Investigations • Illegal Gambling • Class Action
How Polymarket Built a $12B Empire on Unlicensed Sports Gambling
What the $12 Billion Valuation Costs Real People
There is a man in San Mateo, California who spent two months of his life thinking he was doing something legal. He saw the ads. He read the platform’s own description of itself. He watched the CEO of Polymarket explain on national television that users own a “share,” that it is “similar to a stock.” He trusted that. He opened his wallet.
Between September and November 2025, Lorenzo Miro San Diego placed multiple sports wagers on Polymarket. He lost thousands of dollars in real money. Not tokens. Not credits. Real currency that paid real rent, bought real groceries, or didn’t. The lawsuit does not specify exactly how much he lost because that detail is not yet public. What is public is the word the complaint uses to describe how he ended up there: he was “induced.”
That word is doing a lot of work. It means he did not simply wander into a bad bet. It means the platform was designed, marketed, and operated in a way that pulled him in. The complaint describes a platform that puts the potential winnings in a “visually prominent way while downplaying the costs and odds.” It describes design elements that “gamify participation” and “encourage rapid and repeated wagering.” It names the psychological mechanism being exploited: addiction.
Gambling addiction is not a character flaw. The American public health community has spent decades establishing that it is a diagnosable disorder, that online platforms accelerate it faster than physical casinos, and that young men are particularly vulnerable. The complaint cites data showing 10% of young men exhibit behaviors indicative of gambling addiction, compared to 3% of the general population. It cites Harvard research linking gambling disorders to a suicide rate 15 times higher than the general population. It cites a 45% spike in calls to the National Problem Gambling Helpline between 2021 and 2022 alone.
None of that data was posted anywhere on Polymarket’s advertising. No “If you or someone you know has a gambling problem, call 877-8-HOPENY” message appeared on its Instagram page. No self-exclusion program was offered. No age verification beyond 18 blocked a teenager from betting on a Syracuse University football game. These are not optional courtesies at a licensed sportsbook. They are mandatory by New York law. Polymarket skipped all of them.
What Lorenzo Miro San Diego lost goes beyond the dollars. He lost the right to make an informed decision. The platform never told him his participation was illegal. It never told him the bets he was placing were the same bets you would place at a licensed casino. It never told him that the same federal agency had already penalized the company four years earlier and forced it to shut down, only for it to relaunch with the same business model wearing different language. He found out through a lawsuit.
And he is not alone. The complaint estimates hundreds, if not thousands, of class members across the United States. Each of them saw the same marketing. Each of them placed bets under the same false belief. Some of them certainly lost far more than thousands of dollars. Some of them, statistically, are now calling a helpline. The platform collected its transaction fee on every single one of those bets.
Verbatim: What the Court Documents Actually Say
The following quotes come directly from the class action complaint filed February 4, 2026, in Case No. 1:26-cv-00973 in the Southern District of New York. Nothing is paraphrased.
“Defendants own and operate Polymarket, one of the most popular prediction gambling markets on the planet. Through Polymarket, users can place bets on the outcome of sports games, individual player metrics, team results, and sometimes even a combination of events (i.e. Parlays). These bets materially resemble those offered at traditional casinos or sportsbooks.”
— Complaint, ¶¶ 2–3
- This paragraph directly kills the “prediction market” defense before it can be raised. The complaint establishes at the outset that the product being sold is functionally a sportsbook, not a financial instrument, by describing it in the exact terms regulators and courts use to define illegal gambling.
- The inclusion of parlays is legally significant. Parlays are multi-leg bets that compound risk across multiple game outcomes. They are one of the most addictive and house-favoring bet structures in regulated sports gambling. Their presence on Polymarket is evidence that the platform replicates full-service sportsbook mechanics.
“To evade regulatory scrutiny and mislead consumers, Polymarket markets itself as a ‘predictions market.’ This designation is purely cosmetic, intended to mask the reality that the platform facilitates and profits from illegal gambling.”
— Complaint, ¶ 5
- The complaint does not call the “prediction market” label a misunderstanding or an aggressive regulatory interpretation. It calls it cosmetic and intentional. That is the language of fraud, not oversight failure.
- This framing is legally critical for the deceptive practices claims under New York GBL § 349. To prevail, plaintiffs must show the deception was consumer-facing and material. Calling the label “cosmetic” and “intended to mask” sets up both elements simultaneously.
“Shayne Coplan, Polymarket’s founder and chief executive officer, proclaimed that ‘[u]nlike a betting site where you make a bet and it’s against the house, here you own a share. You could almost say it’s similar to a stock, but it’s not a stock.'”
— Complaint, ¶ 46 (quoting CBS News / 60 Minutes)
- The CEO made this statement to a mass national audience on 60 Minutes, one of the most-watched news programs in the United States. This is not a fine-print disclaimer or an internal communication. It is a public, on-record attempt to reframe gambling as investing for the widest possible consumer base.
- The claim that users “own a share” is directly contradicted by how the platform operates. A share has residual value and can be sold at any time. A binary event contract on a sports outcome expires worthless the moment the game ends. The analogy is false on its face, and the CEO appears to acknowledge this with the caveat “it’s not a stock.”
