New York v. Valve Corporation - Loot Boxes and Gambling

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW Y ORK ------------- ------------- ------------ ------------- ------------ ----- X THE PEOPLE OF THE STATE OF NEW YORK, by Letitia James, Attorn ey General o f the State of New York, Plaintiff, COMPLAINT -against- Index No. IAS Part VALVE CORPORATI ON, Defendant. ------------- ------------- ------------ ------------- ------------ ----- X Of Counsel: CHRIS D’ANGEL O Chief Deputy for Economic Justice KIM BERGER Bureau Chief, Bureau of Internet and Technology CLARK RUSSELL Deputy Bureau Chief, Bureau of Internet and Technology JORDAN ADLER Senior Enforcement Counsel, Bureau of Internet and Technology MARC E. MONTGO MERY ALEXANDRA HIAT T Assistant Attorneys General, Bureau of Internet and Technology 28 Liberty St. New York, NY 10005 (212) 416-8433 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 1 of 52

i TABLE OF CONTE NTS NATURE OF THE ACT ION..........................................................................................................1 PARTIES AND J URISDICTI ON...................................................................................................3 FACTUAL ALLEGATI ONS..........................................................................................................4 I. New York Closely Regul ates Gambling...............................................................................4 II. Valve Is a Highly Successful Video Game Developer and Distributor................................5 A. Valve develops the Steam platform and emerges as the leading distributor of PC desktop games...............................................................................................................5 B. Valve develops its flagship video game franchises.......................................................7 III. Valve Monetizes Its Mos t Popular Games by Selling C hances to Win Virtual Items Through Loot Boxes.............................................................................................................8 A. Valve introduces loot boxes..........................................................................................8 B. Valve’s loot boxes opera te similarly across its fla gship games..................................10 i. Counter- Strike loot boxes requi re users to purchase “keys ” from Valve that function similarly to virtual coins or tokens used in online casinos.................... 10 ii. Loot boxes in Team Fortress 2 and Dota 2 employ the same operational principles as Counter - Strike weapons cases........................................................ 17 IV. Valve’s Virtual Items Ha ve Value......................................................................................20 A. Valve designed and built its games and platform to enable users to sell the virtual items they have won...................................................................................................20 i. Valve enables users to sell virtual items throu gh the Steam C ommunity Market.................................................................................................................. 20 ii. Valve designed Steam to enable buying and selling virtual items on third -party marketplace s........................................................................................................ 22 iii. Valve h as consistent ly fostered t hird - party marketplace s that allow the purchase and sale of vir tual items........................................................................ 25 B. High market values and easy liquidation have made Valve virtual item s attractive targets for th ieves........................................................................................................28 V. Users Open Valve’s Loot Bo xes to Gamble.......................................................................30 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 2 of 52

ii VI. Valve’s Loot Boxes Pose the Sam e Dangers as Casino Gam bling, Especially for Children..............................................................................................................................36 A. Valve’s loot boxes use t he same mechanics and psy chological lures as tradit ional casino games...............................................................................................................36 B. Valve’s loot boxes can lead to addiction and result in rea l harm................................38 C. The risks associated with Valve’s loot boxes are particularly heightened for children and adolescents.............................................................................................39 D. Teenagers and child ren comprise a significant se gment of Valve’s users..................42 CAUSE S OF ACTIO N..................................................................................................................43 PRAYER FOR RELI EF................................................................................................................47 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 3 of 52

1 NATURE OF THE ACTI ON 1. Plaintiff, the People of th e State of New Y ork, by Attorney General Letitia James (“OAG ”), brings this action pursuant to Executive Law § 63(12) to remedy unlawful conduct by Valve Corporation (“Valve” or “Defendant”). 2. Valve has developed and published several long-running video game franchises t hat have achieved widespread influence in th e gaming world. The se franch ises —Counter- Strike, T eam Fortress, and Dota —have been incredibly popular, attracting hundreds of millions of players over the course of two and a half decades. 3. The franchises also have proven to be remarkab ly lucrative for Valve, even though the games have been free to play for years. Valve has managed this feat by pioneering an alternativ e model for monetizing its games: gambling. 4. In Valve’s games, gambling takes the form of a v irtual container known as a loot box. Loot boxes are not p art of regular game ac tivity but are ancillary attraction s that users can engage in when they are not playing the game. 5. For most loot boxes, Valve charges users for a key t hat “opens ” the loot box and awards the user one of several dozen virtual item s. The v irtual items have no impact on gameplay. Instead, they are used to decorate users’ weapons and characters as a display of status and affluence to other game players. Despite having no in - game functionality, the se virtual items can be extremely valu able, with the rarest items worth thousands of dollars. 6. This last point— the monetary value of the virtual ite ms — has been a critical factor in Valve’s success. And it is the result of delib erate decisions Valve made — in the design of its loot boxes, the virtual items they contain, and the platform on which they are bought and sold— to n ot only drive demand for virtual items, but also to e nsure th ose items have value. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 4 of 52

