pelimies79
Newbie member
- Joined
- May 2, 2025
- Location
- Finland
How should I react to the decision? The fact is that I was living in Spain this year using the local net in addition to my Finnish mobile one.
The Respondent is L.C.S. Limited, a company registered under Maltese law with registration
Number and registered address Ta'Xbiex Malta Suite 1, Sterling Building, Enrico Mizzi Street Suite
1, Sterling Building, Enrico Mizzi Street Ta'Xbiex Malta.
2. Procedural History
The Complaint was filed by the Complainant with the Maltese Dispute Resolution Entity ("MADRE")
on the 25 Mar 2025 by online submission.
In accordance with the Rules of Procedure, MADRE formally notified the Respondent of the
Complaint and this case was formally opened on 25 Mar 2025. The response by the Respondent
was submitted on the .
MADRE appointed one of its adjudicators as the sole arbiter for this case.
3. Factual Background
The Complaint refers in particular to an incident on the 20 Mar 2025. At the time the Complainant
was active as a customer on the Respondents platform.
madre-online.eu
4. Complainant’s Claim
The Complainant requests Withdrawal of Winnings amounting to EUR 1,346.22.
5. Contentions of the Parties
Complainant
The Complainant holds the forthcoming:
Dazzlehand confiscated everything except returned my last deposit. Nothing was wrong with my
bets and neither did I anything else the long list includes.
Any evidence substantial for MADRE‘s ruling is reproduced below.
Respondent
The Respondent holds that the claim is not sufficiently founded. The Respondent states:
Response to Case 3048349640
Response to the unjustified deduction claim
The complainant alleges that DazzleHand Casino wrongfully deducted the sum of 1346.22€ from
their account. However, we shall present clear and compelling evidence demonstrat- ing that the
complainant’s activities constituted a breach of our General Terms and Conditions, thereby
justifying our actions as lawful and appropriate. At this juncture, we would like to draw attention to
the fact that during the registration process, the com- plainant employed the use of a proxy server
to access our platform. In this regard, we respectfully invoke Term 12.10 of our General Terms and
Conditions, which expressly stipulates the following:
12.10 Company reserves the right, in its sole discretion, to void any winnings and forfeit any
balance (winnings and deposits) in your betting account, to terminate the Agreement and/or to
suspend the provision of the Services or deactivate your account if: i) we identify you have
disguised or interfered, or taken steps to disguise or interfere, in any way with the IP address of any
Device used to access our Site (such as using a Virtual Private Network “VPN”) ii) it comes to our
attention that the customer used forged documents (photos, scanned documents, screenshots etc.)
during the verification procedure or in any point time the Agreement is active iii) there is a
reasonable suspicion that you have committed or attempted to commit a bonus abuse, either on
your own or as part of a group iv) you are involved in any fraudulent, collusive, fixing or other
unlawful activity in relation to Your or third parties’ participation or you use any software-assisted
methods or techniques or hardware devices for Your participation in any of the services provided by
the Company.
Grounds for deduction
Contrary to the complainant’s allegations, our actions were fully following the rules and terms to
which the complainant agreed upon registration. As illustrated in Figure 1, we detail the sports
betting restrictions that were applied to all of the L.C.S. complainants’ accounts by our Sports
Trading Teams. These limitations were imposed in response to the complainant’s problematic
betting activities, which were deemed to present an un- acceptable level of risk to our operations.
The restrictions were implemented with the sole purpose of mitigating risk and preventing the
complainant from exploiting discrep- ancies in odds across multiple brands, including multiple L.C.S
platforms as shown, for arbitrage and other opportunistic tactics aimed at maximizing profit unfairly.
Overall, the complainant’s activities remained consistent across our brands, reflecting a system- atic
and deliberate effort to maximize profits without engaging in valid wagering of their actual funds.
This pattern of behavior further underscores the complainant’s intention to exploit our platform for
financial gain in violation of our Terms and Conditions.
Figure 1: Sports limitations applied to the L.C.S accounts of the complainant
Furthermore, we wish to draw your attention to the complainant’s actual sports bet- ting patterns on
DazzleHand. As demonstrated in Figures 2 & 3, the complainant’s activity remained within normal
parameters until recently, at which point their transac- tions began to exhibit characteristics
indicative of problematic or exploitative behavior. This prompted the Risk Department to undertake
a comprehensive investigation, which ultimately resulted in the imposition of a maximum stake of 1€
per betslip across all available sports markets.
