Okay, let me just say this real fast. I'm going to do the read through. I'm going to do my best not to offer my commentary until the end, but I hope you stick to the end because I do have commentary and I have a part of another lawsuit that ironically it makes that other lawsuit more ironic when I see what uh Drake is accused of in this lawsuit. So hopefully you stick stick with me and then we can also have a couple things we can listen to related to this lawsuit after I finish the read through. Okay, so this is LSA Ridley and Tiffany Hines Stake US users within the United States versus Sweepstakes uh LimitedStakes US, Aubrey Drake Graham, Aiden Ross, and George Nuin. Okay, it says class action complaint. Plaintiffs Leanna Ridley and Tiffany Hines by and through their attorneys bring this action individually and on behalf of all others similarly situated the class against defendants sweepstakes limited stake us Aubrey Drake Graham Aiden Ross and George Wyn collectively defendants plaintiffs make the following allegations upon information and belief except those allegations as to the plaintiffs or their attorneys which are based on personal knowledge nature of the action. This consumer class action seeks to stop stake us, an illegal online gambling platform promoted by Drake, Ross, and Win, and used by Drake, Ross, and Win to obscure transa transmissions of money in furtherance of their ongoing music botting campaigns, from continuing to prey upon consumers, and to impose civil penalties on all defendants to deter future misconduct. stake us, a US storefront for stake.com, has been operating as one of the largest and most profitable illegal online casinos since at least 2022. Stake US was created and marketed to US customers as a social casino that purportedly does not permit real money gambling to bypass to bypass applicable United States, Federal, and Commonwealth of Virginia gambling regulations. Attempt Excuse me. Attempting unsuccessfully to hide behind the facade of a safe and free gambling experience. Stake US misrepresents itself to regulators and consumers. In reality, it operates as an illegal casino. Stake US offers nearly 2,000 casino games and permits players to place bets using specialized casino chips and to cash out their winnings. Stake us offers two types of virtual currency, gold coins and stake cash. Gold coins have no monetary value and cannot be converted into real money. However, stake cash can be redeemed for cryptocurrency or digital gift cards at a rate of one stake cash to one United States dollar. Stake US bundles every purchase of gold coins with stake cash. Thus, when a player purchases gold coins to engage in casino games, they are also purchasing stake cash. If a player is lucky and wins, they can cash out their stake cash for cryptocurrency. But if a player loses their stake cash and wishes to continue gambling, they must buy more worthless gold coins, which will be bundled with more stake cash. Defendants Drake and Ross are paid by stake to promote the the platform. The two have engaged in livereamed gambling, wagering large sums of money that was provided surreptitiously by stake. In other words, through Jake through Drake and Ross, sorry. In other words, though Drake and Ross purported to be gambling with their own stake cash, it was in fact provided to them by the house. Through these and other promotions, stake has bombarded consumers with advertisements appearing on social media platforms depicting its games as safe, legal, and fun. But these casino games are illegal in Virginia and through throughout the United States and have inflicted harm on consumers across the Commonwealth who have lost real money chasing gambling wins on the stake platform. Defendants Drake, Ross, and Wyn have also made use of Stake, including through its US storefront, Stake us, to directly transfer money between and among themselves using Stakes tipping program, an unlimited and wholly unregulated money transmitter that appears to exist outside the oversight of any financial regulator. Defendants have utilized stakes tipping program to interalia transfer gambling proceeds wagered through on the stake platform. In addition, through stakes tipping function, defendants have financed their combined artificial streaming or botting to create fraudulent streams of Drake's music, fabricate popularity, disparage competitors and music label executives, distort recommendation algorithms, and distribute financing for all the foregoing while concealing the flow of funds. At the heart of the scheme, Drake acting directly and through willing and knowledgeable co-conspirators has deployed automated bots and streaming farms to artificially inflate play counts of his music across major flat platforms such as Spotify. These inauthentic streams injected via interstate digital pathways were calibrated to mislead royalty and recommendation engines manufacture popularity, distort playlist and charts and divert both value and audience attention. In tandem, this manipulation has suppressed authentic artists and narrowed consumers access to legitimate content by undermining the integrity of curated curated experiences. Okay, it says stake userto-user tipping and encrypted internal transfer mechanisms have fueled and enabled payments to bot operators and amplifiers to be hidden from public or regulatory view. One example of a publicly documented large value tip is a $100,000 tipping transfer between defendants Drake and Ross in 2023. In December 2024, Drake gave away large sums of money in partnership with Ross and Stake as part of his Drismas giveaway. These tips and many others like them cycled among defendants Drake, Ross, and Win, underwriting botting and paid engagement campaigns. Days before the filing of this complaint, defendant Drake gave defendant Ross a $220,000 car as a gift. Stake US's platforms design which masks counterparties and camouflages withdrawals as generic transactions stemi scrutiny and obstructs tracing of illicit proceeds. Tipping proceeds and other transfers on and from stake us went directly or indirectly from defendant Drake to through or with the knowledge and assistance of defendant Ross and on from there to defendant Wyn. Nwyn served as a facilitator and operational broker alternately converting stakebased cryptocurrency to cash or receiving cash from stake transferred cryptocurrency proceeds. From there when interfaced with bot vendors supervised coordinated amplification strategies and integrated paid clipping campaigns. The clipping campaigns were facilitated through the clipping service and affiliated networks on the X, formerly