LEGAL OPINION LETTER FOR MOBILE APP
This is a legal opinion letter for confirmation of fulfilment of the legal requirements as a service
provider for sports fantasy games through https://apps.apple.com/us/app/newzhype/id1533535682.
The letter will also probe the completion of all necessary steps with the regulator.
Licensing requirements and completion of necessary steps with the regulator
The US does not require any type of gaming license for fantasy sports, as the Unlawful Internet
Gambling Enforcement Act of 2006 (UIEGA) carves out an exception for fantasy sports in
which “all winning outcomes reflect the relative knowledge and skill of the participants and are
determined predominantly by accumulated statistical results of the performance of individuals
(athletes in the case of sports events) in multiple real-world sporting or other events.” 31 U.S.
Code § 5362 provides as follows; ( E) does not include; (ix)participation in any fantasy or
simulation sports game or educational game or contest in which (if the game or contest involves
a team or teams) no fantasy or simulation sports team is based on the current membership of an
actual team that is a member of an amateur or professional sports organization (as those terms
are defined in section 3701 of title 28) and that meets the following conditions:
(I)All prizes and awards offered to winning participants are established and made known to the
participants in advance of the game or contest and their value is not determined by the number
of participants or the amount of any fees paid by those participants.
(II)All winning outcomes reflect the relative knowledge and skill of the participants and are
determined predominantly by accumulated statistical results of the performance of individuals
(athletes in the case of sports events) in multiple real-world sporting or other events.
(III)No winning outcome is based—
(aa)on the score, point-spread, or any performance or performances of any single real-world
team or any combination of such teams; or
(bb)solely on any single performance of an individual athlete in any single real-world sporting
or other event.

As UIEGA classifies fantasy sports as a game of skill, it doesn’t require any kind of gaming
license. Following the exception clause in the Unlawful Internet Gambling Enforcement Act
2006 (UIEGA), no licensing requirement was required for operation of the fantasy sports app.
Conclusion
The fantasy sports app complies with the legal requirements in its development. The services to
be provides by the app are legal as established above.

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