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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.

Papaya granted a $10 million dividend to shareholders at the end of 2025.

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The DSWV said the findings should prompt a thorough reassessment of official black market size estimates in Germany.

The DOCV, another trade body representing licensed online casino operators in Germany, also expressed support for the prosecutorial efforts. However, it emphasised that the raid exposed regulatory gaps which had allowed organised crime to flourish.

Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.

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The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.

All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.

It requires operators to describe in detail how they will responsibly wind down their operations should their licence not be renewed or be revoked. Or if they decide to leave the market midway through the five years between renewals.