Twitter, Discord, and Kick platforms. Kick in turn is a betting platform financially underwritten by the founders of stake. Public posts, chat logs, leaked communications, and other records document WIN's direct handling of funds through multiple payment platforms, orchestration of narrative surges and application alongside and as an instrument of Drake and Ross. Plaintiffs and the class are stake users who have been misled by stake us misrepresentations that stake US is a legal, harmless, and safe gaming site when it is in fact not legal, not harmless, and not safe. Stake us pres on consumers in Virginia and nationwide who are lured into real money gambling, exposing consumers to substantial risk of gambling addictions and jeopardizing their and their family's financial well-being. Each of the plaintiffs was influenced to participate and to continue to participate after their initial participation on the stake platform by the online promotional activities of defendant Drake as viewed by each of the plaintiffs. Plaintiffs have been further damaged by the false marketing manipulations and abuses of defendant Drake, who by his own public announcements has been paid some $100 million per year to promote State, as well as defendants Ross and Wyn, who have participated directly in the marketing of stake. US as documented in their many online posts across multiple platforms advertising and endorsing stake. Plaintiffs assert claims under the Racketeer Influenced and Corrupt Organizations Act, RICO, Virginia Consumer Protection Act. Plaintiffs, I'm sorry, and the Virginia Consumer Protection Act. Plaintiffs seek damages, treble damages under RICO, restitution and disgorgement, injunctive and declaratory relief, attorney's fees and costs, and all other relief deemed just and proper. And then this talks about the jurisdiction and venue. Um the plaintiffs reside in Virginia and they're saying that um other class citizens may be different in different states besides them. Um they assert their claims arising under RICO because the court has supplemental judgment supplemental jurisdiction over related state law claims. Substantial part of the events or omissions giving rise to the claims occurred in this district. It says the court has personal jurisdiction over defendants because they transacted business, committed tortous acts and caused injury in this district and purposefully directed the conduct at issue here through interstate wires and platforms accessible and operated in this district. the parties. It says plaintiffs in the class of stake users within the United States, including in the Eastern District of Virginia who during the relevant period were misled by the marketing practices of defendants and were induced to participate in unlawful gambling on the stake platform. Plaintiffs and the class suffered substantial financial and economic harm as alleged herein. defendant. Sweepstakes stake US is a Cypress limited company with its principal place of business located I'm just going to say at Cypress. Sweepstakes also operates a US office in Dallas, Texas. Through its website and brand stake us corresponding advertisements and promotions including targeted advertisements. Stake US intentionally conducts business in Virginia. Defendant Aubrey Drake Graham is a Canadian do domiciliary. At all relevant times, Drake engaged in nationally promoted live streams and financial promotions connected to stake. US that reached this district and caused the other harms to class members residing within this district as described herein. Is the volume too low? Because I still have a lot of reading. So sound check. Is my volume too low for y'all. my normal reading volume, please let me know. I'm gonna take a moment to pause and I'll just get some water, too. Okay, I see you, Jacqueline. I'm just trying to see um overall I'm hoping I get some more feedback cuz sometimes I don't know if it's individual or group and I I can adjust it a little bit. I think if it's group I think I have some more gain. Okay, because if I go too loud then it makes it bad for the overall experience. Okay, volume is good. Volume's okay. Okay, because if I go too loud it'll start having echo, possible other feedback and stuff like that. So I have to check with the Okay. All right. I have to make sure because some a lot of times it is me and my mic, but my new platform is a little better. Okay. Oops. Sorry. Sorry, y'all. All right. So, it says, "Defendant Aiden Ross is an online media personality and streamer who at all relevant times coordinated live streams and promotions on platforms accessible within this district, including streams featuring stake. US tipping while maintaining close relationships with Drake and Wyn relevant to the conduct alleged. Defendant George Nwyn is upon information and belief an Australian national residing in New South Wales who at all times relevant operated or co-founded entities or ventures including weekdays weekdays capital and clipping and used online aliases including grand wizard nin coordinated botting facilitation and paid amplification across the US facing platforms and transacted in payments mass through stake us and stake.com including through their tipping features in connection within with the same factual allegations. Stake US's illegal gambling operation. Stake US has operated since at least 2022 one of the largest and most profitable illegal gambling illegal online gambling operations. While defendants Drake, Ross, and Win promote the illegal casino to consumers and enable recruitment of new American players. Stake.com is banned from operating in Virginia and indeed anywhere in the United States. Stake US was created by Stake.com's founders to bypass such restrict restrictions. Stake US is almost identical to stake.com as both websites offer the same or substantially the same content including online casino games such as slots, table games, and live dealer games. Additionally, both offer gold coins and stake cash. Stake US encourages users to play the casino games advertised on its website and users are allowed to cash out for digital gift cards or cryptocurrency. Despite offering online casino games, State us holds itself out in its terms and conditions as a platform that does not offer real money gambling and claims that no purchase or payment is necessary to participate or play stake us games. The stake us homepage claims it provides the ultimate social safe and free gaming experience. However, these representations are misleading as players are encouraged to wager gold coins or state cash or some combination of both on the casino games, confusing consumers