In the Matter of CSGO Lotto, Inc., File No. 1623184 #00003

Submission Number:
Christopher Jahn
Outside the United States
Initiative Name:
In the Matter of CSGO Lotto, Inc., File No. 1623184
Greetings and Salutations, I would just like to give my reasons for my disagreement with the end results of this investigation, and provide my reasons for why I think this case should be reopened, and why the two people therein (Trevor Martin and Thomas Cassell) should face a much stricter reprimand, not excluding heavier fines and prison time, at the FTC's discretion. I have two major points that I would like to make, which I did not see any mention of in the FTC's article on the investigation. 1) I'll start with the less severe offense. Since Thomas and Trevor both owned the gambling website CSGOLotto, this gave them access to the website's coding, which would have allowed them to fix the results for their videos and for the videos of their affiliates. Doing so would have grossly and egregiously misrepresented the odds of winning on the actual website for anyone not in the affiliate program. 2) Secondly, and this is what I think was the most overlooked aspect of the whole investigation. For both Trevor and Thomas, a very large portion of the demographic which they cater to include persons under the age of 18. People who legally aren't allowed to gamble within the United States. This fact should not be taken lightly. For most YouTubers of this size, the owning and operation of a channel becomes a business instead of a simple hobby. Knowing one's demographic is an integral part to any business, so there's reasonable cause to assume that Trevor and Thomas knew exactly who they were advertising to. A very large portion of their demographic (probably more than half) is under the age of 18, and I very much believe that their demographic statistics should be disclosed, at least to an FTC investigation. The website in question, CSGOLotto, does not require that any individual signing up submit proof or documentation of their age. The only requirement to register to this site, as well as gamble within it, was that they sign in using a Steam account (Steam also doesn't verify people's age. When signing up for Steam, the only age verification process is a checkbox saying you're 13 or older). Yes, CSGOLotto does have a clause in their Terms of Service saying users must be above 18 years of age to use the service, but let's be honest here, what teenager is actually going to abide by that, let alone even read it? Can you imagine a modern day teenager saying "well, I'm not quite 18 yet, guess I'll be a law abiding citizen and go do something else". No teenager is going to do that. To summarize this final point, Thomas and Trevor, knowing full-well their demographic and knowingly making their website easy to register to, illegally marketed their gambling site to people under the legal gambling age. Their marketing material was tailored to be appealing to people of that very same demographic. "How to win $13,000" in 5 minutes", with a title like that, what other demographic could they possibly be targeting, other than the young and gullible? Trevor and Thomas purposely and knowingly advertised a gambling site to children, using deception and lofty promises to exploit them for money, and that is part of this investigation that I feel should not be discarded or overlooked. This is a multi-billion dollar gambling industry, with estimates of over $5 Billion in skins being traded in 2016 alone. This is not a small economy and this is not a small-size gambling service. With all this being said, I implore the FTC to re-open this investigation and to prosecute Trevor and Thomas to the fullest extent permitted by Federal law. These two people knew what they were doing was wrong (if not illegal), and they did it anyway, knowing they could probably escape prosecution due to loopholes and legal grey areas when it came to internet and video game related law. In legal jargon, this should satisfy both the Mens Rea and the Actus Reus. Archived version of CSGOLotto from July 2016: