Consumer complaint received 2025-09-22 00:00:00
Product: Money transfer, virtual currency, or money service — Mobile or digital wallet
Issue: Unauthorized transactions or other transaction problem — 
Company: Paypal Holdings, Inc
State: FL

Complaint narrative:
" I am filing this complaint because my dispute regarding transactions made with my XXXX XXXXXXXX XXXX to the merchant 'XXXX  ' was unfairly denied by XXXX  . These transactions, totaling approximately {$400.00} were for what I now understand to be an illegal online gambling service. The XXXXXXXX XXXX, as the issuer of my XXXX Debit Card, and XXXX, as the payment processor, are obligated to reverse these charges due to the deceptive practices employed, the inherent illegality under Florida law, and violations of XXXX Operating Regulations. 
As an individual with a XXXX XXXX, I am particularly vulnerable to platforms that obfuscate their true nature. XXXX markets itself as a 'social casino ' and 'sweepstakes, ' which falsely suggests a legal and safe entertainment product. Due to this deceptive marketing, I was led to believe I was participating in a lawful sweepstakes, not an unregulated and illegal gambling operation that exploited my vulnerability. 
between XXXX, I used my XXXX XXXXXXXX XXXX to purchase XXXXXXXX XXXX ' from XXXX. This service fundamentally functions as an unlicensed and illegal lottery under Florida Statute 849.09. This statute defines an illegal lottery by the presence of three elements : ( 1 ) a prize, ( 2 ) consideration, and ( 3 ) a result determined by chance. XXXXXXXX XXXX  service clearly meets all three : Prize : XXXX offers cash prizes through the direct redemption of its XXXXXXXX XXXX ' for U.S . Dollars ( XXXX SC = {$1.00} USD ). 
Chance : The outcome of its casino-style games ( e.g., slots, card games ) is predominantly determined by chance. 
Consideration : My purchase of XXXXXXXX XXXX ' ( which are bundled with 'XXXX XXXX  ' necessary to play for cash prizes ) constitutes 'consideration. ' The merchant 's purported 'no purchase necessary " Alternate Method of Entry ( AME ) is commercially unviable and designed to funnel users into purchasing XXXXXXXX XXXX ' thereby making payment the de facto consideration. 
As a resident of Florida, I was deceived into entering into transactions for an illegal purpose. Under fundamental contract law, a contract for an illegal purpose, especially when coupled with deceptive marketing preying on consumer vulnerability, is void and unenforceable. The electronic fund transfers I authorized for this illegally represented service are invalid. 
Furthermore, XXXX is violating XXXX Operating Regulations. Merchants engaged in gambling activities are required to use specific Merchant Category Codes ( MCC XXXX : Betting/Casino Gambling ). XXXX, I believe, is deliberately miscategorizing these transactions under generic codes ( e.g., 'Digital Goods ' or 'Entertainment ' ) to circumvent regulatory scrutiny. XXXXXXXX XXXX network expressly prohibits its use for illegal transactions. By processing these transactions, The XXXXXXXX XXXX  and XXXX  are facilitating illegal activity and violating their own network 's policies. 
I initiated a dispute with XXXX on XX/XX/year> stating that " I participated in this transaction, but there is a problem, ' and further specified that 'The merchandise or service is not as described ' because it was an illegal gambling service exploiting deceptive marketing. This claim was unjustly denied by XXXX on [ Date of denial ]. 
I provided clear evidence, including screenshots of XXXX 's purchase pages, gameplay featuring cash-redeemable 'Sweeps Coins, ' and their prize redemption processes, all of which unequivocally demonstrate the gambling nature of the service. My XXXX XXXXXXXX XXXX statement also shows these transactions. 
I request that the CFPB investigate why The XXXXXXXX XXXX ( via XXXX ) is facilitating and denying disputes for transactions that fund an illegal operation under Florida law, violate explicit XXXX network policies, and exploit individuals susceptible to gambling-related deception. I seek a full reversal of all disputed transactions totaling XXXX. ''

Company response to consumer: Closed with explanation