into believing they are participating in harmless and free gaming when in fact they are participating in gambling. Here's how it works. Stake offers users two types of virtual currency, gold coins and stake cash. Gold coins do not have monetary value and are described by stake as solely for entertainment purposes. Stake cash on the other hand can be cashed out at a onetoone exchange rate for US dollars and thus serves as the currency with which most bets are made. Users can users can buy gold coins or earn them through various promotions and stake characterizes gold coins as the primary currency for casual gameplay. With each purchase of gold coins, however, stake bundles a set quantity of stake cash, which has actual monetary value and is the true currency with which stake users place bets. Indeed, for every dollar spent on purchasing gold coins, stake bundles a nearly equivalent amount of stake cash. For example, as of the date of this complaint, a user could purchase 200,000 gold coins and $205 in state cash for 20 US. The state us platform allows users to play casino games such as roulette and virtual slot machines, which are pure games of chance. The outcome of these games is determined by random number generators. Users may bet stake cash on these online casino games with the prospect of a large payout, often many multiples of what was bet. Stakes virtual casino games involve no skill or strategy. Stake US also features live dealer games, which allows users to interact with human dealers and experience what it would be like to be at a landbased casino while you're sitting comfortably at home behind your computer screen on your mobile device. Stakes live dealer games are filmed in a studio and players may bet on the results. For example, of the spin of a roulette wheel or the next blackjack card. Stakes live dealer games like their counterpart in a brickandmortar casino are games of chance. Stake US thus generates revenue from unwitting and often vulnerable American consumers, incentivizing stake us to continually deceive American consumers and regulators. State us conducts an illegal gambling business within the meaning of 18 USC 1955, including by operating casino type wagering in violation of multiple state laws involving five or more persons and in substantially continuous operation with substantial daily revenue. publicly filed civil enforcement and consumer actions across multiple states accuse state usus of unlawful gambling operations including Minnesota, South Carolina, Massachusetts, Alabama, Illinois, and California. These allegations are pleaded not for the truth of the underlying claims but to demonstrate stakes role, intent, common purpose, and the predicate acts showing cons, excuse me, showing continuity of racketeering activity within the last 10 years. States online operations also violate Virginia law, which prohibits online gaming by providing a freely accessible online gambling forum accessible to consumers in the Commonwealth. Stake is flagrantly violating Virginia law and jeopardizing the health and safety of Virginia residents. Stake.com originally created as an online cryptocurrency casino that could be accessed, albeit unlawfully, by consumers in the United States by use of a VPN, obscuring the user's true locations. Stake.com's founders later developed Stake US, an almost identical version of State.com, to further entrench itself as an online casino platform in thei the United States. State us advertises that it social casino offers a safe and free gaming experience. This misleading statement deceives consumers into believing that they are participating in harmless gameplay when in fact they are being lured into real money gambling. Drake, Ross, and Wyn have been zealous promoters of stake. Drake has been paid by his own admission $100 million per year for his promotional services. Drake, Ross, and Wyn have further incentive to promote and mask the true nature and extent of their conduct on and around stake. Since at least 2022, Drake and those acting under his direction, including Ross and Wyn, have made use of Stake.com and Stake US. US to covertly finance the orchestrated procurement of botting and streaming farm activities to artificially inflate the number of plays attributed to Drake's catalog across major digital streaming services such as Spotify. State US facilitates this covert financing scheme through its user-to-user tipping and internal transfers that effectively obscure the identities of counterparties through these mechanisms. Withdrawals are recorded merely as stake transactions, concealing their true origins and recipients. These transactional features enable the concealment co covert routing and dispersement of funds to bot operators, intermediaries and amplifiers integral to sustaining and expanding the artificial streaming and ampl amplification operations. Okay, I'm checking on something real fast here because I believe I can change this. Yes. Yes, I can. Hold on so I can show y'all. Okay, so you can see this lawsuit says Frozen Moments uh is the petitioner and it's against UMG Recording Studios and Spotify, right? Frozen Moments is owned by Drake. Drake accused them of using bots or let me see. Yes. So, here in Drake's lawsuit against UMG, it says in 2024, UMG did not rely on chance or even ordinary business practices to break through the noise on Spotify and likely other music platforms. It instead launched a campaign to manipulate and saturate the streaming services and airwaves with a song not like us in order to make that song go viral, including by using bots and pay-to-play agreements. So, the accusation that Drake put in his lawsuit against UMG, which Drake has an interest in saying that for Kendrick, if it's true or not, he has an interest in saying that. These uh citizens for the class action lawsuit are accusing Drake of doing that through this uh casino operation. Okay, let me put my other thing back up here. I just wanted to show that connection because that was so I did not expect to see that they were being accused of that while he's over here suing UMG saying that they did that to Kendrick's songs. Okay. All right. So it says for these reasons among others Drake and Ross maintain a monetized and closely intertwined relationship with stake us. Drake. Sorry, my chair. Sorry, I have attention issues and my chair is rubbing. Okay. For these reasons, among others, Drake and Ross maintained a monetized and closely intertwined relationship with stake us. Drake and Ross have exchanged high dollar amount above US currency transaction report thresholds tips during live streams, including a