Trevor Martin and Thomas Cassell built large followings promoting content related to a popular video game, and used that platform to endorse an online gambling site called CSGO Lotto to their audiences. According to the Federal Trade Commission, what they did not tell their followers was that they owned the company behind the site they were promoting.DOCUMENTED
The FTC's complaint further alleged that Martin and Cassell paid other online influencers to endorse the platform as well, without requiring those influencers to properly disclose that they had been paid to promote it — compounding a single undisclosed material connection into a wider network of endorsements that appeared, to ordinary viewers, to be independent and unpaid.DOCUMENTED
- Trevor Martin and Thomas Cassell promoted the online gambling site CSGO Lotto to their respective audiences.
- The FTC alleged neither disclosed that they owned the company operating CSGO Lotto.
- The complaint further alleged the two paid other influencers to promote the platform without requiring proper disclosure of the payment relationship.
- The FTC's complaint alleged the promotions misled ordinary consumers into believing the endorsements were independent opinions.
- The settlement order requires Martin and Cassell to clearly disclose any material connections in future influencer marketing.
- The case is frequently cited as a foundational example in FTC guidance on influencer endorsement disclosure requirements.
What the complaint alleges
The FTC's Endorsement Guides require that any “material connection” between an endorser and the product or brand being endorsed — a financial, ownership, employment, or personal relationship — be clearly and conspicuously disclosed, so that an audience can properly weigh the credibility of an endorsement against the endorser's actual stake in the outcome.REVIEWED Ownership of the very company behind a product is about as direct a material connection as exists, and the complaint against Martin and Cassell alleges that connection was never disclosed to the audiences watching their promotional content for CSGO Lotto.DOCUMENTED
The complaint's allegation regarding paid third-party influencers adds a second layer to the deception: rather than relying solely on their own undisclosed ownership stake, Martin and Cassell allegedly extended the same pattern outward by paying other creators to promote the platform, again without ensuring those creators disclosed the payment relationship to their own audiences.DOCUMENTED That structure meant a viewer could encounter the same undisclosed promotional pitch from multiple, seemingly independent sources, reinforcing a false impression of broad, organic enthusiasm for the platform rather than a coordinated and compensated promotional campaign.
Why gambling-adjacent products draw particular scrutiny
Online gambling and gambling-adjacent products, including the “skin gambling” and loot-box-adjacent platforms popular within gaming communities during this period, drew heightened regulatory attention in part because their core audience skewed toward younger viewers who may have limited experience evaluating financial risk and limited awareness of endorsement disclosure norms generally.REVIEWED An undisclosed ownership stake in a gambling platform being promoted to that audience compounds the underlying disclosure violation with the additional concern of steering a comparatively vulnerable audience toward a product from which the endorsers stood to profit directly.
Why disclosure rules apply even to "just an opinion"
A common misconception among online creators is that a genuine, honestly held opinion about a product does not require a material-connection disclosure as long as the recommendation itself is sincere; the FTC's guidance rejects that framing directly, since the disclosure requirement exists to let the audience factor in the endorser's financial stake regardless of whether the endorser's stated opinion happens to be genuine.REVIEWED An owner of a gambling platform recommending that platform to followers may well believe every word of the endorsement, but the audience has no way to independently discount that opinion for the endorser's direct financial interest unless the ownership stake is disclosed alongside it.
Terms of the settlement
Under the settlement order, Martin and Cassell are required to clearly disclose any material connections — financial, ownership, employment, or personal — in any future influencer marketing campaigns they participate in.DOCUMENTED The order effectively puts the two individuals under an ongoing disclosure obligation for future endorsement activity, rather than simply resolving the specific CSGO Lotto promotions retroactively.REVIEWED
The influencers promoting the gambling site to their audiences didn't just fail to disclose their ownership stake — they allegedly paid other creators to make the same undisclosed pitch.
Why the case matters
The CSGO Lotto case has become a frequently cited reference point in FTC guidance materials on influencer disclosure precisely because its facts are so clear-cut: undisclosed ownership of the very product being endorsed, compounded by a network of paid endorsers who also failed to disclose their compensation. For any creator or brand engaged in influencer marketing today, the case remains a foundational illustration of exactly the kind of material connection the FTC's Endorsement Guides are designed to force into the open.
How the case shaped later platform-level disclosure tools
In the years following the CSGO Lotto settlement, major social platforms introduced built-in disclosure features, such as branded-content tags and paid-partnership labels, designed to make compliance with endorsement disclosure requirements easier for creators to implement consistently.REVIEWED Those platform tools address one specific gap the CSGO Lotto case exposed — that disclosure, left entirely to an individual creator's own initiative and judgment, is easy to omit either through deliberate choice or simple carelessness — though the underlying legal obligation to disclose material connections rests with the endorser regardless of whether a given platform's built-in tools are actually used.
Why ownership disclosure is treated more strictly than paid promotion
Regulators and legal commentators have generally distinguished between a simple paid-promotion disclosure, which discloses that money changed hands for a specific post, and an ownership disclosure, which reveals an endorser has an ongoing financial stake in every dollar the endorsed business generates regardless of the specific post in question.REVIEWED That distinction matters because an owner's incentive to mislead an audience persists continuously, not just for the duration of a single sponsored post, making undisclosed ownership arguably a more serious material connection than a one-time paid partnership — a hierarchy of severity the CSGO Lotto case, with its ownership-level nondisclosure, sits squarely at the more serious end of.
Sources behind this report
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