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In Sweden, Spelinspektionen recently flagged affiliates and social media as key channels for black market advertising and how affiliate networks redirect search traffic towards unlicensed operators.

Regulators have so far focused mainly on monitoring paid advertising. In Germany, the GGL credited an updated Google ad policy with reducing black market visibility. Yet, it acknowledged that illegal operators could still achieve visibility in organic search through SEO manipulation. 

This points to a wider shift towards addressing organic search signals and domain-level practices such as doorway pages, an issue also raised in the UK, where research has linked black market migration to search-driven promotion and SEO exploitation.

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“The Court should refuse the relief requested by … because it is manifestly contrary to the public policy of the United States based on the Debtors’ well-documented and pervasive bad faith conduct,” the petition said. “The Debtors are using the Israeli Action—a limited action which lacks many of the core characteristics of a collective insolvency proceeding—as a strategic tool to evade responsibility for their deceptive conduct.”

On Aug. 26, Tel Aviv District Court Judge Iris Lushi-Abudi rejected Papaya’s motion to pay down the Skillz judgment over 6.5 years with profits from its continuing operations.

Yaron Elhawi, an attorney based in Tel Aviv representing Skillz, said in court filings that Papaya has not proposed a reformulated debt arrangement, nor suggested how it intends to treat Skillz’s debt.