widely publicized six figure transaction. These live streams are also used to promote stake and pushes gambling services onto Drake and Ross' millions of online followers. Specifically, one kick live stream captured exchange of a $100,000 tip among Drake and Ross via stake with another instance evidencing a $10,000 tip. Additional stream recordings reveal reiterated substantial exchanges between Drake and Ross routed through stake with ongoing stream of funds on information and belief totaling in the millions of dollars amounts which upon information and belief have underwritten continued botsing and amplification efforts. Just days before this complaint was filed, defendant Drake gifted a $220,000 car to defendant Ross. and this was filed December 31st, 2025. Payments between Drake and Ross extended beyond direct exchanges. Public records and leaked communications reveal intermediary transfers to bot vendors and logistics facilitators, including when a known recipient of payments linked to clipping and amplification campaigns. Portions of funds transmitted through stakes tipping and internal transfers pass through to bot vendors and amplification intermediaries to perpetuate and scale manipulation activities. NW known in online forums as Grand Wizard, Grand Wizard Chat Ninja or Grand Wizard CN functioned and appears to continue to function as a broker and operational facilitator for these schemes. He is publicly connected to weekday weekdays capital and the clipping service which orchestrated paid clipping campaigns intrinsically tied to streaming numbers and influencer content including campaigns involving Drake and Ross. Wyn actively promoted and participated in the clipping discord server and received direct payments both from clipping administrators and separately from other co-conspirators. W's public posts include corroboration by Ross, who on stream declared, "I'm friends with Grand Wizard, that's my dog," while tagging Drake's account. Drake has bet large sums on Stake and live streamed the event, further promoting Stake to his millions of followers. stake. US publicly stated that Drake has been a longtime member of the stake community and ultimately a partnership was formed in which a new gaming experience will allow users to have a chance to win big alongside Drake. This type of giveaway will be on a magnitude unseen before. I'm writing down a note for myself for my commentary that I definitely want to point out to y'all. I'm trying not to insert my opinion too much yet. Okay. Drake's journey from a player to to a partner is documented on Stake's web properties, while Drake's social media accounts identify his partnership with Stake. During live streamed events, Drake and Ross have made large bets on Stake using house money provided by Stake. This conduct simply encourages and influences the large fan base of Drake and Ross to make similarly large and/or unwise bets. yet using state cash they purchase themselves. State us, a website developed based on state.com, misrepresents to consumers that it offers safe, free, and legal gaming services when in fact it functions as an illegal online casino. State characterizes itself as a social casino, which is intended to misrepresent the legality of the platform's operations. According to stake, a social casino refers to an online platform that offers casino style games for entertainment purposes without involving real money. Instead, we use tokens, gold coins, and state cash. Users can enjoy a variety of casino games such as slots, roulette, and blackjack, but with the use of virtual currency tokens rather than real money. This is demonstrabably false. Stake US offers traditional casino games to its users, providing the option to place bets and cash in winnings. Stake us consumers can receive gold coins or stake cash or a combination of the two to continue wagering bets on stake us website. State cash is purchased using cryptocurrency and its value is pegged to the US dollar. If a user wins their bet, they can cash out stake cash for real money. Such misrepresentations that stake us is not a casino when in fact it functions as one prey on consumers particularly those who are prone to gambling addiction by masking its real money gambling platform as a free and safe social casino. stake and defendants create a predatorial gambling environment, deliberately misleading consumers and exposing consumers to the risks of gambling addiction and jeopardizing the financial well-being of consumers and their families. Stake further misleads consumers by identifying in its terms of service certain states where it where its use is prohibited. Virginia is not among the states identified in this list, thus leaving the impression that using stake is permissible in Virginia. Plaintiffs have been damaged by the false marketing, manipulation, and abuses of defendants Drake, Ross, and Wyn who participate in the marketing of stake. Defendants Drake, Ross, and Win scheme has caused damage to plaintiffs who were who were manipulated into signing onto and transacting on stake us based upon defendants Drake, Ross, and W's representations. The enterprise, which is a key word to use for the RICO, the enterprise has operated as a continuous coordinated unit since at least 2022, defined by explicit roles. Stake us is an illegal online casino earning profit by selling consumers gold coins and stake cash and serving as a transactional infrastructure for routing, concealing, and distributing funds via tipping. Drake is a paid promoter and spokesperson for stake and finance directed and reaped the benefits of streaming and social media manipulation. Ross is also a paid promoter for stake and amplified stake us as a casino and covert payment conduit. Nwin was also paid to promote stake and receive money through stake to broker. Oh, sorry. To he received money through stake to broker, coordinate, and operate through bot vendors and clipping channels to artificially boost Drake's streams. The scheme has been executed on an ongoing basis persistently since at least 2022 and remains an ongoing and imminent threat of racketeering activity. defendants stake us, Drake, Ross, and Wyn together with bot vendors, streaming farm operators, and other facilitators known and unknown associated to form an association in fact enterprise, the enterprise. The enterprises common purpose was to facilitate illegal online gambling and to conceal, route, and distribute proceeds of the scheme through stake. US's pseudo anonymous payment rails, using proceeds and other funds to enrich themselves and artificially inflate streaming accounts for Drake's catalog. Roles