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“Just eight years ago, this court reiterated that ‘each state is free to act on its own’ in regulating sports betting,” the petition says. “But Kalshi has a different view. Kalshi bills itself as ‘the first app for legal sports betting in all 50 states’ and believes it can offer that legal sports betting without following the sports-gambling laws of any of those 50 states.”

In a statement, Kalshi spokesperson Dani Lever said the platform is “an open, nationwide, financial exchange” that “cannot be regulated by 50 different regulators”, per CDC Gaming.

“Both the Third Circuit and the District of New Jersey side with Kalshi, because the CFTC’s exclusive jurisdiction prompt state law,” Lever said, adding that “nothing in New Jersey’s filing” changes that view.

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Notably for highly engaging verticals light online slots, if players are receiving a smaller-than-expected RTP (return to player), or bonuses have been restricted, they could again transition to an illegal offering where there are no such restrictions.

As has been flagged in previous reports, Regulus highlighted that the top 1% of active customers accounts for almost 50% of black market revenue across Europe. This follows a similar trend across licensed gambling as the report highlights “online gambling is a consumer discretionary expenditure item. This means a large proportion of expenditure is concentrated into a relatively small number of players.”

In its market-specific breakdown, the report noted a “rapid reduction in channelling” in the UK, following the increased use of affordability checks.

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“You have to follow that chain,” Madsen says. In some cases, that chain can involve multiple layers. “A site might redirect ten times before reaching the actual destination.”

Madsen describes Trace2Trace as “a large search engine that continuously crawls websites”.

AI is used, but only towards the end of the process. First, the system gathers objective indicators; AI is then used to assess the overall pattern and probability of a connection. “We only provide evidence-based findings,” Madsen says. “We don’t say that something is a mirror site because we suspect it is. It is only reported when we are 100% confident there is a match.”