Figure 2: 1€ strict limitations for all markets, applied to complainant’s Dazzlehand account
Figure 3: 1€ strict limitations for all markets, applied to complainant’s Dazzlehand account
Finally, in Figures 4,5 & 6, we present samples of the IP addresses recorded when the complainant
instigated activity in DazzleHand. As is clearly shown, those correspond to an external VPN/Proxy
server, which was used to access DazzleHand.com. This finding constitutes a violation of the
aforementioned Term 12.10, since, in alignment with our above findings, it strongly indicates BOT
activity and external tools deployed for maximizing profits and served as the basis for our decision.
Figure 4: Evidence of Proxy usage by the complainant to access the DazzleHand.com domain with
a Spanish IP while the registered location is Finland
Figure 5: Evidence of Proxy usage by the complainant to access the DazzleHand.com domain with
a Spanish IP while the registered location is Finland
Figure 6: Evidence of Proxy usage by the complainant to access the DazzleHand.com domain with
a Finnish IP
Conclusion
In conclusion, DazzleHand Casino maintains its position regarding the issues raised by the
complainant. Our team acted in full compliance with the terms and conditions of our promotional
offer. It is important to note that, while Term 12.10 does not entirely encompass the full scope of the
complainant’s problematic and abusive behavior across our brand, it was nonetheless breached.
This breach was deemed sufficient by our Risk Department to proceed with voiding the
complainant’s activity and the removal of the associated profits at the time (1346.22€).
We are committed to resolving this matter amicably and look forward to your re- sponse.
Sincerely, The DazzleHand Team
Any evidence substantial for MADRE‘s ruling is reproduced below.
6. Discussion and Findings
Admissibility
MADRE has found the claim admissible under Sections 2 of the Rules of Procedure as the
Respondent has duly submitted to MADRE's arbitration procedure.
In accordance with the Rules of Procedure, MADRE has to decide a complaint on the basis of the
statements and documents submitted and in accordance with these Rules, the applicable Terms
and Conditions and in due consideration of the principles of law that it deems applicable [MADRE
rules of procedure, section 3(c)]. In particular, the Maltese Gaming Player Protection Regulations
(L.N. 246 of 2018) and the MGA Directive 2 of 2018 Player Protection Directive must be considered
in the present case.
There is general consistency between the parties that the amount in question was won by the
Complainant playing in an online casino under the MGA license of the Respondent. The winnings
amount to EUR 1.346,22.
The Respondent claims that he had the right to void the Complainants winnings due to 'fraudulent
activities' - due to utilization of IP Proxies - that constitutes a violation of the Respondents Terms
and Conditions. It has hence to be determined, whether the objection and the resulting legal actions
of the Respondent have been lawful. This would be the case, if the relevant Terms and
Conditions the Respondent quotes, are applicable, if the behavior of the Complainant falls under
the requirements of those Terms and Conditions and can thus be deemed as 'fraudulent', and if the
Respondent had thus the right to void winnings of the Complainant as a legal consequence based
on the alleged breach of the Respondents Terms and Conditions.
Contractual basis of Relationship
By taking recourse to the Respondent’s complaints procedure, which is based on the Respondents
Terms and Conditions as well as the general MGA regulation, the Complainant at least implicitly
recognizes the validity of the Terms and Condition as a basis for the contractual relationship
between himself and the Respondent.
Accordingly, the terms and conditions of the Respondent may be referred to for the determination of
the judgement in the present case.
Applicable Terms and Conditions
The Respondent complains about the breach of Clause 12.10 of the Respondents terms and
conditions by the Complainant:
12.10 Company reserves the right, in its sole discretion, to void any winnings and forfeit any
balance (winnings and deposits) in your betting account, to terminate the Agreement and/or to
suspend the provision of the Services or deactivate your account if: i) we identify you have
disguised, or interfered, or taken steps to disguise or interfere, in any way with the IP address
of any Device used to access our Site (such as using a Virtual Private Network “VPN”) ii) it
comes to our attention that the customer used forged documents (photos, scanned documents,
screenshots etc.) during the verification procedure or in any point time the Agreement is active
iii) there is a reasonable suspicion that you have committed or attempted to commit a bonus
abuse, either on your own or as part of a group iv) you are involved in any fraudulent, collusive,
fixing or other unlawful activity in relation to Your or third parties’ participation or you use any
software-assisted methods or techniques or hardware devices for Your participation in any of
the services provided by the Company.
