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`Rafey S. Balabanian (SBN 315962)
`rbalabanian@edelson.com
`Todd Logan (SBN 305912)
`tlogan@edelson.com
`Brandt Silver-Korn (SBN 323530)
`bsilverkorn@edelson.com
`EDELSON PC
`123 Townsend Street, Suite 100
`San Francisco, California 94107
`Tel: 415.212.9300 / Fax: 415.373.9435
`
`Counsel for Plaintiffs and the Proposed Class
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`
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
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`
`KATHLEEN WILKINSON, NANCY
`URBANCZYK, and LAURA PERKINSON,
`individually and on behalf of all others
`similarly situated,
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`Plaintiffs,
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`v.
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`FACEBOOK, INC., a Delaware corporation,
`
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`Defendant.
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`Case No. _________________
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`CLASS ACTION COMPLAINT
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`JURY DEMAND
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`Plaintiffs Kathleen Wilkinson, Nancy Urbanczyk, and Laura Perkinson, individually and
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`on behalf of a proposed class, bring this Class Action Complaint against Facebook, Inc., seeking
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`restitution, damages, an injunction, and other appropriate relief from Facebook’s ongoing
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`participation in an illegal internet gambling enterprise. Plaintiffs allege as follows upon personal
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`knowledge as to themselves and their own acts and experiences, and as to all other matters, upon
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`information and belief.
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`INTRODUCTION
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`1.
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`Over the last decade, the world’s leading slot machine makers—companies like
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`International Game Technology, Scientific Games Corporation, and Aristocrat Leisure—have
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`teamed up with American technology companies to develop a new product line: social casinos.
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`2.
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`Social casinos are apps, playable from smartphones, tablets, and internet
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`CLASS ACTION COMPLAINT
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`1
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`Case No. __________________
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`Case 3:21-cv-02777 Document 1 Filed 04/16/21 Page 2 of 28
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`browsers, that make the “authentic Vegas-style1” experience of slot machine gambling available
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`to consumers anywhere and anytime. See Figure 1 (Screenshot of DoubleDown Casino
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`Gameplay). By moving their casino games directly onto the phones and computers of players,
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`and by leveraging an innocuous-sounding “free-to-play” model,2 social casino companies, along
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`with Facebook, Google, and Apple (the “Platforms”), have found a way to smuggle slot
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`machines into the homes of consumers nationwide, twenty-four hours a day and three-hundred-
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`sixty-five days a year.
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`3.
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`Just like Las Vegas slot machines, social casinos allow users to purchase virtual
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`“chips” in exchange for real money, and then to gamble those chips at slot machine games in
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`hopes of winning still more chips to keep gambling. In DoubleDown Casino, for example,
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`players purchase “chip packages” costing up to $499.99. See Figure 2 (Screenshot of “Popular”
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`Chip Packages in DoubleDown Casino). But unlike Las Vegas slots, social casinos do not allow
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`players to cash out their chips. Instead, purchased chips and won chips alike can be used only for
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`more slot machine “spinning.”
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` Figure 1
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` Figure 2
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`1
`Form F-1/A DoubleDown Interactive Co., Ltd.,
`https://sec.report/Document/0001193125-20-183157/.
`2
`This term is a misnomer. It refers to a business model by which the initial download of
`the game is free, but companies reap huge profits by selling “in-game” items (known generally
`as “in-app purchases”).
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`CLASS ACTION COMPLAINT
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`Case No. __________________
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`4.
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`Nevertheless, like Las Vegas slots, social casinos are extraordinarily profitable
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`and highly addictive. Social casinos are so lucrative because they mix the addictive aspects of
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`traditional slot machines with the power of the Platforms, including Defendant Facebook, to
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`leverage big data and social network pressures to identify, target, and exploit consumers prone to
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`addictive behaviors.3
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`5.
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`Simply put, the social casino apps do not, and cannot, operate and profit at such a
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`high level from these illegal games on their own. Their business of targeting, retaining, and
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`collecting losses from addicted gamblers is inextricably entwined with the Platforms. Not only
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`do the Platforms retain full control over allowing social casinos into their stores, and their
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`distribution and promotion therein, but they also share directly in a substantial portion of the
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`gamblers’ losses, which are collected and controlled by the Platforms themselves.
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`6.
