What Modo sells

Modo calls itself "America's Super Gaming App." It is operated by ARB Gaming LLC and offers casino-style games of chance, including slots and table-game formats.

The product runs on two coin currencies. Gold Coins are what players buy. Sweepstakes Coins are the second currency, and Modo's terms treat the two as separate items with separate balances. Modo also sells "Modo Box openings" under their own terms of service, and runs a loyalty program called Modo Stars.

On top of the coins sits something most sweepstakes casinos do not advertise in their own terms: a cash wallet, described below.

What the Terms of Use say

Modo published new Terms of Use effective October 1, 2026. They describe a game with nothing to win. With the exception of "no purchase necessary" promotions, the terms say, "there is no opportunity for a User on the Platform to win real-money or any prize while playing the Games, regardless of whether any purchase was made."

The money a player spends is treated as gone. "Any purchases are final," Modo is "not required to provide a refund for any reason," and the coins "carry no cash value." If an account is closed or suspended, the coins are forfeited and nothing is "converted to cash or other forms of reimbursement." Coins left unused for sixty days expire.

Yet the same terms list seventeen states where players may not use Sweepstakes Coins at all and are limited to Gold Coins. A currency with no prize attached would not need a separate list of states.

The wallet: cash in, cash out

Section 12 of the terms describes a "stored-value digital wallet" tied to each account. Players add real dollars to it, called "Wallet Cash," and use those dollars to buy Gold Coin packages and Modo Box openings. The terms say Wallet Cash is "not a deposit account."

The terms then explain how Wallet Cash comes back out. Money added to the wallet carries a "one-time (1x) purchase-through requirement": it must be spent at least once before "any withdrawal of Wallet Cash will be permitted." After that, a player "may request a withdrawal of eligible Wallet Cash." The minimum withdrawal is $6.00, and Modo may "deny, delay, or limit" any withdrawal request.

Put plainly, a player loads dollars, plays them through, and withdraws dollars. That is the shape of a casino account, whatever the terms call it.

Where Modo is offered

The terms bar access from Washington entirely. They bar Sweepstakes Coin play from Arizona, California, Connecticut, Delaware, Idaho, Indiana, Louisiana, Maine, Michigan, Montana, Nevada, New Jersey, New York, Oklahoma, Tennessee, Washington and West Virginia, which the terms call "GC Only States." Everywhere else in the United States, the full product is open.

That list was drawn by the company, not by a regulator. Operators in this market tend to withdraw from the states whose laws are least comfortable for them, so where a company has chosen not to offer its prize currency is often a better guide to the legal risk it sees than anything in its marketing.

Why this matters legally

Under most state laws, gambling has three parts: a prize, decided by chance, in exchange for something the player paid to enter. Sweepstakes casinos are built to remove the third part. Because a free way to get the prize currency exists, the argument goes, nobody paid for the chance to win.

The question this investigation asks is whether that holds up when players fund a cash wallet, spend it on coins and boxes, play casino-style games, and withdraw cash back out. If players paid for their chance to win something of value, that looks like online casino gambling, offered in states where it is not licensed.

Many states let a person recover money they lost to gambling that was not licensed where they live. Some allow recovery of the full amount, and some allow more. Separately, state consumer protection laws reach a business that tells customers a product is lawful when it may not be. Which of these applies depends on the state you played from.

Who may qualify, and what Maginnis Howard is doing

Modo is not a historical case. Its site is live, and it rewrote its Terms of Use as recently as October 1, 2026.

You may qualify if you bought Gold Coins or added money to your Modo wallet, played, and lost more than you got back, in a state where this kind of online casino gambling is not licensed. Helpful records include:

  • Your purchase and wallet history on the Modo account.
  • Card or bank statements showing the charges. These often matter most, because they sit outside the platform.
  • Your withdrawal and redemption records, since net loss is the usual measure.
  • The state you played from.

You do not need complete records to talk to us. There is no cost to have your situation reviewed, and no fee unless we recover money for you.

The legal basis

Why this may be illegal

Modo sells Gold Coins for real money, runs casino-style games of chance with a second currency called Sweepstakes Coins, and lets players load dollars into a wallet and withdraw them. Players say that is online casino gambling, offered under a sweepstakes label in states that never licensed it. Many states let a person recover money they lost to gambling that was not authorized where they live, and state consumer protection laws reach a business that sells an unlawful service as a lawful one. Maginnis Howard is investigating how Modo sells its coins and what players have lost on them.

The law

Many states allow a person to recover money they lost to gambling that was never licensed or authorized in their state. Separately, state consumer protection laws reach a business that markets a service as lawful when it is not. Whether a claim is available, and what can be recovered, depends on the state where the player lives — some states allow recovery of the full amount lost, and some allow more.

What you could recover

Depending on the state where you live, you may be able to recover the money you lost — in some states the full amount, and in some states more than that. State consumer protection laws may add damages set by law, and can require the company to return money it took unlawfully, pay attorney fees, and change how it operates.

How your claim would be handled

Claims like this are handled as individual arbitration cases — private proceedings, no courtroom. For ARB Gaming LLC (Modo Casino), cases are typically administered through JAMS.

What You Paid In* vs. What You Got Back Out*

What You Paid In* (Modo Casino virtual-coin purchases · one illustrative player over about a year, in a state that does not license online casino gambling) $2400.00
What You Got Back Out* (The gap is your loss — and a number of states let a player recover money lost to unlicensed online gambling) $400.00

Figures shown are illustrative examples, not records of an actual transaction; your amounts may differ.

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Frequently asked questions

What is this investigation about?

Modo sells Gold Coins for real money, runs casino-style games with a second currency called Sweepstakes Coins, and lets players load and withdraw dollars through a wallet. We are investigating whether that is unlicensed online casino gambling in states that never authorized it, and whether the way it is marketed misleads players about its legality.

Modo says no purchase is necessary. Does that matter?

The free route does not by itself settle the question. What matters for your claim is whether you actually put real money in and lost it. If you bought Gold Coins or added money to your wallet, you should have your situation reviewed.

Does it matter which state I live in?

Yes, and it is the single biggest factor. These claims are brought under state law, and the states differ on whether a player can recover gambling losses and on how much. We confirm your state with you when we review your claim, and tell you where you stand.

How is my claim filed?

These claims are filed as individual arbitrations. Your claim is pursued in your own name rather than folded into a group case. We handle the filing and the paperwork for you.

I do not have records of what I spent. Can I still sign up?

Yes. Give us your best estimate and the email address on your account. Your card or bank statements will show the charges, and purchase history is something we can work on obtaining as the claim develops.

What does this cost me?

Nothing upfront. We are paid a percentage only if we recover money for you.

What clients say

The entire process with Maginnis Howard was effortless. All our communication was by email and only a few phone calls. Any calls or emails were answered very promptly. I would like to thank Ian and Maginnis Howard. I will highly recommend any dispute that includes an Arbitration Agreement, there could no be a better Firm to represent you!
— Daniel B.
Ian is an excellent communicator who knows how to work with these companies to obtain a resolution and get you the best settlement offer possible. I highly recommend Ian and the Maginnis Howard law firm for anyone navigating the arbitration process.
— Cheille H.
I'm very grateful for his representation and the result we achieved. If you're facing arbitration and feel overwhelmed or unsure of your rights, I highly recommend Ian Vance and Maginnis Howard. They know how to handle these cases and fight for their clients.
— Ryan Z.

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