized crime, to restrain all persons from seeking profit from professional gambling activities in this state; to restrain all persons from patronizing such professional gambling activities; to safeguard the public against the evils induced by common gamblers and common gambling houses engaged in professional gambling; and at the same time, both to preserve the freedom of the press and to avoid restricting participation by individuals in activities and social pastimes, which activities and social pastimes are more for amusement rather than for profit, do not maliciously affect the public, and do not breach the peace.” 7 8 9 10 11 12 13 65. 16 66. 19 20 21 22 23 24 Defendants’ wrongful conduct occurred in the conduct of trade or commerce-- i.e., while Defendants were engaged in the operation of making computer games available to the public. 17 18 Defendants have violated RCW § 9.46.010, et seq., because its online casino games are illegal online gambling games as described in ¶¶ 46 to 59 supra. 14 15 Defendants violated RCW § 9.46.010, et seq. which declares that: 67. Defendants’ acts and practices were and are injurious to the public interest because Defendants, in the course of its business, continuously advertised to and solicited the general public in Washington State and throughout the United States to play its unlawful games of chance. This was part of a pattern or generalized course of conduct on the part of Defendants, and many consumers have been adversely affected by Defendants’ conduct and the public is at risk. 68. Defendants have profited immensely from their operation of unlawful games of chance, amassing hundreds of millions of dollars from the losers of their games of chance. 25 26 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC - 16 - 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 17 of 19 1 69. As a result of Defendants’ conduct, Plaintiff and the Class members were injured 2 in their business or property—i.e., economic injury—in that they lost money wagering on 3 Defendants’ unlawful games of chance. 4 70. Defendants’ unfair or deceptive conduct proximately caused Plaintiff’s and the 5 members of the Classes’ injury because, but for the challenged conduct, Plaintiff and the 6 members of the Classes would not have lost money wagering at or on Defendants’ games of 7 chance, and they did so as a direct, foreseeable, and planned consequence of that conduct. 8 9 10 71. violation and recover actual damages and treble damages, together with the costs of suit, including reasonable attorneys’ fees. 11 THIRD CAUSE OF ACTION Unjust Enrichment (On behalf of Plaintiff and the Classes) 12 13 14 Plaintiff, on his own behalf and on behalf of the Classes, seeks to enjoin further 72. Plaintiff incorporates by reference the foregoing allegations as if fully set forth 73. Plaintiff and the Classes have conferred a benefit upon Defendant in the form of herein. 15 16 the money Defendants received from them for the purchase of coins to wager at their online 17 casino games. 18 19 74. Defendants appreciate and/or have knowledge of the benefits conferred upon them by Plaintiff and the Classes. 20 75. Under principles of equity and good conscience, Defendants should not be 21 permitted to retain the money obtained from Plaintiff and the members of the Classes, which 22 Defendants have unjustly obtained as a result of its unlawful operation of slot machines and/or 23 gambling devices. As it stands, Defendants have retained millions of dollars in profits generated 24 from their unlawful games of chance and should not be permitted to retain those ill-gotten 25 profits. 26 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC - 17 - 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 18 of 19 1 76. Accordingly, Plaintiff and the Classes seek full disgorgement and restitution of 2 any money Defendants have retained as a result of the unlawful and/or wrongful conduct alleged 3 herein. 4 5 6 7 PRAYER FOR RELIEF Plaintiff Sean Wilson, individually and on behalf of all others similarly situated, respectfully requests that this Court enter an Order: a) Certifying this case as a class action on behalf of the Classes defined above, 8 appointing Sean Wilson as representative of the Classes, and appointing his counsel as class 9 counsel; 10 b) Declaring that Defendants’ conduct, as set out above, violates the CPA; 11 c) Entering judgment against Defendants, in the amount of the losses suffered by 12 Plaintiff and each member of the Classes; 13 d) Enjoining Defendants from continuing the challenged conduct; 14 e) Awarding damages to Plaintiff and the members of the Classes in an amount to be 15 16 17 determined at trial, including trebling as appropriate; f) Awarding restitution to Plaintiff and members of the Classes in an amount to be determined at trial, and requiring disgorgement of all benefits that Defendants unjustly received; 18 g) Awarding reasonable attorney’s fees and expenses; 19 h) Awarding pre- and post-judgment interest, to the extent allowable; 20 i) Entering judgment for injunctive and/or declaratory relief as necessary to protect 21 22 the interests of Plaintiff and the Classes; and j) Awarding such other and further relief as equity and justice require. 23 24 JURY DEMAND Plaintiff requests a trial by jury of all claims that can be so tried. 25 26 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC - 18 - 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Case 3:18-cv-05277-RBL Document 1 Filed 04/06/18 Page 19 of 19 Respectfully Submitted, 1 2 Dated: April 6, 2018 By: /s/Janissa A. Strabuk /s/Cecily C. Shiel 3 4 TOUSLEY BRAIN STEPHENS, PLLC Janissa A. Strabuk [email protected] Cecily C. Shiel [email protected] 1700 Seventh Avenue, Suite 2200 Seattle, Washington 98101-4416 Tel: 206.682.5600 Fax: 206.682.2992 5 6 7 8 9 EDELSON PC Benjamin H. Richman* [email protected] 350 North LaSalle Street, Suite 1400 Chicago, Illinois 60654 Tel: 312.589.6370 Fax: 312.589.6378 10 11 12 13 14 Rafey Balabanian* [email protected] 123 Townsend Street, Suite 100 San Francisco, California 94107 Tel: 415.212.9300 Fax: 415.373.9435 15 16 17 18 19 *Pro hac vice admission to be sought. 20 Attorneys for Plaintiff and the Putative Class 21 22 23 24 25 26 27 COMPLAINT—CLASS ACTION Case No. T OUSLEY B RAIN S TEPHENS , PLLC - 19 - 1700 S eventh A venue,S uite 2200 S eattle,W ashington 98101-4416 T el:206.682.5600 • Fax:206.682.2992 Comments are closed.
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