Coalitions warn bill threatens innovation and legal promotions amid vague definitions and rushed process
A growing coalition of digital gaming and promotional industry stakeholders is urging California lawmakers to halt Assembly Bill 831 (AB831), a controversial piece of legislation that opponents say could have sweeping consequences for legitimate sweepstakes-based online entertainment platforms. Introduced via a last-minute “gut-and-amend” maneuver on June 24, AB831 has drawn significant criticism for its broad language, opaque terminology, and potential to criminalize widely accepted promotional practices.
The bill seeks to revise key definitions in California’s gambling code, particularly targeting “freemium plus sweepstakes” models that combine digital gameplay with potential prize redemption. These models are commonly used by social casino games and promotional platforms that operate legally under existing federal and state frameworks.
SGLA and SPGA: Bill Could Criminalize Legal Business Models
The Social Gaming Leadership Alliance (SGLA) and the Social and Promotional Games Association (SPGA) have been at the forefront of opposition. In a Senate Governmental Organisation Committee hearing on July 2, SGLA Executive Director Jeff Duncan, a former U.S. Congressman, criticized the bill as anti-competitive:
“This bill isn’t about protecting players. It’s about protecting incumbents from innovation and competition.”
The SPGA echoed these sentiments in a formal letter to Assemblyman Avelino Valencia, calling the bill “too vague, too rushed, and too risky.” Legal experts and industry leaders fear that the bill’s vague definitions—such as “dual currency system,” “cash equivalents,” and “indirect consideration”—could lead to unintended criminalization of standard promotions used by tech companies, retailers, and media platforms.
Legal Ambiguities Spark Compliance Nightmares
Gaming attorney Bill Gantz emphasized that social casino games—typically free to play with optional in-app purchases—have operated legally in California since 2012.
“These are legitimate entertainment services. The mechanics used by so-called illegal games are also common in mainstream consumer promotions,” he said.
AB831 proposes penalties of up to $25,000 in fines and one year in jail, not just for operators, but also for vendors, payment processors, and even advertising outlets that promote or facilitate these platforms.
Public and Political Pushback Grows
In the week leading up to the hearing, more than 20,000 California residents submitted calls, letters, and messages opposing the bill. Senator Rosilicie Ochoa Bogh acknowledged flaws in the bill’s rushed trajectory, commenting:
“This is what happens when we don’t go through the proper process.”
Critics argue that AB831 bypasses normal legislative procedures and stakeholder engagement. Given its potentially far-reaching consequences, both SGLA and SPGA are advocating for converting AB831 into a two-year bill, which would delay its passage to allow time for comprehensive consultation, definition refinement, and economic impact analysis.
Broader Implications for Digital Entertainment and Commerce
If passed in its current form, AB831 could disrupt a wide swath of digital commerce, from loyalty rewards programs to sweepstakes run by retailers and influencers. Industry leaders caution that such overreach would stifle innovation, limit consumer choice, and push responsible operators out of California’s market.
At stake is not only the future of social gaming, but also California’s reputation as a hub for tech-forward entertainment and digital innovation. As scrutiny intensifies, lawmakers face increasing pressure to revisit the bill’s intent and language before it becomes a legislative misstep with long-lasting ramifications.