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`Because the Platforms are the centers for distribution and payment, social casinos
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`gain a critical partner to retain high-spending users and collect player data, a trustworthy
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`marketplace to conduct payment transactions, and the technological means to update their apps
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`with targeted new content designed to keep addicted players spending money.
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`7.
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`For example, in 2019, PBS NewsHour reported:
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`[w]e obtained leaked company documents that show how [a social casino’s] VIP system
`tracks players by their Facebook IDs, closely monitors their game play, and then prods
`people to keep them spending. They refer to their VIPs as whales, a term taken from the
`casino industry to describe big spenders.
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`Social casinos now use behavioral analysis software to quickly identify people who are
`likely to become big spenders. Behaviors like increasing your bet, or playing frequently,
`are signals to the companies, and they target these players with heavy marketing, and
`label them, proto-whales…
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`Facebook's website shows how it tracks people online, and can predict who is likely to
`spend big by analyzing user data. Facebook helps social casinos find those potential
`whales. It charges a premium to nudge players to spend more, to target people whose
`online behavior might be a sign of addiction.4
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`3
`See, e.g., How social casinos leverage Facebook user data to target vulnerable gamblers,
`PBS NEWS HOUR, youtube.com/watch?v=FFtkFLNJZfM.
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`4
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`Id.
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`CLASS ACTION COMPLAINT
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`3
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`Case No. __________________
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`

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`Case 3:21-cv-02777 Document 1 Filed 04/16/21 Page 4 of 28
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`8.
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`Last year alone, consumers purchased and gambled away an estimated $6 billion
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`in social casino virtual chips.5 Indeed, of the top twelve grossing apps available on Defendant
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`Facebook, nine are social casinos. See Figure 3 (Screenshot of “Top Grossing” Facebook Apps).
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`Figure 3
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`9.
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`By utilizing Facebook for distribution and payment processing, the social casinos
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`entered into a mutually beneficial business partnership. In exchange for distributing the casino
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`games, providing them valuable data and insight about their players, and collecting money from
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`consumers, Facebook (and the other Platforms) take a 30 percent commission off of every
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`wager, earning them billions in revenue. By comparison, the “house” at a traditional casino only
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`takes 1 to 15 percent, while also taking on significant risk of loss in its operation. Facebook’s 30
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`percent rake, on the other hand, is guaranteed for its ability to act as a casino “host” and bankroll.
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`10.
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`The result (and intent) of this dangerous partnership is that consumers become
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`addicted to social casino apps, maxing out their credit cards with purchases amounting to tens or
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`even hundreds of thousands of dollars. Consumers addicted to social casinos suffer a variety of
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`non-financial damages ranging from depression to divorce to attempted suicide.
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`5
`SciPlay Net Income Skyrockets 127 Percent, as Social Gaming Embraced by Americans
`Sheltered at Home, CASINO.ORG, https://www.casino.org/news/sciplay-net-income-skyrockets-
`127-percent-as-social-gaming-embraced/.
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`CLASS ACTION COMPLAINT
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`4
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`Case No. __________________
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`

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`Case 3:21-cv-02777 Document 1 Filed 04/16/21 Page 5 of 28
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`11.
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`These devastating consequences are not hypothetical or hyperbole: below are
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`excerpts of sworn testimony from individuals describing their experiences with three different
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`social casinos at issue in this case:
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`• DoubleDown Casino: “I was drawn to DoubleDown because I could play
`the same games that I played when I went to real casinos. Overall, I
`estimate that I have spent over $40,000 on chips in DoubleDown Casino. I
`am addicted to DoubleDown Casino . . . I knew being on DoubleDown
`Casino every day for hours was a problem, but I couldn’t seem to stop. I
`believe that DoubleDown is taking advantage of people’s addictions. They
`know that gambling is addictive, and they act exactly like a physical casino
`that pays out money. I feel alone and embarrassed about spending money to
`do something that only feeds my addiction. DoubleDown Casino consumes
`you, and makes you feel like you always have to go play. I feel guilty
`because I’ve spent money on DoubleDown that I’ve needed to pay bills or
`buy food.” Exhibit 1, Declaration of Willa Moore [emphasis added].