and relationships were stable and continuous. Stake at all times served as a gambling platform and money transfer conduit through which payments could be concealed. Drake was paid to promote stake and made and received payments through stake and directed and benefited from artificial streaming and narrative application. Ross was paid to promote stake in finance, promoted and facilitated the routing of value, including via public and private tipping and large value transfers on stake while coordinating amplification with wind. when further promoted stake sent and received payments through its tipping system and brokered and interfaced with bot vendors and paid amplification pipelines, including through weekdays, weekdays capital and the clipping service. The enterprise engaged in and affected interstate and foreign commerce through the use of nationally accessible platforms, interstate wires, and crossber payment and settlement networks. Within the past 10 years, State US has been accused in multiple civil enforcement and consumer actions of operating unlawful gambling businesses in US jurisdictions. These allegations are pleaded not for their truth, but to show Stake US's role, capacity, and propensity within RICO's 10-year window. The enterprise leveraged stake us platform and Rails to facilitate and conceal scheme proceeds and to compensate participants in executing and concealing the scheme. The enterprise utilized domestic and foreign financial institutions and processors to obtain, move, and disguise funds by means of materially false pretenses and omissions regarding the nature and purpose of transactions. The predicate acts were related in purpose results, participants, victims, and methods were repeated across releases, campaigns, and accounting periods, and present a threat of continued racketeering activity. The enterprise functioned as a continuing unit since at least 2022. Class action allegations. Plaintiffs bring this action individually and on behalf of a class of similarly situated individuals pursuant to rule 23 of the federal rules of civil procedure. Plaintiffs seek to represent the following classes or persons. All persons in the United States who created an account on or accessed State US and who purchased gold coins bundled with state cash and made and lost one or more wages using state cash within the last 3 years. In the alternative plaintiffs seek to represent the following classes or persons. All persons in Virginia who created an account on or access state. the US and who purchased gold coins bundled with state cash and made and lost one or more wages using state cash within the last 3 years. Excluded from the class are defendants, their officers, directors, and affiliates, and any judicial officer assigned to this matter and their immediate families. Plaintiffs reserve the right to amend or modify the class definition in connection with their motion for class certification as a result of discovery at trial or as otherwise allowed by law. Plaintiffs bring this action individually and on behalf of all others similarly situated because there is a well- definfined community of interest in the litigation and the proposed class is easily ascertainable. I'm going to skip over these but I'll name the sections but their naming because of their their possible number. That's why it is practical to do a class action. The commonality and predominance is a reason the typicality the adequacy of representation. the superiority of the class action and it says because for the fair and efficient adjudication of this controversy and we're going to the counts that are going against Drake and the other defendants. So count one violation of RICO defendants associated together with others known and unknown to form an association in fact enterprise within the meaning of 18 USC 19614 with a common purpose to operate and facilitate an illegal online gambling platform. Each defendant conducted or participated directly or indirectly in the enterprises affairs through a pattern of racketeering activity affecting interstate and foreign commerce, including leveraging state. by US's unlawful gambling related operations as a conduit within the last 10 years as reflected in public enforcement and consumer actions to facilitate and conceal the scheme in violation of 18 USC 1955 and to establish continuity of racketeering conduct. The predicate acts are related in purpose, results, participants, victims, and methods, and amount to continued criminal activity across multiple years, and release cycles posing a threat of continued racketeering activity. As a direct and proximate result of defendants violations, plaintiffs and the class suffered injury to business or property, including loss of the benefit of their bargain and loss of money and/or property. Plaintiffs and the class seek tribal damages, cost, and reasonable attorneys fees. And I do want to say this is a civil lawsuit, civil class action lawsuit. It is not a criminal. Um, it's not criminal at this time. Count to RICO conspiracy. Plaintiffs releged the proceeding paragraphs as if alleged herein. Defendants knowingly agreed and conspired that one or more of them would conduct or participate in the enterprises affairs through a pattern of racketeering activity. Overt acts in furtherance include dissemination of coordinated narratives and the routing and concealment of payments via state us tipping and internal transfers. Plaintiffs and the class suffered injury by reason of defendants violation and seek trouble damages cost and fees. Count three, Virginia Consumer Protection Act. Plaintiffs releg the proceeding. defendants engaged in deceptive and misleading acts and practices in connection with consumer transactions affecting Virginia residents, including by misrepresenting the stake platform as a safe, harmless, and legal platform when in fact when it when it in fact constitutes an illegal gambling platform. Defendant's conduct constitutes misrepresentations and omissions of material facts, false representations as to characteristics, standard and qualities of the service consumed and deception likely to mislead reasonable consumers in violation of the VCPA. And I do see y'all. I promise I will come back to the chat. I don't want you to think I'm not ignoring you. I promise. Plaintiffs and the class suffered ascertainable losses as a result of defendants violations, including overpayments and loss of the benefit of their bargain. Plaintiffs seek statutory damages, actual damages, treble damages were authorized for willful violations, injunctive relief, attorneys fees, and costs. Prayer for