Reasoned Legal Opinion for Meta Gambling and Gaming Ad Authorization
Meta requires written permission before online gambling and real-money gaming ads run. If your product is not itself a licensed operator, the application commonly asks for legal documentation covering each state you target. I write that document as a signed, reasoned legal opinion addressed to your company, naming Meta as a party permitted to rely on it for its authorization review.
| Scope | Fixed fee |
|---|
| One state | $2,500 |
| Four states | $5,000 |
| Each additional state beyond four | $1,000 |
| All 50 states | $15,000 |
The fee is fixed and agreed in writing before work begins. If you start with the $300 Written Attorney Consultation, the $300 is credited in full toward the opinion within 30 days.
Who this is for
- Affiliates and marketers paid by sportsbooks, casinos or fantasy operators (flat fee, CPA, revenue share or hybrid).
- Picks, analytics, odds-comparison and expected-value subscription products that link to operators.
- Daily fantasy, pick'em and contest products, including prize and pooled-entry features.
- Sweepstakes, social-casino and skill-gaming products that want to advertise on Meta.
- Licensed operators that still need a state-by-state matrix for a specific campaign.
What you receive
- A signed, reasoned legal opinion (PDF) addressed to your company, with Meta Platforms, Inc. named as a party permitted to rely on it solely for its gambling-ad authorization review.
- A state-by-state analysis of how your product is characterized under each target state's gaming, sports-wagering, fantasy and sweepstakes rules: operator, affiliate or vendor, or information service, and what licensing, registration or disclosure that characterization triggers.
- Where compensation structure matters (affiliate and vendor registration regimes that turn on revenue share, per-registration or per-depositor payments), the opinion addresses your actual arrangement.
- A limited federal overlay (Wire Act, UIGEA, Illegal Gambling Business Act) to the extent needed to support the state conclusions.
- The conditions, assumptions and exclusions stated in the opinion itself, so the reader knows exactly what the conclusions rest on.
- Two revision rounds, and a written amendment path if you add states later ($1,000 per state).
Why the state-law analysis cannot be removed
Buyers sometimes ask for "just the opinion for Meta, not a licensing analysis." They are the same document: the signed conclusion Meta asks to see is a conclusion about how each state's gaming, wagering, fantasy or sweepstakes rules treat your product, so an opinion that skips that analysis is not an opinion anyone can rely on. What varies, and what the fee follows, is how many states it covers.
What the opinion does not do
It does not promise a predetermined conclusion. The engagement buys independent legal analysis and a signed opinion stating the conclusions the verified facts and applicable law support, with whatever conditions and qualifications are necessary. If the facts do not support a favorable conclusion in a state, the opinion says so. That is what makes it worth relying on.
What I need from you: the factual certificate
The opinion rests on facts you certify in writing. Before drafting I ask for:
- Operator relationships and compensation. Every direct or indirect payment from every sportsbook, casino or fantasy operator: flat sponsorship, CPA, per-depositor, revenue share, or a mix.
- What the product actually does. Whether it only displays information, or also accepts or transmits entries, routes wagers, pre-populates bet slips, deep-links into particular selections, executes transactions or manages accounts.
- Every linked operator and its status in each target state (license, permit or registration), which I check against current official regulator sources.
- Any contest, prize, pooled-entry or managed-account feature.
- The ads and landing pages you plan to run, so the factual presentation in the opinion matches what users see.
- Age gating and geographic targeting: age controls, state targeting, geolocation or exclusion mechanisms, and whether the product is available nationwide.
- Subscription terms and user flow: current terms, pricing, cancellation, account flow, disclaimers, and any language about wagering or expected winnings.
Jurisdiction and reliance, stated plainly
I am admitted in California and Washington. Opinions on other states are prepared as limited multijurisdictional work under those states' temporary-practice rules and are expressly qualified that way in the opinion. Where a state's rules or Meta's instructions call for locally admitted counsel, I tell you before you pay and scope local-counsel review separately. I review Meta's exact request before scoping, because the required form of the document varies.
Not included
- License, permit or vendor-registration applications and regulator correspondence (scoped separately when needed).
- Representation before Meta or any platform, negotiations, litigation or arbitration.
- Factual investigation beyond verifying your certificate against official sources.
- An unlimited review of creatives; the review covers the ads and landing pages you submit with the certificate.
How the engagement runs
You email the four items in the button above (or ask the AI Legal Analyst on this page). I confirm the scope, the states and the fixed fee in writing with a short engagement letter and the factual certificate to sign. Work starts when the signed letter and payment are in. A one-state opinion is typically delivered within two business days of the signed certificate and complete materials; multi-state opinions get a written delivery date in the engagement letter. I prepare the opinion using AI-assisted research and drafting tools, review it before delivery, and remain responsible for its content.
Frequently asked questions
Does Meta require a legal opinion for gambling or gaming ads?
Meta requires written permission before online gambling and real-money gaming ads run. Licensed operators usually submit their license. Products that are not licensed operators, such as affiliates, picks and analytics subscriptions, fantasy, sweepstakes and skill games, are commonly asked for legal documentation covering each state they target. I review Meta's exact request before scoping, because the required form varies.
Can you guarantee that the opinion will say my product is lawful?
No. The engagement buys independent legal analysis and a signed opinion stating the conclusions the verified facts and applicable law support, with whatever conditions and qualifications are necessary. If the facts do not support a favorable conclusion in a state, the opinion says so.
What if an operator pays me a revenue share?
Compensation structure is often the fact that decides whether a state treats you as a registrable affiliate or vendor rather than an information service. The opinion addresses your actual arrangement, which is why the certificate asks for every payment stream.
How many states do I need, and can you cover all 50?
The ladder is priced per state covered: one state $2,500, four states $5,000, each added state $1,000, all 50 states $15,000 with a state-by-state schedule of conclusions and conditions. Which states must be covered is set by Meta's request and by where you advertise, not by the ladder. I read Meta's exact request before scoping, so you pay for the states the authorization actually turns on.
How long does it take?
A one-state opinion is typically delivered within two business days of the signed factual certificate and complete materials. Multi-state opinions get a written delivery date in the engagement letter. Two revision rounds are included.
Is a $300 written consultation a sensible first step?
Yes, if you are not sure which states to target or whether your product needs an opinion at all. You send the facts and Meta's request, and you get a written answer with the issues, risks and the exact next step. The $300 is credited in full toward the opinion within 30 days.
Related
Sergei Tokmakov, Esq. · California Bar #279869 · Washington State Bar #65720 · licensed since 2011.
This page describes my services. It is not legal advice and does not create an attorney-client relationship; an engagement starts with a signed engagement letter.