`
`• DoubleDown Casino: “I believe I have spent close to $25,000 on
`DoubleDown Casino. I would buy the chips with a credit card which I
`couldn’t pay in-full, so there’s interest on top of that too . . . I was a well-
`respected, active member of my community who owned my own business
`for 36 years. But when I retired, and my fellow started having health
`problems, DoubleDown Casino made me fall into the trap of escape and
`adrenaline rush to cope with all my other responsibilities. When I won, it
`was just great. When I lost, and started buying more and more chips, I felt
`lower than pond scum. I was sick to my stomach, felt like a total loser,
`wondered about suicide (although I would never leave my partner), could
`not sleep, had anxiety attacks with a rushing heart, and couldn’t eat. I just
`couldn’t understand how I could let it get so out of control. It was as if it
`had a power over me that I couldn’t break. I couldn’t stop.” Exhibit 2,
`Declaration of Jan Saari [emphasis added].
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`• Jackpot Party Casino: “Overall, I believe that I have spent between
`$10,000-$20,000 playing Jackpot Party Casino. I was addicted to Jackpot
`Party Casino and I hate that . . . This kind of loss put a huge strain on my
`ability to even buy food . . . I believe Jackpot Party Casino had been taking
`advantage of my addiction . . . This game hurt me and the worst part was
`that when my husband was alive, he would say, ‘You’re not spending
`money on there are you?’ and I lied. I hate that I have to live with that
`now.” Exhibit 3, Declaration of Laura Perkinson [emphasis added].
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`• Jackpot Party Casino: “I believe that I’ve spent at least $30,000 on
`Jackpot Party Casino . . . I am going through a divorce right now, in part
`because of how much money I spent on Jackpot Party . . . Scientific Games
`will provide incentives to their top spenders so that they continue to spend.
`I have received Christmas gifts two times. They have sent me a robe, oils,
`phone charger, bath bombs, a blanket, and more. I know that they have sent
`other players flowers and candies . . . This game has changed my way of
`thinking and caring. I never thought I would get addicted to anything
`except cigarettes, but this has taken too much of my life away. I don’t
`know how my life would be different without this game, but I know that it
`would be better and I know that I would be much better off financially . . . I
`wish it didn’t exist.” Exhibit 4, Declaration of Donna Reed [emphasis
`added].
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`CLASS ACTION COMPLAINT
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`• High 5 Casino: “I have spent at least $10,000 on coins in High 5 Casino . .
`. I believe I am addicted to High 5 Casino . . . I have tried to quit but I
`believe three weeks is the longest amount of time I’ve ever been able to
`stop . . . Sometimes I feel guilty about playing High 5 Casino and spending
`so much money. My husband does not know I have spent money on it. My
`grandkids will sometimes ask for money and I can’t give it to them because
`I have to save it for this game.” Exhibit 5, Declaration of Aida Glover
`[emphasis added].
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`12.
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`13.
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`Unsurprisingly, social casinos are illegal under many states’ gambling laws.
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`As the Ninth Circuit held in Kater v. Churchill Downs Inc., 886 F.3d 784, 785
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`(9th Cir. 2018):
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`In this appeal, we consider whether the virtual game platform “Big Fish
`Casino” constitutes illegal gambling under Washington law. Defendant–
`Appellee Churchill Downs, the game’s owner and operator, has made
`millions of dollars off of Big Fish Casino. However, despite collecting
`millions in revenue, Churchill Downs, like Captain Renault in Casablanca,
`purports to be shocked—shocked!—to find that Big Fish Casino could
`constitute illegal gambling. We are not. We therefore reverse the district
`court and hold that because Big Fish Casino’s virtual chips are a “thing of
`value,” Big Fish Casino constitutes illegal gambling under Washington law.
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`14.
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`As an instructive example, DoubleDown Casino is illegal both in Washington and
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`here in California (where the Platforms, including Defendant Facebook, host it and collect their
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`30% rake). This year, consumers will purchase approximately $300 million worth of virtual
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`casino chips in DoubleDown Casino. That $300 million will be divided up approximately as
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`follows: $170 million to DoubleDown; $30 million to International Game Technology (“IGT”)
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`(a multinational slot machine manufacturer that licenses slot machine game intellectual property
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`to DoubleDown); and—as particularly relevant here—the remaining $100 million to Facebook
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`and the other Platforms (for hosting the app, driving vulnerable consumers to it, and processing
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`the payments for those consumers’ virtual chip purchases).
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`15.
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`In other words, despite knowing that DoubleDown Casino is illegal, Facebook
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`and the other Platforms continue to maintain a sizable (30%) financial interest by hosting the
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`game, driving customers to it, and acting as the bank.