2 7. First, unlike many other video game developers, Valve enables users to sell the virtual items they have wo n, ei ther through its own virtual mark etplace, the St eam Community Market, or through third - party marketplace s. Virtual items that are bought and sold through these marketplace s have monetary value. Indeed, the market for v irtual items for the Cou nter - Strike franchise alone has been estimated to be in the bi llions of dollars, an unparalleled sum in t he vi deo game industry. 8. Second, Valve has made some items far harder to win than others, awarding them on ly infrequently when a loot box is opened. Valv e makes it readily apparen t to users which are which, grouping items together into various tiers based on the likelihood they will be awarded. For example, in Valve’s Counter- Strike gam es, the rarest and most pr ized items are design ated “Exceedingly Rare Spec ial Item s” and marked with a gold badge. The demand, and price, for a particular i tem directly re late s to its rarity. 9. Nearly every user who buys a key and opens a loot box receives a virtual item that is commonplace and worth only pennies— far less than wh at they s pent to open the loot box. Anyone who actually want ed such an item could obtain i t far more cheap ly — again, for pennies — by simply purchasing it through a marketplace. Most people, there fore, purchase a key and open a loot box for the same reason peop le play the lott ery or a slot machine —the poten tial of winning a large prize. 10. This loot box model that Valve has developed — charging a n individual for a chance to win something of value based on luck alone — is quintessential gambling, prohibited under New York’s Constitution and Penal Law. 11. In Valve’s most popular game, opening a loot box even resembles a virtual slot machine: a wheel cycles through potential items before stopping on one. And like a slot machine, the CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 5 of 52

3 spinning wheel conveys the illusion of a “near miss” when it appears to stop close to, but not on, a valuable item. 12. Loot boxes, like other forms of gambling, ca n lead to addiction and result in real harm. But Valve’s loot boxes are particularly perniciou s because they are popular among children and adolescents, who are lured into opening loot boxes by the prospect of winning expensive virtual items that c onvey statu s in the gaming world. Resear ch has shown that children who are introduced to gambling are at a significantly higher risk of developing gambling addictions later in life. 13. Valve has made tens of millions o f dollars sell ing keys t o thousands of New York residents, who have used t hem to open Valve loot boxes in the hope s of winning valuable virtual item s. And Valve has made m illions of dollars more in co mmissions from New Yorkers who sold virtual items obtained from loot boxes. 14. As describe d further bel ow, Valve’s a ction s violate Article I, Section 9 of the New York Constitution, and Sections 220.05 and 220.10 of New York’s Penal Law. PARTIES AND J URISDICTION 15. Plaintiff is the People of the S tate of New York, by L etitia James, Atto rney General o f the State of New York. 16. Defendant Valve Corp oration is a Washington c orporation headquartered at 10 4 00 NE 4th St., Suite 1400, Bellevue, Washington 98004. The company has d eveloped and published numerous video games, including Counter - Strike: Global Offensive, Counter - Strike 2, Dota 2, and Team Fortress 2. The co mpany also operates Steam, an onl ine gaming platform. 17. Defendant has transacted business in New York and contracted to supply goods and services in New York. It has offered and p rovided consumers in New York with online accounts CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 6 of 52

4 through the Steam platform, offered and sold video games and gaming equipment to consumers in New York, offered and sold virtual items to consumers in New Y ork, and enabled consumers in New York to wag er on and win virtual items through loot boxes. 18. This Court has jurisdiction pursuant to Executive Law § 63(12), which em powers the Attorney General to seek injunctive relief, restitution, damages, disgorgement, and other equitable relief when any person or business h a s engaged in repeated fraudulent or illeg al acts or otherwise demonstrated persisten t fraud or illeg ality in the carrying on, conducting, or t ransaction of business. 19. The parties entered in to a series of tolling agre ements that tolled the applicable statute s of limitations b eginning April 5, 2023 and ending February 6, 2026. FACT UAL ALLEGAT IONS I. New York Closely Regulates Gambling 20. Gambling is illegal in New York with certain limited excep tions. 21. Most forms of gambling are expressly prohibited by the New York State Constitution, which states that “no lottery or the sale of lottery tickets, pool - selling, book - making, or any other kind of gam bling … shall [] be auth orized or all owed within this state.” N.Y. Const. art I, § 9. This “provision largely dat[es] back to 1894.” White v. Cuomo, 38 N.Y.3d 209, 217 (2022). Th e “broad [constitutional ] prohibition” against gambling is subject to certain “limited” e xceptions, Dalton v. Pataki, 5 N.Y.3d 243, 254 (2005), none of which are relevant here. 22. New York’s Penal Law similarly has long recognized crimes for promoting gambling activity. Penal Law §§ 225.05, 225.10. A bu siness that knowingly advances or profits f rom unlawful gamb ling activity violate s these laws. Id. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 7 of 52