relief. Wherefore, plaintiffs individually and on behalf of the class respectfully request that the court enter judgment in their favor and against defendants and award the following relief. Certifying this action as a class action. Appointing plaintiffs as class representatives and plaintiffs council as class counsel and directing appropriate notice to the class. awarding all available damages not less than $5 million, including statutory, compensatory, consequential, punitive, and enhanced damages and attorneys fees were authorized by law. Ordering restitution and disgorgement of amounts wrongfully obtained by defendants. Entering injunctive and declaratory relief to prevent further unlawful conduct. Awarding pre and post judgment interest, attorney's fees, and costs as permitted by law. and granting such other and further relief as the court deems just improper. Plaintiffs hereby demand a trial by jury on all issues so triable. I'm going to let y'all hear one of I'm going let y'all hear Drake's Drismas promotion and it'll well you'll probably be able to see it too cuz you can see my screen. So here's the Drismas one. It has a popping sound um just so you know um because I think they got rid of the music. I don't know. I don't know why it has a popping sound but it does. It's not me when you hear it. But here's his Drisma's steak promotion. If later someone comes in here and you don't see these, they copyrighted it and I had to remove it. Okay, here we go. >> Holidays, ladies and gentlemen's, ladies with gentle hands, uh, old people [music] with pension plans, those of you who graduated and have less exams, those of you who showed up to flex some bands, even the bitter and desperate men's. Happy holidays. Welcome to the greatest online streaming event of all time. My name is Drake. I'm here on behalf of Stake. I got a great great great night for you. I'm so excited. And uh I feel like we should take us down. Let's take us down. Let's take us down. I'm trying to land this. Oh yeah. Yeah. >> Okay. And it's more of that. It's more of that. Then here is it's on I muted it on purpose, but here is um a stake promotion. Again, if y'all don't see this later, they made me take it down, but this is when Drake joined stake. And it's still on YouTube right now. So, it it has a copyrighted song for sure playing, so I can't play the sound, but that is uh that's them promoting Drake coming to stake. And then I asked now it's Google AI so I can't rely on it too much but I did want to know is the consumer or the company respons is a cons I asked is the customer responsible for knowing if online gambling is illegal in their state. This is what the AI answered. I I was looking for actual website to answer my question a little bit better but they weren't answering the question I asked. So this is what we got. But take it with a grain of salt because you see it's AI overview. But it says yes, as a general principle of law, individuals are responsible for knowing and adhering to the laws of their jurisdiction, including those related to online gambling. While licensed operators have significant legal obligations to ensure compliance with state regulations, the customer is ultimately accountable for their own actions and ensuring they are betting legally. So that I I had Oh, that was a burning question because that's a that's a big chunk of the lawsuit. Okay. Now I'm coming to the chat and then I'll give my commentary after that. Let me see. Okay. Okay. So, let me see. The state it originated in for this lawsuit is Virginia. Um, who was that? Jacqueline or Pette? Who is that? Yeah, Jacqueline. This originated in Virginia. And yeah, Leo Libra Love said, "Pop me kettle." because Drake is literally, unless they closed it up, cuz I didn't go check if it's closed now, but he literally had sued UMG for inflating streaming. Oh, and here's another one he said that they did. I don't know if y'all can still see it. Let me see here. Can y'all y'all can't see that? But I'm going to read you the paragraph. It says that he's also accusing them of uh paying off Apple in a poliola. So, every time someone asks them to play Drake, it actually plays not like us. That's what he's accusing Apple of doing. And he said in the song that uh describes him as a PDF, that's what it plays. If someone verbally says, you know, Apple or however they say it, you know, Siri, play um play Drake, it'll play Kendrick Lamar. That's what they're alleging. So, I was like, "Oh, if you want to see the full reading of that, I definitely have all that posted on legal at some point if you want to see that full lawsuit." It was interesting. I was laughing a lot, so I apologize now if y'all go back and look at that one. Um $5 million. Does it say with the actual dollar amount of the money they lost on the site? Um, no. They did not list in their lawsuit how much they each lost. Um, they only listed that they are asking for no less than $5 million on this lawsuit. Um, I'm on the wrong lawsuit. Scrolling down. [clears throat] They may say that during actual trial if it goes to trial, but not in here. I read everything that they put in here. So, they did not say how much they lost. They're more going after the bad practice than their individual money lost too, though. It's the fact that I could have lost $20, but if this was if if if it comes out to be that you are doing this illegally, I I get treble damages plus attorneys fees and blah blah blah or if they lost more. Um, okay. Let me see if I missed anybody. Jacqueline said, "Wow, Minnesota again." What else happened in Minnesota? Okay. Okay. Leo Libra Love says, "I agree that they misrepresented the nature of the site. Nothing safe about gambling. One of the worst addictions to have." That is That is true. Saying safe is crazy to put that with gambling. That is true. [laughter] Um, let me see. Okay. So, I'm going to read my commentary real fast and I'll go back and look and see if y'all say something. Okay. So, one of the things they pointed out in this lawsuit, so this is either going to be a benchmark type of lawsuit or it's going to get lost in the sea of lawsuits against online gambling. And the reason I say that is because a lot of things that it does accuse Stake us of doing. Um, a lot of places do, even the gaming companies do now with the loot boxes. That's gambling. It's just massive something else. But loot boxes, if you're not into gaming, is where you do so many things as your skill. you gain points of blah blah blah and if you basically uh they call it dang it they call it something where you just have to play you just have to keep playing grind it's like a