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`16.
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`As such, DoubleDown, Facebook, and the other Platforms are all liable as co-
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`conspirators to an illegal gambling enterprise. Moreover, DoubleDown Casino is just one of
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`more than fifty social casino apps (the “Illegal Slots”) that the Platforms illegally host and profit
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`CLASS ACTION COMPLAINT
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`6
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`Case No. __________________
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`

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`Case 3:21-cv-02777 Document 1 Filed 04/16/21 Page 7 of 28
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`from.
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`17.
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`Consequently, Facebook and the other Platforms—alongside the Illegal Slot
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`companies—are liable as co-conspirators to an illegal gambling conspiracy.
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`18.
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`Defendant Facebook, for its part, is a direct participant in an informal association
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`and enterprise of individuals and entities with the explicit purpose of knowingly devising and
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`operating an online gambling scheme to exploit consumers and reap billions in profits (the
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`“Social Casino Enterprise”).
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`19.
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`This ongoing Enterprise necessarily promotes the success of each of its members:
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`Social casino operators, like DoubleDown, need Platforms like Facebook, Apple, and Google, to
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`access consumers, host their games, and process payments. The Platforms, for their part, need
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`developers like DoubleDown to publish profit-driven and addictive applications on their
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`platforms to generate massive revenue streams.
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`20.
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`Through this case, Plaintiffs seek to force Facebook to stop participating in, and
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`to return to consumers the money it has illegally profited from, the Social Casino Enterprise.
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`21.
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`Plaintiffs, on behalf of the putative Class, bring claims for damages and for
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`injunctive relief under the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. §
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`1961, et seq. (“RICO”), and California’s Unfair Competition Law, Business and Professions
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`Code § 17200, et seq. (“UCL”).
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`PARTIES
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`22.
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`Plaintiff Kathleen Wilkinson is a natural person and a citizen of the State of
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`Montana.
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`23.
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`24.
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`Washington.
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`Plaintiff Nancy Urbanczyk is a natural person and a citizen of the State of Illinois.
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`Plaintiff Laura Perkinson is a natural person and a citizen of the State of
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`25.
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`Defendant Facebook, Inc. is a corporation existing under the laws of the State of
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`Delaware with its principal place of business located at 1 Hacker Way, Menlo Park, California
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`94025. Facebook regularly conducts and transacts business in this District and throughout the
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`United States. Facebook owns and operates the Facebook App Center.
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`CLASS ACTION COMPLAINT
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`Case No. __________________
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`JURISDICTION AND VENUE
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`26.
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`Federal subject-matter jurisdiction exists under 28 U.S.C. § 1332(d)(2) because
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`(a) at least one member of the proposed class is a citizen of a state different from Defendant, (b)
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`the amount in controversy exceeds $5,000,000, exclusive of interests and costs, and (c) none of
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`the exceptions under that subsection apply to this action.
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`27.
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`The Court has personal jurisdiction over Defendant because Defendant is
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`headquartered in this District and Defendant’s alleged wrongful conduct occurred in and
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`emanated from this District.
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`28.
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`Venue is proper in this District under 28 U.S.C. § 1391(b) because a substantial
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`part of the events giving rise to Plaintiffs’ claims occurred in and emanated from this District.
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`GENERAL ALLEGATIONS
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`I.
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`Social Casinos Are Illegal Slot Machines Under California Law .
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`29.
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`30.
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`Slot machines have long been outlawed in California.
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`California law recognizes that a device can be an illegal slot machine without
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`offering users the opportunity to win money.
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`31.
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`In fact, if a gaming machine has the look and feel of a slot machine, accepts real
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`money for gameplay, and rewards a winning spin with an “additional chance or right to use the
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`slot machine or device,” the device is an illegal slot machine.
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`32.
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`Consequently, social casinos, as described herein, are illegal slot machines under
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`California law.
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`33.
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`California gambling law is, on this point, consistent with the laws of many other
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`states—including Washington. In Kater, for example, the Ninth Circuit held that social casinos
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`are illegal under Washington law because, while users cannot win money, social casino chips are
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`“things of value” because they can be purchased for money, are awarded as prizes in social
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`casino slot machines, and then can be used to allow players to keep spinning social casino slot
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`machines. After two years of subsequent litigation, the parties in Kater reached a $155 million
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`CLASS ACTION COMPLAINT
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`8
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`Case No. __________________
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`

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`nationwide class action settlement. The settlement was finally approved on February 11, 2021.6
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`34.
