IMGL Magazine July 2023

VIDEO GAMBLING

the games. Thus, all Phillips’ claims were dismissed. 5 While the Fourth Circuit affirmed the previously reported holding in Mason, and the Illinois District Court followed similar logic, the Ninth Circuit overruled the trial court in Kater v. Churchill Downs Inc., 886 F.3d 784 (9th Cir. 2018). The Kater case centered around a virtual casino, dubbed the Big Fish Casino, that offered players the ability to receive free daily deposits of chips that could be used to play a variety of casino games. These game chips could also be purchased with real-world money if a player did not want to wait until the next

day’s deposit of free credits, and could be transferred to another player for a fee charged by the game operator. Unlike Mason, there was not a separate virtual world, or virtual resources that were useful within the virtual world. Instead, the chips awarded from successful games of chance that extended game play time. Kater alleged violations of Washington’s Recovery of Money Lost at Gambling Act, the Washington Consumer Protection Act, and unjust enrichment. The Ninth Circuit determined that the trial court erred when it dismissed the case with prejudice and also erred in holding that the virtual

5 Ristic v. Machine Zone, Inc., No. 15-CV-8996, 2016 WL 4987943 (N.D. Ill. Sept. 19, 2016), which dealt with an Illinois player seeking to recover alleged gambling losses based on the same application and casino gaming present in Mason, followed similar reasoning regarding “winners” and “losers”.

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