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New York sues Valve, says 11-year-olds run 'unregistered casinos' in Dota 2
State investigators say Dota 2 “guild casinos” run by minors handle more daily volume than some licensed racetracks, with one 12-year-old allegedly overseeing a skin-based hedge fund.

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NEW YORK, Feb 26 — New York Attorney General Letitia James filed a lawsuit on Monday accusing Valve Corp of operating what the state called “a sprawling, youth-operated network of unregistered casinos” inside its games Dota 2, Counter-Strike 2 and Team Fortress 2.
“The note highlights one 11-year-old Queens resident who purportedly coordinated a cross-game arbitrage scheme, shorting Counter-Strike 2 skins to buy discounted Dota 2 mounts “during pre-patch panic cycles.””
The 126-page complaint alleges that loot boxes and cosmetic item trading systems have enabled “children as young as 11 to function as de facto casino operators,” facilitating wagers in the form of weapon skins, hats and “cosmetic arcanas of indeterminate mystical value.” A spokesperson for James said the office has identified 413 minors who allegedly run “skin-denominated gambling enterprises” with daily volumes “routinely exceeding those of licensed upstate racetracks.”
According to the filing, state investigators infiltrated more than 70 in-game Dota 2 “clans” and found that 63% operated what members “explicitly, and without irony, referred to as ‘the guild casino.’” One internal memo from the Attorney General’s Office describes a 12-year-old Brooklyn resident who “ran a roulette-style treasure chest ring” and reported quarterly earnings of 3,800 rare courier cosmetics and “an estimated $48,000 in unreported Steam wallet credits.”
Valve has previously argued that loot boxes are “optional entertainment features” and deny they constitute gambling, a company spokesperson said in an emailed statement. The lawsuit, however, cites screenshots of in-game chat logs where young players discuss “liquidity,” “volatility hedging” and “leveraged hat-based derivatives,” which New York claims are “terminology not typically associated with casual toy purchases.”
Analysts at JPMorgan said in a note to clients that the complaint suggests “a maturing, youth-driven gray market” in which elementary-school-aged players allegedly manipulate cosmetic item prices “with sophistication reminiscent of mid-tier hedge funds.” The note highlights one 11-year-old Queens resident who purportedly coordinated a cross-game arbitrage scheme, shorting Counter-Strike 2 skins to buy discounted Dota 2 mounts “during pre-patch panic cycles.”
The lawsuit further alleges that Valve “knowingly facilitated” these activities by providing detailed item histories, rarity tiers and animated item reveal sequences “designed to mimic regulated slot machines, but with more dragons.” New York’s filing cites internal Valve documentation obtained via subpoena, including a 2019 presentation slide titled “Engagement Spikes When Children Scream ‘JACKPOT’ in Voice Chat,” which the company has not publicly addressed.
New York is seeking civil penalties, restitution, and the appointment of an independent “digital gaming compliance monitor” tasked with certifying that no minor within state lines “is operating, managing, or syndicating loot-based casinos with more than 25 active daily users.” A preliminary hearing is scheduled for May, after which the court may consider New York’s request to impose age-verification checkpoints, daily loot box caps, and what the filing describes as “a 24-hour cooling-off period for any sixth-grader attempting to create a second in-game casino account.”