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`California aggressively regulates all forms of gambling. One reason it does so is
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`to prevent consumers from being cheated by professional gambling operations.
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`35.
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`Because social casinos have previously operated as if they were not subject to
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`gambling regulations, they do not comply with any of the regulations that govern the operation
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`of slot machines.
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`36.
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`Notably, while any legitimately operated slot machine must randomize its results,
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`social casinos do not randomize their results. Instead, social casinos tailor “wins” and “losses” in
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`such a way as to maximize addiction (and, in turn, revenues). As the CEO of DoubleDown
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`Casino once explained, “[o]ur games aren’t built to be bulletproof like you’d need to be if you’re
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`a real gambling company. We can do things to make our games more [fun] that if you were an
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`12
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`operator in Vegas you’d go to jail for, because we change the odds just for fun.”7
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`37.
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`In other words, social casinos are not just illegal under California law, but they
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`would not be legal slot machines under any state law as they cheat players out of a legitimately
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`randomized slot machine experience. Not only can players never actually win money, but their
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`financial losses are maximized by deceptive gameplay tweaks that would never be allowed in a
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`legitimate slot machine.
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`18
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`II.
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`Facebook Hosts and Facilitates At Least Fifty Illegal Social Casinos.
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`38.
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`The Platforms, including Defendant Facebook, have directly assisted in creating
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`the unregulated market of virtual casino games from the outset of the industry.
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`39.
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`Before gaining access to these social media platforms, the Illegal Slots used
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`6
`Settlements in two related cases were also finally approved in February 2021. Three more
`related cases are being litigated in Washington, against the owners and operators of certain social
`casino games. See Wilson v. Huuuge, Inc., No. 3:18-cv-05276, 2018 WL 5921019 (W.D. Wash.
`Nov. 13, 2018) (settled); Wilson v. Playtika, Ltd., 349 F. Supp. 3d 1028, 1041 (W.D. Wash. Nov.
`20, 2018) (settled); Fife v. Sci. Games Corp., No. 2:18-CV-00565-RBL, 2018 WL 6620485, at
`*4 (W.D. Wash. Dec. 18, 2018) (in litigation); and Wilson v. PTT, LLC, 351 F. Supp. 3d 1325,
`1337 (W.D. Wash. Dec. 14, 2018) (same); Benson v. Double Down Interactive, LLC, 798 F.
`App’x 117 (9th Cir. 2020) (same).
`7
`Gambling giant IGT buying Double Down for $500M, moving into Facebook games,
`GEEK WIRE, https://www.geekwire.com/2012/gambling-giant-igt-buying-doubledown-500m-
`moving-facebook-games/ [emphasis added].
`
`CLASS ACTION COMPLAINT
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`9
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`Case No. __________________
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`

`

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`Case 3:21-cv-02777 Document 1 Filed 04/16/21 Page 10 of 28
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`methods like loyalty cards to track data on how much gamblers spent, how frequently they
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`played, or how often they bet. The Platform partnerships upgraded their business model to an in-
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`app payment system and provided additional user data which skyrocketed revenue by providing
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`them with access to a whole new market of consumers.
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`40.
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`The core marketing for the Illegal Slots is accomplished in concert with the
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`Platforms, and their systems are inextricably linked. DoubleDown described this very setup in a
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`public filing:
`
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`Our games are distributed through several main platform providers, including
`Apple, Facebook, Google, and Amazon, which also provide us valuable
`information and data, such as the rankings of our games. Substantially all of our
`revenue is generated by players using those platforms. Consequently, our
`expansion and prospects depend on our continued relationships with these
`providers.
`….
`
`
`We focus our marketing efforts on acquiring new players and retaining existing
`players. We acquire players both organically and through paid channels. Our paid
`marketing includes performance marketing and dynamic media buying on
`Facebook, Google, and other channels such as mobile ad networks. Underlying
`our paid marketing efforts are our data analytics that allow us to estimate the
`expected value of a player and adjust our user acquisition spend to a targeted
`payback period. Our broad capabilities in promotions allow us to tailor
`promotional activity around new releases, execute differentiated multi-channel
`campaigns, and reach players with preferred creative content.
`….