- This quote will likely appear in every state enforcement action and every regulatory proceeding against Polymarket going forward, because it documents the CEO personally promoting the platform’s legality to consumers while regulators were simultaneously moving against it.
“The platform’s lifetime sports-related contract volume has surpassed $6 billion, with the 2025 Super Bowl alone generating $1.1 billion in wagers, underscoring the big shift over the last 12 months from politics to sport.”
— Complaint, ¶ 7 (citing Sporting Crypto newsletter)
- This figure destroys any argument that sports betting is a minor or incidental feature of the platform. The 2025 Super Bowl alone generated more in single-event wagers than the entire U.S. sports betting market processed in all of 2017 ($4.9 billion total). Polymarket extracted $1.1 billion from a single football game.
- The phrase “big shift over the last 12 months from politics to sport” confirms this is a deliberate business pivot, not organic usage. The company actively redirected its platform’s energy toward sports gambling after the 2024 election cycle ended.
“Defendants allows anybody over the age of 18 to gamble on their platform in complete disregard for the laws prohibiting individuals under the age of 21 to gamble in New York.”
— Complaint, ¶ 73
- New York law sets 21 as the minimum age for sports wagering at licensed facilities. By allowing 18-year-olds, Polymarket exposes three full years of legally-adults-but-not-legally-permitted-to-gamble users to a product the complaint characterizes as designed to encourage addiction.
- This allegation is particularly damaging because age verification is one of the baseline compliance requirements for any gambling platform. Its absence is not an oversight; it is a policy choice that maximizes the addressable user base at the expense of a protection that exists specifically because young adults are the highest-risk demographic for gambling disorder.
— Complaint, ¶¶ 118–119
Who Pays When the House Wins Without a License
Public Health
Polymarket entered a U.S. gambling market already in a public health crisis, then added fuel. The documented damage is specific and measurable.
- Approximately 2.5 million adults in the U.S. suffer from severe gambling disorders, with an additional 5 to 8 million experiencing significant problems. Online platforms like Polymarket directly expand the reach of gambling addiction by removing the physical friction of entering a casino.
- People diagnosed with gambling disorders are 15 times more likely to die by suicide than the general population, according to research cited in the complaint from Harvard University. This is not an abstraction. It is a mortality multiplier tied directly to the industry Polymarket profits from.
- Internet searches for gambling addiction help, such as “am I addicted to gambling,” rose 23% nationally since the 2018 legalization ruling through June 2024, representing an estimated 6.5 to 7.3 million total help-seeking searches, with 180,000 monthly searches at peak. Polymarket’s unlicensed operation contributed to demand it refused to acknowledge with a single helpline number.
- Young men between 18 and 21 face the highest risk: 10% of that demographic exhibits signs of gambling addiction, compared to 3% of the general population. Polymarket’s minimum age of 18, three years below New York’s legal requirement, placed its most addictive product directly in the hands of this highest-risk group.
- The National Council on Problem Gambling documented a 45% increase in helpline contact between 2021 and 2022 alone. Polymarket offered no helpline on its advertising, no problem gambling plan, no self-exclusion program, and no quarterly reporting to any regulator on the mental health impacts of its platform.
- The complaint describes a platform built to exploit “psychological triggers associated with gambling and addiction in order to target susceptible populations.” The UI puts “potential winnings in a visually prominent way while downplaying the costs and odds,” a design pattern replicated from the most predatory corners of the regulated gambling industry.
— Complaint, ¶ 11
Economic Inequality
The financial harm documented in this case is structured, systematic, and deliberately obscured from the users bearing all the risk.
- Polymarket processed over $6 billion in lifetime sports-related wagers and achieved a $12 billion valuation. Every dollar of that valuation was built, at least in part, on users who believed they were engaging in legal activity and had no way to independently verify otherwise.
- The platform retains a transaction fee on every single bet, including losing ones. This means users can lose money, and Polymarket still profits from that loss. The complaint characterizes Polymarket as the “winner” under New York’s loss recovery statute precisely because the fee structure guarantees revenue regardless of outcomes.
- Licensed sportsbooks pay substantial state taxes on gambling revenue. By operating without a license, Polymarket has evaded these tax obligations entirely. The complaint notes this directly: “By operating outside the licensing system, Polymarket avoids the robust taxes paid by lawful operators.” That tax shortfall is money that would fund public services, including, in some states, problem gambling treatment programs.
- The class action structure exists precisely because individual financial losses are small relative to the cost of litigation. Most class members would receive nothing if they pursued claims individually. The platform’s bet sizing is calibrated to keep individual losses below the threshold of practical legal action, while aggregating enormous revenue across millions of transactions.
- Low-income users disproportionately bear the costs of unregulated gambling. Licensed platforms are required to provide self-exclusion programs, deposit limits, and cooling-off periods. Polymarket provided none of these. Without these guardrails, users with the least financial resilience have the least protection against catastrophic loss.
- The complaint describes families and communities as secondary victims: “The addiction and fallout related thereto is not limited to gamblers. It has a ripple effect that negatively impacts spouses, partners, children, and employers.” Polymarket’s unlicensed operation externalized these costs entirely onto households and social services.