grinding type play you can play all you want to you still won't get certain loot boxes unless you put money in it and even then you're just getting like say purple loot boxes are the best loot boxes and they have the best chance of getting the best things and mostly you know kids are playing games too it's definitely not just it's more kids than anything so you got kids in here basically gambling asking their their parents for money for their game to put on their game to get their coins or whatever it is that then earns them to open that loot box and then the thing that they wanted might still not be in that loot box. So, it's not just even state, it's gaming. They're they're really trying to uh tighten up regulations on all kinds of things that are that are appear as online gaming. Then, of course, uh other online casinos and then other stuff like DraftKings. All of that is it is predatory gambling. The question is, is it illegal to be that predatory yet? And then my thing is, if even with this class action lawsuit, if they could afford to play Drake, to pay Drake $100 million per year, suing them for no less than $5 million, they're going to probably see that like a drop in the bucket. Even if they do lose and get fined, that they're not going to it's not really going to affect them. Um, I don't know if they're part of like the disruptive market like how Uber Uber operated illegally. Those scooters you see around the city operated illegally, but they just did it. Flooded the market, got everybody addicted. So, by the time they got fined and it got tried, now the politicians are at risk of people not voting for them or whatever because they're mad that you got rid of something that they liked like Uber, stuff like that. So, now there's pressure and it's like, ah. So, they kind of get fined, but they kind of can keep it. I don't know if this is also one of those types of things, but it's so much at play when the companies are super big that it's just not that black and white of now, are they predatory? They are predatory. Not questioning that. Will something happen because they're predatory? I don't know. U Oh, Minnesota alleged daycare centers. Gotcha. Is it online gambling only because there are casinos in Virginia? Great question. So, I looked up online gambling by state and this site is called Altonar. Again, we're taking everything with a grain of salt because I was just googling trying to have something because I had questions myself. So, online betting activities permitted by state and it says Virginia can have sports betting and lottery. West Virginia can have sports betting, casino, poker, and lottery. Some of these are blank. They can't have it at all. and they did list it like Texas is blank. There's no apparently there's no legal online betting in Texas or Utah and stuff like that. So that was how I that was the best I could answer my question on that one that I even had like okay so but that's why I also asked that question how much responsibility falls back on the consumer because if you're on so if you're on social media you're reaching every state in the United States and then you're reaching countries. So, like I was like, it's got to be that they're going to put this back on the consumer that you have to know your own laws for your state if you can or can't do this for your state because they're reaching everybody. If you post on the social media, you don't go, "Let me block Virginia because it's about this. Let me block Utah because it's about this." You know, you know what I'm saying? So, like, this is interesting. I don't There'll be a benchmark if they do win on some of these. Um, I'm I'm going back to my notes on here, too. They didn't even age restrict it. They're going down. can't have M. No, they can't have minor gambling. They definitely need to age restrict. That one should be a minimum. And again, they'll just get fined probably for that. I don't know if they get shut down cuz only shutdown would hurt them. A $5 million even up to $100 million probably won't hurt them because that's what they're paying just Drake to promote it. That's not even what they're paying Aiden Ross, who whoever else they're paying to promote it, and then them keeping their profits. So, it's like the motivation is going to be very, very low to change if it's going to be for them. that's going to be a very small amount to pay out even like you know you see what I'm saying just the scale of money cuz these companies they take they'd rather take the fine and keep going then fix it because the profit's so large um okay I told y'all about Drake saying UMG inflated streams oh this also very common for any online gambling website to use celebrities influencers to promote their site and it It's very common for none of those people that are promoting it to be using their own money. They're most likely going to be using the house money. So, it's not just um stake us that does that. Again, that could be predatory, but it's going to have to be predatory for all of them if that if that happens because all of them do that. They're not making the people promoting their their company pay with their own money to gamble. So, that's that's across the board with online gambling. Let's see. Now with the exception of um again the minors like Leo Libra love like she was saying and what I was talking about with the exception of minors I do want to see how much is going to fall back on the on adults when it happens to them but at the same time with them playing off an addiction I think someone has said they should treat them like tobacco companies where they can't promote um on social media I think or they can't do certain things to promote tobacco anymore that's you we have those companies a lot of them still exist, but you don't see them promoting like that because apparently they're very very restricted. And I think some people are trying to get gambling to be the same way. I don't know if it's going to happen between all the lobbying I'm sure they're doing, but you know, um, and then with it being on social media now, the push notifications can really get into your head, especially if you already have a problem. So then you like, you know, you put it down, take a break, then you get that ding, you get that little whatever little ch-ching sound or whatever you get that puts that in your brain like, "Oh, let me just go check the site. Let me do one more spin. let me do this. So, I I am not disagreeing that this is very predatory. It is. It is predatory. Um, the safe and free gaming experience might get them again, but it's still it's going to be a drop in the bucket if they