Keep three approvals separate: permission, observed availability and legal suitability. A successful launch answers only a bounded technical question.
| Question | Evidence owner | What constitutes useful evidence | What does not answer it |
|---|---|---|---|
| May this publisher serve this game to this audience? | Supplier and buyer’s legal reviewer | Controlling licence, schedules and explicit clarifications | A working iframe or general corporate licence |
| Does it work in the required environment? | Engineering/QA | Timestamped results from authorised locations and devices | A global catalogue count |
| Are the page, promotions and data flows appropriate? | Legal/privacy/product | Review of audience, destination operators, disclosures and actual processing | The absence of a real-money stake inside the demo |
What US-specific issues belong in the comparison?
- Linked wagering destinations: New Jersey’s regulator publishes its authorised internet gaming sites. Use the relevant state’s official information when reviewing destination operators; a demo-content supplier’s approval is not a substitute. (njoag.gov)
- Affiliate relationships: a New Jersey DGE letter dated 9 September 2024 required platform-provider certification concerning affiliate partners, with annual submissions thereafter. This is evidence that affiliate conduct can matter to regulated counterparties—not a nationwide rule for all demo publishers. (nj.gov)
- Commercial disclosures: FTC guidance says affiliate relationships should be disclosed clearly and conspicuously where relevant to endorsements. Review the surrounding review page and calls to action, not only the game frame. (ftc.gov)
- Privacy choices: for businesses subject to the CCPA, California guidance describes opt-out rights for sale or sharing, including Global Privacy Control. Assess the supplier’s processing and the publisher’s implementation rather than assuming an iframe isolates the obligation. (oag.ca.gov)
- Children’s information: COPPA analysis depends on factors including child-directed services and actual knowledge of under-13 users. FTC guidance discusses third-party collection as well as site-operator responsibilities; a generic adult-content notice does not replace that assessment. (ftc.gov)
This is a risk-screening framework, not a legal opinion or a complete state-by-state assessment. Ask counsel to classify the actual product, audience, promotions and data flows before launch.