5 23. G ambling is broadly defined under New York law. A person “engages in gambling when he stakes or risks something of value upon the outcome of a contest of chance or a future contingent event not under his control or influence, upon an agreement or understanding that he will receive something of value in the event of a certain outcome.” Penal Law § 225.00(2). II. Valve Is a Highly Successful Video Game Developer a nd Distribu tor A. Valve develops the Steam p latform and e merge s as t he l eading d istributor of PC d esktop games 24. Valve was founded in 1996 as a developer and publisher of video games. The company achieved early success with the re lease of several PC desktop g am e s, which were sold through brick -and- mortar stores. 25. In 2003, Valve launched the Steam p latform, which enabled consumers, i ncluding New York residents, to directly purchase and download Valve games. Valve later expanded th e Steam platform to allow fo r the distribution and sale of PC d esktop games published by othe r companies. Valve collects a 30% commission on the sale of most third - p arty games sold through Steam. 26. Steam has grown to become the do minant platf orm for gamers to purchase, maintain, a nd play PC desktop games. As of 2024, industry analysts estimated that Steam co mmanded a 74 % market share for the dist ribution of PC desktop games. As of January 202 6, Steam was estimated to have 132 million monthly active users and 69 million daily users. In the United St ates, more than 146,000 games are available on t he Steam platform, with Valve adding thousands more each month. 27. In 2015, Valve introduced its first hardware offering w ith a gami ng console called the Steam M achine. That product was discontinued in 2018 but one year later, in 2019, Valve began selling a VR headset, called the Valve Index. In 2022, Valve added a handheld gaming console, CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 8 of 52

6 called the Steam Deck, to the hardware products available for purchase on Steam. V alve is slate d to release addition al hardware offerings in 2026. 28. Users in the United States, including New Yorkers, can purcha se the games and hardware available through Steam with a credit card, PayPal, or funds store d in a digita l wallet, ca lled the Steam Wallet. Figure A 29. Users can fund their Ste am Wallet in several ways, including w ith a credit card or with a digital or ph ysical Steam gift ca rd. Steam gift cards can be purchased at retail stores lik e Best Buy with any payment method accepted by the vendor, including cash. Ever y dollar a user deposits in their Steam Wallet results in a dol lar increase to the user’s Ste am Wallet balance, and can be used to purchase a dollar in goods on the Steam platform. 30. Steam Wallet funds can also be used to pur chase virtua l items from o ther Steam u sers on the Steam Community Ma rket, to buy loot boxes or loot box keys from Valve, or to make in - game purchases. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 9 of 52

7 B. Valve develops i ts f lagship v ideo game f ranchise s 31. As Valve emerged as a dominant player in t he field of PC desktop gam es, it continued to develop successful vid eo game franchises. To date, Valve’s three most popular video game franchises are Counter-Strike, Team Fortres s, and Dota. 32. The Counter- Strike franchise consists of a series of realistic multip layer first - person shooter game s that divide players into two tea ms, t errorists and counter - terroris ts. Va lve launched its first standalone game in the series in 2000. The franchise experienced explosive growth in popularity with a version Valve introduced in 2012 called Counter - Strike: Glob al Offensive (“CS:GO”). CS:GO was succeeded by Counter-S trike 2 (“CS 2 ”) in 2023. 33. Team Fortress 2 is a multiplayer first - person shooter game with a cartoon aesthetic, developed and published by Valve in 2007. 34. Dota 2 is a multiplayer fantasy -themed battle game that Valve introduced in 2013. 35. Hundreds of millions of people hav e played these games since their rele ase. As of mid - 2025, CS 2 was estimated to have 24 millio n monthly active players, with around 1.8 million people playing the game concurrently during peak peri ods. And a lthough Team Fortress 2 and Dota 2 have been available for years, they have been periodically revamped and updated with new features and remain popular today, with hundreds of thousa nds of active users during peak times. 36. All three Valve franchises are popular events in esports c ompetitions, 1 many of which are sponsored by Valve. A s an espor ts event, Counter- Strike has grown to the point where it has spawned academy teams, similar to those in prem ier soccer leagues, where up -and- coming players compete and develop their skills. 1 Esports, short f or elect ronic s ports, ref ers to the organi zed com petitive playi ng of vi deo game s, where i ndividuals or teams often engage in struct ured tour naments and lea gues. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 10 of 52

8 37. The franchises also have given ri se to thousands of content cre ators who strea m themselves playing the games and post game - related content on online platforms such as YouTube and Twitch. III. Valve Monetizes It s Most Popular Games by Selling Chances t o Win Vi rtual Items Through Loot Boxes A. Valve i ntroduces loot boxes 38. For many years, Valv e’s primary source of reven ue was the sale of video games. See king a new way to monetiz e its most popular gam es, Valve introd uced cosmetic v irtual items into its flagship games. Depending on the game, the virtual items can be pieces of apparel, like a hat for a player’s ch aracter, or artis tic overlays for a player’s weapon s. These virtual items ha ve no impact on gameplay and are instead intended to be status symbols or luxury items. 39. When Valve first releas ed Team Fortress 2 on Steam in 2011, it made some of these virtual items avail able for dire ct purchase on its Stea m platform. Wi thin two y ears of that r elease, however, Valve developed a more lucrat ive method for distributing the virtual items — selling users a chance to win the m through a virtual container known as a loot box. Valve soon adopted th is model for Dota 2 and Counter- Strik e as well. 40. Under this mod el, Valve distrib utes loot box es to users for free through “drops.” By engaging in a certain amount of activity in a particular game over the course of a week, a user can earn a “drop” or “care p ackage” that often includes a loo t box. A user can keep the loot box in their inventory, sell it on the Steam Community M arket, or “open” it. 41. To open most of these loot boxes, users must purchase a key from V alve. U sers can then use that key to “unlock” a loot box a nd win a randomly selected v irtual item. Key purchases and loot box openings can only take place outside of gameplay. 2 2 A user can bu y keys a nd open c ases whe n no active ga me is r unning o r they can use a n “ove rlay” fea ture that allows the game to run i n the ba ckground while t he user purchase s a key or opens a case. In either situation, the case - opening activity is unrelated to the game activity. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 11 of 52