It is decisive, whether the behavior of the Complainant falls under the scope of the clauses
mentioned above. The Respondent provides detailed evidence that the Complainant used IP
Proxies. MADRE deems it proven beyond reasonable doubt that the Complainant has utilized tools
in order to gain an unfair advantage playing in the casinos of the Respondent. The Complainant is
hence in direct breech of the Respondents Terms and Conditions that form the basis of the legal
relationship at hand.
It is not relevant, whether the Complainant has acted deliberately and purposefully in an abusive
manner. For a breach of these terms and conditions no fault in the sense of negligence or intent is
required. Due to the contractual relationship between the parties, it is sufficient that the
Complainants actions actually fulfill Clause 12.10 in order to constitute a breach.
Lawfulness of the legal consequences taken by the Respondent
Lastly, it has to be determined whether the Respondents immediate action to void the winnings of
the Complainant was lawful. While the law and Maltese gambling regulation provide several
reasons to lawfully freeze player funds for a limited period of time, the permanent confiscation of
funds seems more difficult to argue. Hence, the Terms and Conditions need to clearly grant the
Respondent a right for his actions as a consequence of the breaches outlined above. The
Respondent invoked the right to permanently close the Complainants account and confiscate funds
available on the account. This right is was derived from Clause 12.10 first sentence directly. Due to
the severity of the breach MADRE considers the consequence of forfeiting winnings to be
reasonable and justified, hence lawful.
Conclusion
Within the framework of contractual relationship between the Complainant and the Respondent, the
general terms and conditions of the Respondent were binding for the Complainant and thus
governing the legal relationship between the parties of the case.
The Complainant has violated the Terms and Conditions; the Complainants behavior is to be
classified as 'fraudulent' in the sense of Clause 12.10 of the Terms and Conditions, due to the
utilization of IP proxies.
Based on the Complainant's breach, the Respondent had the right to declare the Complainant's
winnings void according to Clause 12.10 first sentence of the Respondents Terms and Conditions.
Accordingly, the Complainant has no claim against the Respondent for payment of the winnings in
the amount of EUR 1.346,22. The case is decided in favor of the Respondent.
Therefore, MADRE follows the argumentation of the Respondent.
7. Decision
MADRE accedes to the submissions of the Respondent. The submissions made by the opposing
party could not convince the arbitrator and are therefore rejected.
The Respondent is L.C.S. Limited, a company registered under Maltese law with registration
Number and registered address Ta'Xbiex Malta Suite 1, Sterling Building, Enrico Mizzi Street Suite
1, Sterling Building, Enrico Mizzi Street Ta'Xbiex Malta.
2. Procedural History
The Complaint was filed by the Complainant with the Maltese Dispute Resolution Entity ("MADRE")
on the 25 Mar 2025 by online submission.
In accordance with the Rules of Procedure, MADRE formally notified the Respondent of the
Complaint and this case was formally opened on 25 Mar 2025. The response by the Respondent
was submitted on the .
MADRE appointed one of its adjudicators as the sole arbiter for this case.
3. Factual Background
The Complaint refers in particular to an incident on the 20 Mar 2025. At the time the Complainant
was active as a customer on the Respondents platform.
madre-online.eu
4. Complainant’s Claim
The Complainant requests Withdrawal of Winnings amounting to EUR 1,346.22.
5. Contentions of the Parties
Complainant
The Complainant holds the forthcoming:
Dazzlehand confiscated everything except returned my last deposit. Nothing was wrong with my
bets and neither did I anything else the long list includes.
Any evidence substantial for MADRE‘s ruling is reproduced below.
Respondent
The Respondent holds that the claim is not sufficiently founded. The Respondent states:
Response to Case 3048349640
Response to the unjustified deduction claim
The complainant alleges that DazzleHand Casino wrongfully deducted the sum of 1346.22€ from
their account. However, we shall present clear and compelling evidence demonstrat- ing that the
complainant’s activities constituted a breach of our General Terms and Conditions, thereby
justifying our actions as lawful and appropriate. At this juncture, we would like to draw attention to
the fact that during the registration process, the com- plainant employed the use of a proxy server
to access our platform. In this regard, we respectfully invoke Term 12.10 of our General Terms and
Conditions, which expressly stipulates the following:
12.10 Company reserves the right, in its sole discretion, to void any winnings and forfeit any
balance (winnings and deposits) in your betting account, to terminate the Agreement and/or to
suspend the provision of the Services or deactivate your account if: i) we identify you have
disguised or interfered, or taken steps to disguise or interfere, in any way with the IP address of any
Device used to access our Site (such as using a Virtual Private Network “VPN”) ii) it comes to our
attention that the customer used forged documents (photos, scanned documents, screenshots etc.)
during the verification procedure or in any point time the Agreement is active iii) there is a
reasonable suspicion that you have committed or attempted to commit a bonus abuse, either on
your own or as part of a group iv) you are involved in any fraudulent, collusive, fixing or other
unlawful activity in relation to Your or third parties’ participation or you use any software-assisted
methods or techniques or hardware devices for Your participation in any of the services provided by
the Company.