`
`
`Our player retention marketing includes advertising on Facebook as well as
`outreach through email, push notifications, and social media posts on channels
`such as Facebook, Instagram, and Pinterest. Our data and analytics also inform
`our retention marketing efforts. Campaigns are specially designed for each
`channel based upon player preferences for dimensions such as time of day and
`creative content. We consistently monitor marketing results and return on
`investment, replacing ineffective marketing tactics to optimize and improve
`channel performance.
`….
`
`
`We employ a rigorous, data-driven approach to player lifecycle management
`from user acquisition to ongoing engagement and monetization. We use
`internally-developed analytic tools to segment and target players and to
`optimize user acquisition spend across multiple channels.
`….
`
`
`We continuously gather and analyze detailed customer play behavior and
`assess this data in relation to our judgments used for revenue recognition.8
`
`
`8
`Form F-1/A DoubleDown Interactive Co., Ltd.,
`https://sec.report/Document/0001193125-20-183157/.
`
`CLASS ACTION COMPLAINT
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`10
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`Case No. __________________
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`Case 3:21-cv-02777 Document 1 Filed 04/16/21 Page 11 of 28
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`41.
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`By moving to online platforms for marketing, distribution, and payment
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`processing, Defendant Facebook entered into a mutually beneficial business partnership with the
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`Illegal Slots. In exchange for pushing and distributing the social casino apps and collecting
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`money from consumers, Facebook and the other Platforms take a 30 percent commission off of
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`every in-app purchase, earning them billions in revenue.
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`42.
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`The Platforms, through their app review process, are keenly aware of the illegal
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`and deceptive nature of the Illegal Slots. Likewise, because they act as the “bank” for the Illegal
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`Slots, the Platforms are entirely aware that some consumers spend hundreds of thousands on the
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`Illegal Slots.
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`43.
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`Furthermore, on information and belief, in the wake of the Kater decision, the
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`Platforms did not remove any social casinos from their offerings and conferred with each other at
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`that time, jointly deciding that they would each continue to offer illegal social casino games.
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`44.
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`At all relevant times, Facebook and the Platforms have known of the unlawful
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`nature of the Illegal Slots and nonetheless have subjected the general public to those risks in
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`order to maximize profits at the expense of the public’s health and welfare.
`
`A.
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`The Illegal Slots
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`45.
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`Each of the following fifty social casinos offered by Facebook (together the
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`“Illegal Slots”) is an illegal slot machine under California law.9
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`Game Title
`#
`1 DoubleDown Casino
`2
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`Slotomania Slot Machines
`
`Figure 4 – The Illegal Slots
`Facebook URL
`https://apps.facebook.com/doubledowncasino/
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`https://apps.facebook.com/slotomania/
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`3
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`4
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`Jackpot Party Casino Slots
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`https://apps.facebook.com/jackpotpartycasino/
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`House of Fun - Slots
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`https://apps.facebook.com/houseoffun/
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`5 DoubleU Casino
`6 High 5 Casino Real Slots
`7 Heart of Vegas
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`https://apps.facebook.com/doubleucasino/
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`https://apps.facebook.com/highfivecasino
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`https://apps.facebook.com/heart_of_vegas
`
`
`9
`For the Court’s convenience, an iPad containing Apple-based versions of the Illegal Slots
`will be lodged with the Court as Exhibit 6. Upon request from Facebook’s appearing counsel, a
`copy of the iPad will be produced to Facebook. For the purposes of the claims alleged here, the
`Apple-based versions of the Illegal Slot games are materially indistinguishable from the
`Facebook-based versions.