9 42. The chance of a user winning a part icular virtual item is based on odds set by Valve. To create demand, Valve awards certai n types of items in only a very small percentag e of loot box openings. Rare ite ms are worth far more on the Steam C ommunity Market an d third - party marketplace s, in some cases thousands of dollars, than the more commonly awarded items. 43. This system, which is highly profitable for Valve, generates revenue streams in two ways. First, Valve charges for the keys that are required to open the loot boxe s — currently, $2.49 plus applicable sales tax ($0.2 2 in New York) for most keys. 3 Second, Valve collects a 15% commission when virtual items f rom its games a re sold on the Steam Community Market. 44. Valve has sold billions of dollars’ worth of Count er - Strike keys alone, including tens of millions of d ollars in sales to New York residents. In addition, Valve has generated tens of millions of dollars in fe es from the sale of virtual it ems through th e Steam Commu nity Market, inc luding millions of d ollars from s ales by residents of New York. 45. Valve’s revenue from loot boxes depends on users placing monetary value on the virtual items they can win by opening a loot box and the existence of a robust market where the virtual items can be bought and sold. If some of these items are sufficiently va luable, users will be w illing to spend the money for a chance at winning them by opening a loot box. 46. To create virtual items that genera te value and drive the Steam economy, Valve w orks closely with the community of players of the respective games, holding artist workshops where creators can earn money for de signs of virtua l items tha t are adopted by Valve. As Valve continue s to refine its mon etization strat egy, it monitor s the health of the economy it has created by keeping 3 Some loot boxes in Dota 2 and Team Fortress 2 do not require keys, but t he user s till mus t pay Val ve $2.49, plus tax, in o rder to open the loot b ox. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 12 of 52

10 close tabs on the markets for its virtual items, both on the Steam Community Market and on third - party marketplaces. 47. In 2014, a technical artist at Valve noted that a thriving mark et for Valve’s vir tual items requires a free marke t where users are “going to purchase thi ngs that they feel are being sold for a fair price and with enough listings, the downward price pressure of the free market is going to ensure that fair price gets found” — as occurs with the markets for stocks and other digital asse ts. The employee further ex plained that the listings for these items were in “ real currency amoun ts.” B. Valve’s l oot boxes op erate s imil arly a cross i ts f lagship g am es 48. Valve enables individuals to purchase keys and open loot boxes using a Steam account. Individuals create an ac count by co mpleting an online form, available o n the Stea m website and through a Steam software application. The form requires that the individu al enter their ema il address, a Steam account name, and a password. H undreds of thousands of N ew York residents have created and used St eam accounts. i. Counter- Strike loot boxes require users to purchase “keys” from V alve th at function similarly to virtual coins or tokens used in online casinos 49. The Counter - Strike franchise has p roved to be the most fertile environ ment for Va lve’s loot box strategy. Valve has offered several types of loot boxes in the Counter - Strike games, the most popular of which i s the weapons case. W hen opened, weapons cases aw ard virtual items called “ skins, ” which are cosme tic overlays that can be appl ied to a user’s weapons. 50. While users are provided with a default set of guns and knives at the outset of Counter- Strike, they can apply skins to their weapons as symbol s of status and affluence. The following images show a C ounter- Strike AK - 47 rifle a s it is prov ided to all playe rs at the outs et of the game (i.e., without a skin) and the same AK -47 with a cosme tic skin applied. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 13 of 52

11 AK -47 without a skin AK -47 with a skin a pplied Figure B 51. Notably, skins provide no advantage or other impact on gameplay. The two AK -47s pictured above function identically when playing Counter - Str ike. 52. Over the years, Valve has periodically introduced new weapons ca ses and skins to spark user interest and demand. 53. To open a weapons case and win a skin, a user must purchase a key from Valve. This is reflected graphically by a padlock, which appears on every case. An example of a Count er - Strike weapons case (with the padlock c ircled) and key are shown in Figure C, below. Dreams & Nightmares Weapons Case Weapons Case Key Figure C 54. Once a user has obtained a case, ei ther through an in - game drop or by purc hasing it on the Steam Community Market, they can examine it to see the list of skins they might win if they e lect to purchase a key and open the case. This list o f items is re ferred to as th e drop list. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 14 of 52

