Case 1:25-cv-01283-ABA Document 26 Filed 05/09/25 Page 10 of 36
operating within the State. In its first full year of operation, sports wagering delivered over $60
million in revenue to the State. Id. at ¶¶ 3-4. This revenue was directed to the Blueprint for
Maryland’s Future Fund, which supports public education programs. Id. at ¶ 3.
Maryland has an extensive statutory and regulatory framework governing the conduct of
sports wagering within its borders. Ann. Code of Md., St. Gov . (“SG”), §§ 9-1E-01 et seq. and
Code of Maryland Regulations ( “ COMAR ” ), Chapter 36, Title 10. Maryland defines “sports
wagering” as:
the business of accepting wagers on any sporting event by any system or method of wagering, including single-game bets, teaser bets, parlays, over- under, moneyline, pools, exchange wagering, in-game wagering, in-play bets, proposition bets, and straight bets.
SG, § 9-1E-01(j) . “Exchange wagering” is when a “bettor wagers with or against another bettor
through a sports wagering licensee.” COMAR 36.10.01.02.B(24). Under Maryland law, it is
illegal to conduct sports wagering business without the appropriate sports wagering license. Md.
Code Ann., St. Gov., § 9-1E-03(b), § 9-1E-04(b)(6)(ii); Md. Code Ann., Crim. Law § 12-104.
Maryland’s regulation of lawful sports wagerin g is comprehensive. Applicants for a sports
wagering license undergo an extensive investigatory process to determine their integrity and
financial stability. Exhibit 6, Affidavit of J. Philip Metz, Jr. at ¶¶ 4, 8-12. Once licensed, the
Agency ensures that licensees have the required safeguards and internal controls in place. Exhibit
3 at ¶¶ 4-6. Licensees must comply with the technical standards set by the Agency, including
geofencing to ensure that sports wagering in Maryland is limited to those individuals actually
present in Maryland at the time their wager is made. Id. at ¶ 19. Maryland also has significant
regulatory requirements regarding responsible gaming to ensure that those conducting sports
wagering in Maryland do not prey on individuals suffering from gaming addiction. Id. at ¶¶ 13-
14; Exhibit 4 at ¶¶ 17, 18.
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