`
`CLASS ACTION COMPLAINT
`
`
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`11
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`Case No. __________________
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`

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`Case 3:21-cv-02777 Document 1 Filed 04/16/21 Page 12 of 28
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`https://apps.facebook.com/caesars/
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`https://apps.facebook.com/hititrich/
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`https://apps.facebook.com/playmyvegas
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`https://apps.facebook.com/mesmogames/
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`https://apps.facebook.com/rockncash/
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`https://apps.facebook.com/1672695549623058/
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`https://apps.facebook.com/oldvegasslots/
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`https://apps.facebook.com/takefiveslots/
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`https://apps.facebook.com/quickhitslots/
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`https://apps.facebook.com/vegas_downtown_slots
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`https://apps.facebook.com/diamondskycasino
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`https://apps.facebook.com/goldfishcasinoslots/
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`https://apps.facebook.com/657457464407450/
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`https://apps.facebook.com/wizardofozslots/
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`https://apps.facebook.com/hotshotcasino/
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`https://apps.facebook.com/scatterslots/
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`https://apps.facebook.com/jackpotjoyslots/
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`https://apps.facebook.com/realtexasholdem/
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`https://apps.facebook.com/infinityslots/
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`https://apps.facebook.com/letsvegas/
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`https://apps.facebook.com/omgfortune/
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`https://apps.facebook.com/goldpartycasino/
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`https://apps.facebook.com/vegasliveslots/
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`https://apps.facebook.com/mykonamislots/
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`https://apps.facebook.com/spinvegasslots
`
`8 Caesars Slots
`9 Hit It Rich! Casino Slots
`10 myVEGAS Slots
`11 GSN Casino
`12 Rock N’ Cash Casino Slots
`13 Huuuge Casino
`14 Old Vegas Slots
`15 Take5 Free Slots
`16 Quick Hit Slots
`17 Vegas Downtown Slots &
`Words
`18 Diamond Sky Casino
`19 Gold Fish Casino Slots
`20 Billionaire Casino
`21 Slots - Wizard of Oz
`22 Hot Shot Casino Slots
`23 Scatter Slots
`24 Jackpotjoy Slots
`25 Real Casino - Free Slots
`26 Infinity Slots
`27 Let's Vegas Casino-Slot
`Roulette
`28 OMG! Fortune FREE Slots
`29 Gold Party Casino - Free
`Slots
`30 Vegas Live Slots
`31 my KONAMI Slots
`32 Spin Vegas Slots
`33 Cashman Casino
`https://apps.facebook.com/cashman_casino
`34 Baba WILD Slots & Casino https://apps.facebook.com/babacasino/
`35 MONOPOLY Slots!
`36 Slotica Casino - Free Slots
`
`https://apps.facebook.com/monopoly-slots/
`https://apps.facebook.com/slotica_slots/
`
`37 Mirrorball Slots
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`https://apps.facebook.com/mirrorballslots/
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`38 Slots Era
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`https://apps.facebook.com/slotsera/
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`39 CasinoStar - Free Slots
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`https://apps.facebook.com/casinostar
`
`40 Slots - Classic Vegas
`Casino
`41 Lucky Time Slots
`
`42 Vegas Star Casino - Free
`Slots
`
`https://apps.facebook.com/classic-vegas/
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`https://apps.facebook.com/luckytimeslots/
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`https://apps.facebook.com/vegasstarcasino
`
`CLASS ACTION COMPLAINT
`
`
`
`12
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`Case No. __________________
`
`

`

`
`
`Case 3:21-cv-02777 Document 1 Filed 04/16/21 Page 13 of 28
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`43 Willy Wonka Slots Free
`Casino
`44 DoubleHit Casino - Free
`Slots
`45 Winning Slots
`
`https://apps.facebook.com/wonkaslots/
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`https://apps.facebook.com/doublehitcasino/
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`https://apps.facebook.com/winningslots/
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`46 Our Slots
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`https://apps.facebook.com/our-slots/
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`47 Gambino Slots
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`https://apps.facebook.com/gambino-slots/
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`48 Slots Farm
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`https://apps.facebook.com/slots_farm/
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`49 Blazing 7s Slots
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`https://apps.facebook.com/blazingsevensslots/
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`50 VegasTower Casino - Free
`Slots
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`https://apps.facebook.com/vegastowercasino/
`
`
`
`
`46. Most or all of the Illegal Slots are also hosted and promoted by the other Platform
`
`members of the Social Casino Enterprise: Apple and Google.
`
`B.
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`Facebook’s Facilitation, Promotion, and Control Over the Illegal Slots
`
`47.
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`Facebook, for its part, routinely facilitates the success of social casinos by
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`counseling the app developers through the app launch process and providing them with resources
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`and business tools necessary to maximize the platform’s powerful social features.10
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`48.
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`Facebook Products, such as App Ads (targets lookalike audiences to increase
`
`engagement), App Invite (solicits new players via Game Requests), Facebook Analytics for Apps
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`(tracks the time spent between installation and purchase and devises strategies to turn out higher
`
`profits), Facebook login (facilitates easy, familiar sign-up), and Sharing (creates viral social
`
`distribution), all enable the Illegal Slots to acquire new users and retain high-spenders. Social
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`features keep players engaged longer, which in turn dr