12 Figure D 55. As shown in Figure D, each item in the drop list is co lor coded to represent one of five rarity tiers. To comply with Chinese law, Valve has released the odds of receiving Co unter- Strike case items from the d ifferent ra rity tiers: Mil - Spec (Blue): approximately 79.92%; Restricted (Purple): approximately 15.98%; Classified (P ink): a pproximately 3.2%; Covert (Red): approximately 0.64%; and Exceedingly Rare Special Item (Go ld): approximately 0.26 %. 56. As shown in Fi gure D, the identity of the “ Exceedingly Rare Special Item, ” c olor coded gold, is not discl osed. As describe d below, however, users can turn to other sou rces to identi fy the possible high-value items that may be won by opening a p articular weapo ns case. 57. In addition to a rarity tier, Valve randomly assigns each skin a “ floa t value,” whic h represent s the condition of the skin or how much wear is visible on it. Float values wit hin a certain CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 15 of 52

O O O INVENTDRY EVERYTHING EQUIPMENT Orsams & Nightmares Case MAC-10 DuaiBometas SS608 Iight Box Hideout Dezastre thlock MoveTo Storage lkilt Me)W sau Dri Community Mertet.,.... 13 range correspond to a “wear level.” The five wear levels, from least we ar to most, are: factory new, minimal w ear, field - tested, wel l - worn, and battle - sc arred. W ear level can have a significant impact on the market price of a skin, with the least amount of wear generally commanding the highest pric e for a particu lar skin. 58. To purchase a key that will enable a user to open a weapo ns case, a user navigates to their inventory of virtual items where the case, along with any other virtual items acquired by t hat user, will appear. Figure E 59. If the user hov ers their cursor over a case in their inve ntory, a pop- up menu appears that includes an option to “Unlock Container.” Figure F CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 16 of 52

Clos Unlock Container Unlock Dreams & Nightmares Case Activate Windc.. 14 60. If the user selects “Unl ock Container, ” they are presented w ith a screen displayin g thumbnails of the various skins that could be obtained from the selected case. A message at the bottom of the page informs the user that a key is required to open the case. Adjacent to the messag e is a green button with the price o f the key ($2.49 in the image below) that allows the user to purchase the key for the displayed price. For a user planning to engage in repeated case openings, there is a menu option that allows users to purchase mu ltiple keys in a single t ransaction. Figure G CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 17 of 52

C O UNTER-STRIKE 2 This game has requested authorization for the following transaction: QTY NAME PRICE 1 $2.49 Subtotal: $2.49 Ta x: $O.22 Total: $2.71 Steam offers rehmds lit B iniinEr oinihi Mbiaw mish been consumed. modified, or transferred. Authorize 15 61. If the user elects to purch ase a key by clicking the green button, they will be presen ted with a payment pag e where the y can complete the tra nsaction by pa ying with Steam Wal let funds. For New York residents, the total price of the key with tax is $2. 71. Figure H 62. If the user clicks the “Authorize” butto n to complete the purc hase, th e key will be added to the user’s inventory. 63. I f the user then repeats the process of inspecting the case from their inventory page and selects the “Unlock Container” option, as described above, they will again be shown the case details, but this time with a button at the bottom of the screen labeled “ Open to K eep.” 4 Clicking the button open s t he case us ing the purchased key. 4 Valve recently adde d an option to use keys to “rent” a weapons case for seven days. Un der this opti on, all items in the case except f or the exceed ingly rare spec ial items appear in t he user’s invento ry for se ven days and can be applied to their weapons during that time. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 18 of 52

Unlock Container Unlock Dreams & Nightmares Case 0 This Container can only be operied once IMPECTITEM S Activate Wince. INe Oreams & Nightmares Case Key GDSE 16 Figure I 64. Valve designed the experien ce of opening a case to appe ar similar to the spin of a sl ot machine. When a user clicks the button labeled “ Open to Keep,” an animation is displayed showing the unlocking and opening of the case, followed by a simulated spinning wheel with images of the various sk ins in the cas e’s drop list rotating acro ss the displa y. Like a slot machine, t he wheel sp ins rapidly a t first and then gradually slows. When the wheel finally stops, the skin that appears in the center of the display, denoted with a yellow vertical line, is added to the user’s Steam inventory. Figure J 65. As shown in Figure J, the spinning wheel may come to rest immediatel y next to the ic on for the rare and valuable item. This visual give s users the impression that they “almost” won the CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 19 of 52