What Polymarket’s Penalty Bought — and What It Didn’t
Who to Contact, What to Demand, and How to Push Back
The lawsuit has been filed, the regulators have been notified, and the states are moving. Here is exactly who holds power over this situation and what you can do with that information.
The People Running This Operation
The complaint identifies the following executives and corporate structures as responsible parties:
- Shayne Coplan, Founder and Chief Executive Officer of Polymarket. He personally made the public statements characterizing the platform as a legal “prediction market” that the lawsuit identifies as deceptive. He made these statements on 60 Minutes while regulators were already moving against the company.
- Blockratize, Inc. d/b/a Polymarket: Delaware corporation, headquartered in New York City. The primary operating entity named in the lawsuit.
- Adventure One QSS, Inc. d/b/a Polymarket.com: Incorporated in Panama. Principal office listed at 1280 Lexington Avenue, Suite 1448, New York City, NY 10028. The use of a Panama corporation for a New York-operated platform raises questions about regulatory arbitrage that the lawsuit does not answer but regulators will certainly ask.
- QCX LLC d/b/a Polymarket US: Delaware LLC, 7251 W. Palmetto Park Road, Suite 102, Boca Raton, FL 33433.
Regulatory Watchlist
The following agencies have direct jurisdiction over Polymarket’s conduct or are already actively engaged. Contact them, file complaints, and demand enforcement updates.
- CFTC (Commodity Futures Trading Commission): Already issued a $1.4 million penalty against Polymarket in 2022 and forced a shutdown. The relaunch with the same business model is a direct challenge to its authority. File at cftc.gov/complaint.
- Nevada Gaming Control Board (NGCB): Filed a civil enforcement action against Polymarket on January 16, 2026. The NGCB is one of the most authoritative gambling regulators in the world. Its move gives other states legal scaffolding to follow.
- New York State Gaming Commission: Already issued a cease-and-desist to Kalshi, Polymarket’s direct competitor, in October 2025 under nearly identical facts. The Commission has explicit authority to levy civil penalties against Polymarket under the same Racing Law provisions.
- Tennessee Sports Wagering Council: Issued a formal cease-and-desist January 9, 2026, ordering Polymarket to refund deposits and void open contracts. They moved first among state councils; others will follow their template.
- California Attorney General’s Office: The complaint cites the AG’s prior conclusion that prediction market-style sports contracts are unlawful gambling under California law. File complaints at oag.ca.gov.
- FTC (Federal Trade Commission): Has jurisdiction over deceptive advertising in commerce. Polymarket’s marketing campaign — which the lawsuit describes as actively misrepresenting the platform’s legality to consumers across all 50 states — falls squarely within the FTC’s mandate. File at reportfraud.ftc.gov.
- CFPB (Consumer Financial Protection Bureau): Has authority over companies that accept consumer payments in connection with financial services. Polymarket processes real-money transactions from U.S. consumers without the disclosures and protections that licensed financial services providers must offer.
- DOJ / FBI Internet Crime Division: The complaint cites the Illegal Gambling Business Act of 1970 (18 U.S.C. § 1955) as a federal criminal statute Polymarket violates. The DOJ has jurisdiction to investigate and prosecute. File at ic3.gov.
If You Wagered on Polymarket
- Document everything now. Screenshot your transaction history, deposit records, and any Polymarket advertising or communications you received. Courts need evidence of harm for class action certification and individual damages calculations.
- Contact the class action counsel directly. The attorneys of record are Leanna A. Loginov of Shamis & Gentile, P.A. (lloginov@shamisgentile.com, 305-479-2299) and Omer Kremer / Gabriel Mandler of Edelsberg Law, P.A. (omer@edelsberglaw.com, 786-289-9470). If you are a U.S. resident who wagered on Polymarket, you may qualify as a class member.
- File a complaint with your state gaming commission. Every complaint on record strengthens the regulatory case for enforcement and refund orders. Tennessee’s refund mandate came directly from documented consumer complaints.
- If you or someone you know has a gambling problem: Call 1-800-522-4700 or text “HOPENY” to 467369. These are free, confidential, 24/7 resources that Polymarket was legally required to post on its platform and never did.
Mutual Aid and Grassroots Organizing
- Share the source documents. The full complaint is publicly available from the Southern District of New York (Case No. 1:26-cv-00973). Sharing primary legal documents, not just headlines, forces accountability and prevents the story from being softened by PR cycles.
- Push your state legislators. The complaint documents states where enforcement is already happening. If your state is not on that list, your legislators need to hear from you. Contact forms for every state legislature are available at openstates.org.
- Support problem gambling organizations. The National Council on Problem Gambling (ncpgambling.org) directly tracks the harms that platforms like Polymarket cause and lobbies for the mandatory protections Polymarket bypassed. Their funding determines their reach.
- Hold media accountable. Polymarket received favorable press coverage for years while regulators were building cases against it. When outlets run puff pieces about prediction markets, link them to the complaint. Primary documents end spin.
The source document for this investigation is attached below.
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