even do have to pay out because it's obviously not free because they have to buy their little their gold coins which bundles what they probably really want, which is the stake cash or whatever it's called, so they can get real money payouts. What I didn't understand was that as the adults that are filing this, so I'm not talking about kids and stuff like that or or whatever, but as the adults that filed this lawsuit and the lawyers filed it and they have multiple lawsuits open, so they had to have already thought about this. But I'm like, as soon as it asked you for your card or Vinmo or whatever it to take money, at that point you see it's not free like it is a paytoplay like cuz they call them online purchases or whatever. I know like in the mobile games and stuff they'll have online purchases but it's a free game but then you can do online purchases and stuff like Fortnite too stuff like that you if you bought coins and then just earn them off of you know just grinding in the game and doing the promotions or whatever then at that point you do know it takes money because you had to give up your payment information to do the free gambling that no longer is free. Um and I also I just wonder how they're going to play this. I feel like they've already thought about this. Like they're probably like cuz even in the lawsuit it stated something like the gold coins were the main source for gambling. So that's probably what they're going to say too. Like we just we were talking about our main source, not the not the minor source where it does have money involved or I just wonder how they're going to play that because I know they've had to think about this to still be able to still put the word free in there. It's not right to put it. I'm not agreeing that they should put free in there, but I just wonder at what point when you realize as a person, as the end user, oh, they're asking me for my financial information. No, because you said it's free. How did you still end up putting money into that? Um, let me see. I was also going to say though, if y'all have used stake.com in the last three years, you might as well maybe look into signing up for the class action lawsuit because I'm sure if you Google it, um, and I'll put their thing back up here, too, that it'll show who you can contact if it does get approved to become a a for sure like if it gets to proceed as a class action lawsuit. Let me see. Hold on. [snorts] These are the I'm putting on the screen. This is the law office that's representing them right now, it looks like. So, in case you want to add your name to the lawsuit, if you were one of those using stake us, you know. Um, the last thing I wanted to say was, okay, Drake's part that he could get in trouble for possibly. It seems like he'd get more in trouble for the streams, the inflating of the streams, but I don't know if they'll say that still stays well, it's related to Rico wise. Maybe it stays related under the Rico umbrella. So, he might get in trouble for that. But as far as the site misrepresenting things, that's almost like Ja Rule to Fire Festival. Ja Rule got out of that and that was Ja Rule. And you know, Firefest was a Travis. I watched that docu I watched both documentaries. The one that they made that was more favorable to them and the one that really really showed what was happening. I watched both of them and but Ja Rule got out of there. So Drake may get out of there in the sense of I can't be responsible for the terms and conditions they put on there. I'm not going to keep up with every law for every state. I'm here to be a face and in good faith think that they're operating legally. You know what I mean? So, I don't know about that. I also don't know if he could get in trouble for tipping Aiden Ross that money. I don't know. He's using the platform that purports itself to be legal, ethical, and blah blah blah. So, I don't know if he get in trouble for that. But, could he get in trouble still under the RICO part of him inflating streams? Possibly like using that money to use bots to do bot streams. That's where I think he he he might have to also pay out too. And that's a maybe though. Um there's so many people that promote so many things that it's not usually going to fall back on the face. And he's one of the faces. He wasn't I don't think he's the only face. You know what I mean? So I don't know about that one. That one's that one's a iffy in my opinion. But that's those are my thoughts about this lawsuit. So yeah, it is predatory. It does. Oh, and the the regulation of you you are supposed to report after you get so much money in a limit. I think it's over uh I think it's $10,000 and up. So, that might get them too without the regulations of like, hey, you're transferring a lot of money. You're not doing it under the normal regulations. That could get the company. But yeah, those are my those are most of my thoughts. Hopefully, I didn't forget anything. I tried to write down everything I thought of. So, hopefully, you know, this gave y'all some insight and hopefully you enjoyed it. Sorry about the interruptions today. Normally I get no phone calls. I go live where I have to do straight reading and I can't mute because it's not a body cam reaction and I get a phone call. Like I'm so sorry. And it's just stuff that you know when you're live it happens. If Yeah. My plan is to upload a clean read as well. But we'll see cuz other stuff keeps popping up. I didn't expect Drake's thing to pop up. Took up time on I was trying to finish up my veneer tech and stuff. So yeah. But let me know what y'all think. either replay gang gang, my people in the live chat. Definitely appreciate y'all hanging out with me and staying till the end to hear my thoughts. I I really wanted to because I was just like, "Oh, I'm trying to hold off. I'm trying to hold off cuz that's some parts I see and I feel bad. Anybody that has a gambling addiction, I feel bad for for a reasonable adult that may not have an addiction. I don't understand how it's you couldn't see this as soon as as soon as it happened that it's not free. I know it says free, but it's not free and you still put money in it. And I know they're probably going to say, "Well, they're doing it to protect others cuz maybe they did see it instantly." So, that could be it, too. Um, but I do think hold some personal responsibility, but also hold these companies accountable because they'll keep trying to get away with stuff. That's that's where I'm at. All right, y'all. Well, I'll see y'all later. I may may do the veneer tech today. Might move it back some, but I'll see y'all soon. Talk to you later. Bye.