17 valuable item, a design feature associated with slot machines know n as a “near miss. ” In reality, the item that the user is awarded is determined by a r andom number generator on Valve’s server after the user clicks th e button to open the case. 66. Opening loot boxes has become a subject of interest, d istinct from playin g Valve ’s games. A s discussed below, so me well - known stream ers have created videos and channels dedi cated solely to opening Counter- Strike weapons cases. ii. Loot boxes in Team Fortress 2 and Dota 2 employ the same operational principles as Counter - Strike w eapons cases 67. Valve has created a variety of loo t boxes in Team Fortress 2 and D ota 2. While some of the features of th ose loot boxes differ f rom the Counter -S trike weapons cases, they share the same operational princ iples, with users paying about $2.50 to open loot box es t o win rando mly selected virtual item s. In both Team Fortress 2 and Dota 2, Valve offers loot boxes that require keys to open, like the Counter - Strike weapons cases. In addition, Valve sells “key less” loot boxes, which eliminate the step of buying a key, in both of those games. 68. As with Counter -Strike, Valve controls the odds of winning each type o f virtual item from loot boxes in Team Fortress 2 and Dota 2, and some items are awarded far more frequently than others. 69. O ne of the earliest loot boxes in Tea m Fortress 2 was the Mann Co. Supply Crate. L ike the Counter- Strike weapons cases, the supp ly crate is displayed as a cont ainer secured with a padlock, indicating to a user that they must purchase a key if the y wish to open the loot box. Valv e sells keys for Mann Co. Supply Crates for the s ame price as Counter- Strike w eapons case keys, $2.49 plus tax. Unlike the keys in Counter - Strike, users can also buy keys for Team Fortres s 2 loot boxes from other us ers on the Steam Community Market. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 20 of 52

Team Fortress 2 Level 20 Supply Crate Killstreak Back Scatter Kit Killstreak Kritzkrieg Kit Killstreak Arnbassacor Kit or an Exceedingly Rare Series #3 Unusual Hat! 18 Figure K 70. As seen above, th e Mann Co. Supply C rates also have drop lists. A user that opens t he Series #84 Crate shown above could receive one of ni ne “Killstreak K its, ” whic h can be applied to a user’s weapon to add a sty lized counter that tracks the nu mber of kills mad e with the weapon. The user also has a small chance of winning a n “Exceed ingly Rare Series # 3 U nusual Hat. ” 71. When a user purchases and uses a key to open a supply crate, an animation appears sho wing the lock opening and the chai ns falling away. After that, the walls of the crate collap se revealing the virtual item the playe r has won, as shown in Figure L. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 21 of 52

KILLSTRCAK BACWE RNER KiT L Af.H TREA5URE CONTAINS1OF THESE ITEMS Q LUNA Madness of theAmaranthOvb ÀMPLARAS5ASSIN FacelessDestiny WEAVER VespoWStalker VPER Tell ChestofEndlessDays You willnotrocalvetlupl WITH A CHANCETORECEIVEBONUSITEMS WITCHDOCTOR ServantoftheSightlessShamans RARE HOODWINK Scoer9eoftheSkyrangers VERYRARE 0 FACH TREA$URF (n CAI INVOKER Han of Menace ULTRARARE 19 Figure L 72. In Dota 2, the most popular type of loot box is the treasure chest. As in Counter- Strik e, each treasure chest ha s a drop list of virtual ite ms the user may win when the chest is opened. Fo r example, the “Chest of E ndless Days, ” pictured in Figure M below, has a drop list (shown in Figure N) of ten items and three bonus items, the latter of w hich are designated “rare, ” “very rare, ” a nd “ultra rare,” respectively. Like a Counter- Strike weapons case, a user can purchase a key from Valve for $ 2.49 plus tax to open this loot box. 5 Figure M Figure N 5 As with Team Fort ress 2, loot box keys fr om Dota 2 can b e bought a nd sol d on the C ommunit y Marke t. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 22 of 52

20 73. When a user opens this loot box, all the virtual items in the drop list are displayed, as shown in Figure O, and begin to spin. One by one the i tems disappear until one item remains, wh ich is awarded to the user. Figure O 74. The virtual items in the T eam Fortress 2 and Dot a 2 loot boxes provide aesthetic customizatio n s for weapons and characters within the respective games. A s with Counter- Strike, no gameplay is required to open a loot box. IV. Valve’s Virtual Items Have Value A. Valve desig ned and built its game s and platform to enable users to sell the virtual items they have won 75. Valve designed and built its games a nd the Steam platform to enable use rs to sell the virtual items they have won. Users can do so in two ways: through the Community Market that Valve operates on the Steam platform, and through third- party marketplaces. i. Valve enables users to sell v irtual i tems through the Steam Community Market 76. Valve developed a mark etplace, the Steam Community Market, to enabl e users to buy and sell virtua l items. L isting an it em for sale thro ugh the Ste am Community Market is straightforw ard: th e user simply sele cts the item, sets a sa le price, and clic ks a button labeled “O k, put it up for sale.” The interface automatically calculates the fund s the user will receive afte r Valve collects its commi ssion from the sale. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 23 of 52

Put an item up for sale USP-S | Jawbreaker counter-strike 2 Classified Pistol Median Sale $8.30 $7.80 $7.30 Feb 7 Feb 8 13Feb 14 va s ell as.ss Buyer pays: s6 50 (includes fees) I agree to the terms of the Steam Subscriber Agreement ast updated Sep 26, 2024.) OK, put It up for sale 21 Figure P 77. Proceeds fro m the sale s of virtua l items are distribu ted as funds in the seller’s Steam Wallet. These funds have the equivalent purchasing power on the Steam platform as cash. They can be used to purchase any item that is available for sale through the Steam platform, including video game hardware, more than 1 46,000 games, loot box keys, and other virtual items. 78. Steam users also can readily convert virtual items to cash by purchasing Steam hardware and then resell ing it off plat form. Indeed, a n OAG investigator did so, converting a Counter - Strik e skin called a “Stiletto Knife” to $180 by: (a) s elling the skin o n the Steam Community Market for Steam Wallet fun ds, (b) using the S team Wallet fun ds received from th e sale of the skin to purchase a Steam Deck, and (c) sell ing the Steam Deck for $180 in cash at a store that bu ys and sells electronics. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 24 of 52