Grounds for deduction
Contrary to the complainant’s allegations, our actions were fully following the rules and terms to
which the complainant agreed upon registration. As illustrated in Figure 1, we detail the sports
betting restrictions that were applied to all of the L.C.S. complainants’ accounts by our Sports
Trading Teams. These limitations were imposed in response to the complainant’s problematic
betting activities, which were deemed to present an un- acceptable level of risk to our operations.
The restrictions were implemented with the sole purpose of mitigating risk and preventing the
complainant from exploiting discrep- ancies in odds across multiple brands, including multiple L.C.S
platforms as shown, for arbitrage and other opportunistic tactics aimed at maximizing profit unfairly.
Overall, the complainant’s activities remained consistent across our brands, reflecting a system- atic
and deliberate effort to maximize profits without engaging in valid wagering of their actual funds.
This pattern of behavior further underscores the complainant’s intention to exploit our platform for
financial gain in violation of our Terms and Conditions.
Figure 1: Sports limitations applied to the L.C.S accounts of the complainant
Furthermore, we wish to draw your attention to the complainant’s actual sports bet- ting patterns on
DazzleHand. As demonstrated in Figures 2 & 3, the complainant’s activity remained within normal
parameters until recently, at which point their transac- tions began to exhibit characteristics
indicative of problematic or exploitative behavior. This prompted the Risk Department to undertake
a comprehensive investigation, which ultimately resulted in the imposition of a maximum stake of 1€
per betslip across all available sports markets.
Figure 2: 1€ strict limitations for all markets, applied to complainant’s Dazzlehand account
Figure 3: 1€ strict limitations for all markets, applied to complainant’s Dazzlehand account
Finally, in Figures 4,5 & 6, we present samples of the IP addresses recorded when the complainant
instigated activity in DazzleHand. As is clearly shown, those correspond to an external VPN/Proxy
server, which was used to access DazzleHand.com. This finding constitutes a violation of the
aforementioned Term 12.10, since, in alignment with our above findings, it strongly indicates BOT
activity and external tools deployed for maximizing profits and served as the basis for our decision.
Figure 4: Evidence of Proxy usage by the complainant to access the DazzleHand.com domain with
a Spanish IP while the registered location is Finland
Figure 5: Evidence of Proxy usage by the complainant to access the DazzleHand.com domain with
a Spanish IP while the registered location is Finland
Figure 6: Evidence of Proxy usage by the complainant to access the DazzleHand.com domain with
a Finnish IP
Conclusion
In conclusion, DazzleHand Casino maintains its position regarding the issues raised by the
complainant. Our team acted in full compliance with the terms and conditions of our promotional
offer. It is important to note that, while Term 12.10 does not entirely encompass the full scope of the
complainant’s problematic and abusive behavior across our brand, it was nonetheless breached.
This breach was deemed sufficient by our Risk Department to proceed with voiding the
complainant’s activity and the removal of the associated profits at the time (1346.22€).
We are committed to resolving this matter amicably and look forward to your re- sponse.
Sincerely, The DazzleHand Team
Any evidence substantial for MADRE‘s ruling is reproduced below.
6. Discussion and Findings
Admissibility
MADRE has found the claim admissible under Sections 2 of the Rules of Procedure as the
Respondent has duly submitted to MADRE's arbitration procedure.
In accordance with the Rules of Procedure, MADRE has to decide a complaint on the basis of the
statements and documents submitted and in accordance with these Rules, the applicable Terms
and Conditions and in due consideration of the principles of law that it deems applicable [MADRE
rules of procedure, section 3(c)]. In particular, the Maltese Gaming Player Protection Regulations
(L.N. 246 of 2018) and the MGA Directive 2 of 2018 Player Protection Directive must be considered
in the present case.
