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Madsen is clear that Trace2Trace does not shut websites down. Instead it tracks domains, identifies connections and documents changes so that regulators, enforcement authorities or other customers can use the information.

That distinction also informs his view of the wider battle. Asked whether illegal gambling can actually be defeated, his answer is: “No, but you can make it very difficult for them.”

The objective, he argues, is to make it harder for operators to simply replace a blocked domain with another one. “If they knew there was a tool that would find those new sites as well, they might become more cautious.”

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Since returning its prediction market to the US, Polymarket has regularly engaged in nonconforming advertising. Painting a water tower in the company’s blue and branding the structure with its logo is the firm’s latest marketing ploy.

In March, Polymarket opened The Situation Room, a pop-up “newsbar” in Washington, DC. The bar and lounge’s televisions played various content related to prediction markets, like Bloomberg Terminals, cable news, and live social media feeds that were “dedicated to monitoring the situation.”

A month earlier, Polymarket opened a free grocery store in New York City. The promotion ran Feb. 12-16, with shoppers allowed to gather up to $50 per person in free groceries.   

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Patrick Bergin, an attorney for Scotts Valley, rejected that argument, noting the difficulty of converting a site explicitly planned and built for gaming into something like an auto dealership.

Bergin also emphasized that the tribe had formally notified Interior twice about its launch timeline for the Preview Casino, providing regular progress updates without ever receiving a directive from federal officials to halt the project.

The conflict stems back to January 2025, when the outgoing Biden administration initially determined that the Vallejo parcel was eligible for gaming.