100.00 595.00 590.00 an 8 2026 Jan15 2026 Jan 22 2026 lan 29 2026 id 7 2 202 Zoom graph Week Month Lifetime Listings 22 79. Valve also has developed market research tools that it has integrate d into the St eam platform, similar to thos e commonly found on stock and cryptocurrency trading platforms. Users interested in research ing, buying, or selling a pa rticular type of virtua l item can ch art the av erage sale price of the item over various t ime periods, as well as vi ew a list of current offers to bu y and sell items of that type. Figure Q 80. As described below, these tools enable a user w ho is considering whether to spend the money to open a loot box to research the items they migh t win. ii. Valve d esigned Steam to enable buying and selling virtual items on t hird -p ar ty marketplaces 81. Valve has long understood that third - party marketp laces are important t o the economy of the virtual it ems it has created. By pro viding a means fo r users to sell thei r virtual ite ms for cash, these mark etplaces motivate us ers to purchase key s from Valve in the hopes of opening a loot box and winning a high - value item they can cash in. More loot box openings also mean s more virtual items will be sold, w hich drives transaction s and Valve commissions on the Stea m platform itse lf. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 25 of 52

I-?arty Sites You can share this mique URL with other Steam users to allow thern to send you a trade offer even if they aren't on youfmiends Ast. You can share this URL anywhere, mcluckx.j on third- party trading sites and Steam CamnumRy gratps. Trade L 1R httpsW. Create If yS nave snarea or posted your URL arid would Ake to stop receiving trade offers from it, meeting a new URL wil make those links inactive. 23 82. With that understanding, Valve designed the Ste am platform to facilita te the purchase and sale of virtual i tems on third - party marketplaces. For example, Valve provides each Steam user with a Steam “Trade URL, ” which enables users to buy and sell virtual ite ms from their Stea m inventory o n third -party marketplaces. As explained by one web site that reviews skins gamb ling sites and marketplaces, “ the bi ggest reason for needing a Trade URL[] is to make use of t hird - party marketplaces,” and such sites ask users for this information “so that deals can b e processed more easily when both buying and selling skins.” 6 83. Valve itself encourages this, instructing users that the Trade URL can be shared “on third - party trading sites” — one of several terms V alve uses to refer to third - pa rty marketpla ces. Figure R 84. As the demand for and popularity of the virtual item s Valve distributes through its loot boxes have grown, various online marketplaces unaffi liated with Valve have emerged, using the Trade URL and other Steam features to enab le users to buy and sell thei r virtual ite ms. Such sites provide users with two advantages over the Steam Community Market. First, users can receive 6 SkinLor ds, What Is A Stea m Trade Link?, https://skinlords. com/blog/what - is -a- steam - trade - link/ (last visited February 1 3, 20 26). CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 26 of 52

Counter-Strike 2 Skins S&P 500 4.4B 54T 4.2 4.0 52 3.8 51 36 50 Jan 3 Feb 1 Feb 15 Mar 7 Jan 3 Feb 1 Feb 15 Mar 7 2025 2025 Bitcoln Ethereum 110.0K 4.OK 100.0 3.0 80.0 2.0 Jan 3 Feb 1 Mar 7 Jan 3 Feb 1 Feb 15 Mar 7 2025 2025 24 cash for thei r items inste ad of Steam Wallet funds. Second, u nlike the Ste am Community M arket, which caps transaction amounts, third - party sites en able users to sel l rare virtua l items from Counter- Strike, Team F ortress 2, and Dota 2 for tens of thousands of dollars. 7 85. While the market s for Counter- Str ike skins and the virtual ite ms from Team Fortre ss 2 and Dota 2 have experienced fluctuations over the years — similar t o markets fo r other digit al assets — the general trend has been strong growth, esp ecially for C ounter- Strike skins. 86. In March 2025, Bloomberg reported that the market for Counter- Strike skins had surpassed $ 4.3 billion, eclipsing its previous high from April 2023. 8 In 2023, prices for Counter - Strike skins soared on spec ulations abou t how the transit ion from CS:GO to CS 2 would impac t the market. 87. Citing an expert, t he Bloomberg article explained that “Counter - St rike 2 skins represent a distinct inve stment class that fluctuat es according to items’ rarity, p layers’ engage ment in the gam e and other non-conventional economic indicators.” Figure S 9 7 Counter - St rike s kins have re portedly sold for hund reds of t housands dollars t hrough private sales. 8 Cecilia D’Anastasio, Market for ‘Cou nter - Strike 2’ Digital It ems Hits Ne w High, Bl oomberg (Mar. 7, 202 5), https://www.bloomberg. com/news/articles/2025 - 03 - 07/market - fo r - counter - strike -2- digital - items - h its - all - time - high. 9 Id. (source: Pricempire.com). CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 27 of 52