There is general consistency between the parties that the amount in question was won by the
Complainant playing in an online casino under the MGA license of the Respondent. The winnings
amount to EUR 1.346,22.
The Respondent claims that he had the right to void the Complainants winnings due to 'fraudulent
activities' - due to utilization of IP Proxies - that constitutes a violation of the Respondents Terms
and Conditions. It has hence to be determined, whether the objection and the resulting legal actions
of the Respondent have been lawful. This would be the case, if the relevant Terms and
Conditions the Respondent quotes, are applicable, if the behavior of the Complainant falls under
the requirements of those Terms and Conditions and can thus be deemed as 'fraudulent', and if the
Respondent had thus the right to void winnings of the Complainant as a legal consequence based
on the alleged breach of the Respondents Terms and Conditions.
Contractual basis of Relationship
By taking recourse to the Respondent’s complaints procedure, which is based on the Respondents
Terms and Conditions as well as the general MGA regulation, the Complainant at least implicitly
recognizes the validity of the Terms and Condition as a basis for the contractual relationship
between himself and the Respondent.
Accordingly, the terms and conditions of the Respondent may be referred to for the determination of
the judgement in the present case.
Applicable Terms and Conditions
The Respondent complains about the breach of Clause 12.10 of the Respondents terms and
conditions by the Complainant:
12.10 Company reserves the right, in its sole discretion, to void any winnings and forfeit any
balance (winnings and deposits) in your betting account, to terminate the Agreement and/or to
suspend the provision of the Services or deactivate your account if: i) we identify you have
disguised, or interfered, or taken steps to disguise or interfere, in any way with the IP address
of any Device used to access our Site (such as using a Virtual Private Network “VPN”) ii) it
comes to our attention that the customer used forged documents (photos, scanned documents,
screenshots etc.) during the verification procedure or in any point time the Agreement is active
iii) there is a reasonable suspicion that you have committed or attempted to commit a bonus
abuse, either on your own or as part of a group iv) you are involved in any fraudulent, collusive,
fixing or other unlawful activity in relation to Your or third parties’ participation or you use any
software-assisted methods or techniques or hardware devices for Your participation in any of
the services provided by the Company.
It is decisive, whether the behavior of the Complainant falls under the scope of the clauses
mentioned above. The Respondent provides detailed evidence that the Complainant used IP
Proxies. MADRE deems it proven beyond reasonable doubt that the Complainant has utilized tools
in order to gain an unfair advantage playing in the casinos of the Respondent. The Complainant is
hence in direct breech of the Respondents Terms and Conditions that form the basis of the legal
relationship at hand.
It is not relevant, whether the Complainant has acted deliberately and purposefully in an abusive
manner. For a breach of these terms and conditions no fault in the sense of negligence or intent is
required. Due to the contractual relationship between the parties, it is sufficient that the
Complainants actions actually fulfill Clause 12.10 in order to constitute a breach.
Lawfulness of the legal consequences taken by the Respondent
Lastly, it has to be determined whether the Respondents immediate action to void the winnings of
the Complainant was lawful. While the law and Maltese gambling regulation provide several
reasons to lawfully freeze player funds for a limited period of time, the permanent confiscation of
funds seems more difficult to argue. Hence, the Terms and Conditions need to clearly grant the
Respondent a right for his actions as a consequence of the breaches outlined above. The
Respondent invoked the right to permanently close the Complainants account and confiscate funds
available on the account. This right is was derived from Clause 12.10 first sentence directly. Due to
the severity of the breach MADRE considers the consequence of forfeiting winnings to be
reasonable and justified, hence lawful.
Conclusion
Within the framework of contractual relationship between the Complainant and the Respondent, the
general terms and conditions of the Respondent were binding for the Complainant and thus
governing the legal relationship between the parties of the case.
The Complainant has violated the Terms and Conditions; the Complainants behavior is to be
classified as 'fraudulent' in the sense of Clause 12.10 of the Terms and Conditions, due to the
utilization of IP proxies.
Based on the Complainant's breach, the Respondent had the right to declare the Complainant's
winnings void according to Clause 12.10 first sentence of the Respondents Terms and Conditions.
Accordingly, the Complainant has no claim against the Respondent for payment of the winnings in
the amount of EUR 1.346,22. The case is decided in favor of the Respondent.
Therefore, MADRE follows the argumentation of the Respondent.
7. Decision
MADRE accedes to the submissions of the Respondent. The submissions made by the opposing
party could not convince the arbitrator and are therefore rejected.