A new gaming model for sweepstakes casinos has emerged in the post-California Assembly Bill 831 world. And this one eliminates the need for Sweeps Coins or any type of dual-currency or multiple-currency ecosystem altogether.
This model uses real money.
It’s advance deposit wagering.
Yes, sweeps gaming companies are now creating platforms that use horse racing results to determine the outcome of the casino-style games their players play. Think of it as something akin to the horse racetracks that offer historical horse racing machines — which are really just slot machines whose results are determined by historical horse race results — but taken online.
This is the model employed by GiddyUp, the new venture from KHK Games, which also owns the sweeps casinos Clubs Casino and Clubs Poker. HorsePlay is an online gaming platform that also uses this model. As does Lonestar.bet, the newly launched horse racing results-fueled gaming site from RealPlay Tech, which owns sweeps casinos RealPrize and Lonestar.
And these operators may have a court case in Michigan to thank for them being able to pursue this new, seemingly 100% legal approach to offering online gaming.
Churchill Downs vs. Michigan Gaming Control Board
A legal fight between Churchill Downs Incorporated and the Michigan Gaming Control Board that began in 2025 ended in January in a decisive win for the operator, with far-reaching implications.
The dispute began after regulators in Michigan revoked the advance deposit wagering license tied to TwinSpires, arguing the platform no longer met state requirements once its in-state racetrack partner shut down. Churchill Downs challenged that action in court.
And on Jan. 6, it won.
At the heart of the ruling is the Interstate Horseracing Act of 1978 (IHA), which governs interstate betting on horse racing. The court found that Michigan’s attempt to impose additional licensing conditions — beyond the consent structure outlined in the federal statute — created a conflict. In this case, federal law took precedence.
Here’s the bottom line: The IHA establishes the controlling framework for interstate horse race wagering, and states cannot add on requirements that override that system.
So, under the guidance of this ruling, operators theoretically can structure products around the IHA’s consent model rather than navigating fragmented, state-by-state licensing regimes.
In practical terms, that opens the door for companies to create platforms resembling online casino play, with the results based on live racing or historical horse racing instead of pure chance, without relying on traditional state licenses. Instead, companies would just need to land the approvals necessary under the IHA.
Those approvals?
- The state where the player is located
- The state where the horse race takes place
- The racetrack or racing association hosting the event
How modern ADW, casino-style sites abide by the law
GiddyUp, for example, is licensed by the Oregon Racing Commission. And it’s currently live in 17 states: Alabama, California, Colorado, Connecticut, Delaware, Florida, Kansas, Louisiana, Michigan, North Dakota, Nebraska, New Mexico, New York, Oklahoma, Rhode Island, Wisconsin, and Wyoming.
“GiddyUp is an online entertainment platform where players can engage in real-money games powered by the results of live horse races,” GiddyUp’s About page reads. “The platform blends digital gameplay with real racing outcomes for a unique and engaging experience.”
HorsePlay, which is live in 18 states, clearly states it’s being regulated by the IHA on the footer of its site, where it says: “Horseplay is US legal, authorized to conduct online horse wagering pursuant to state licenses and the federal Interstate Horse Racing Act.”
Both HorsePlay and Lonestar.bet say in their terms and conditions that their betting services are being provided by the Game Play Network, a licensed advanced deposit wagering platform.
“LoneStar.bet is a service of Game Play Network,” the Lonestar.bet About page reads. “Headquartered in Los Angeles, Game Play Network is US legal, authorized to conduct online horse wagering pursuant to state licenses and the federal Interstate Horseracing Act. Don’t just play for fun. Play for real.”
These three platforms mark a full departure from the Gold Coin and Sweeps Coin gaming ecosystem. Instead, these are sweeps casinos creating and launching real-money wagering platforms under the legal purview of advanced deposit wagering governed by the IHA — which, according to the Michigan ruling in favor of TwinSpires, overrules any state-level regulation.