25 88. The same article reported that in June 202 4, a CS 2 skin had been sold for $1 million, a record amount at that time. Figure T 10 89. In addition to third - party mark etplaces for Valve’s virtu al items, many sites have emerged that offer users the opportunity to gamble using their Counter - Strik e skins and other virtua l items as stakes. Sites of this nature, generally know n as “skins gambling sites,” first started as a way for users to bet on e s ports games, particularly Counter - Strike. These sites lat er evolved to offer a host of casino games and games of ch ance that mimic Valve’s loot box gambling. iii. Valve has consistently fostered third - party marketplaces that allow the purchase and sale of virtual items for cash 90. In responding to inquirie s regarding whether its loot boxes violate gambling laws, Valve has consistently maintained that its Steam Subs criber Agre ement (“SSA ”) prohibits the sale of skins off pla tform, and th at it actively act s against trading sites that allow u sers to sell Steam virtu al items for rea l money. 10 Screens hot from X post re porti ng the sal e of the C ounter - Strike s kin for more t han $1 mi llion. @J akeSuc ky, X (June 5, 20 24, at 12:12 PM), htt ps://x.com/ JakeSuc ky/stat us/17983 87413313 868135?l ang=en. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 28 of 52

26 91. For example, Valve made the following repres entation in a reply to an inquiry by the Danish Gambling A uthority: [T] he [Steam trading system] has be en abused by third party s ites that violate our terms of se rvice. They o ffer to buy and sel l virtual it ems for real world money. What happens in these cases is that these sites create fake Steam user a ccounts. A user who wan ts to sell their item gifts their virtual it em to the bo t and receiv es real - world money outside of Steam, e.g. via Paypal. Likewise a user who wants to buy an item for real - world money transfers money to the illegal provider by means of Paypal and receives back a “gift” of the des ired item via Steam. As noted above, this behavior is in violation of our te rms of service. We have banned thousands of these bot accounts whenever we have been able to identify the m, but it is u ltimately a game o f cat and mouse. 92. Valve’s public position, however, is belied by its internal actions. W hile Valve has sporadically enforced its SSA against skins gambling sites, Valve has no t acted against sites that permit the s ale of Valve’s v irtual ite ms. 93. Valve’s actual view of these marketplace sites was revealed in an ungu arded answer given by a senior employee who was asked at a panel discussion in 2017 about Valve’s policies towards sites that do n’t offer gambling but do allow u sers to sell their virtual items for cash. The employee admitted that Valve does not enforce its SSA against such sites, replying that “I guess we don’t really fundamentally have an opinion on other uses that people have for their inventories.” 94. Indeed, Valve has expressly ex empted sites that o perate as marketplaces f or Steam virtual items from its e nforcement e fforts agains t skin s gambling sites and repeated ly restored Steam accounts operated by marketp lace sites when those accounts wer e inadvertently suspended by Valve. Valve’s internal com munications demonstrate that employees were well aware these marketplaces enabled V alve’s virtual items to be bought and sold for fiat currency, regularly referring to t hem as “cash out service s,” “real money out sites,” and “trading sites.” CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 29 of 52

27 95. For example, in 2016, Valve prepared to send a series of cease -and- desist letters to sk ins gambling sit es. A Valve employee n oticed that OPSkins, a sk ins marketp lace that d id not offer gambling at the time, was on the list of intended recipients. The emp loyee emailed several Valv e colleagues, w riting, “I don’t think we need to send the letter to opskins and other real money out sites correct, they aren’t gambling [?] ” The employee’s view that Valve’ s enforcement efforts were not targeting cash marketplaces was quickly confirmed, and neither OPSkins, nor any other marketplace site, rece ived a cease - and - desist letter. 11 96. Valve similarly exempted another third - party marketplace, CSGOSell.com, from its cease - and- desist campaign. A V alve employee who had been working on locking accounts used by gambling sites noted in an email that some Stea m accounts operated by CSGOS ell.com, described by the Valve employee as a “a c sgo trading site, no gambling,” got “caug ht” in a wave of account locking. 97. Valve further demonstrated its abidance of cash marketplaces for skins in 2017 when i t was contacted by a professional Counter-Strike player who was interested in starting a “ga mbling website.” A lawyer for Va lve replied that V alve did not per mit such sit es and told the player that if he did start a gambling site, “don’t use CS:GO items in your business.” T he player then asked if Valve had an y problems with him creating a cash marketplace fo r Counter - Strik e skins like the site, CS.Money. The Valve attorney provided a much more measured response, saying that, other than general compliance with “Steam terms and agreement s,” Valve did not “have very many restrictions for what businesses players and teams can be involved in, other than the pr ohibition 11 Two year s later, Valve dec ided t o shut d own Steam accounts connected to OPSkins, not because it allowed users to conve rt their skins to cash, but inste ad becaus e the sit e was “p ushing th e bounda ries act ing prima rily as interme diaries for gambl ing si tes and f raudsters ” and ci rcumve nting a se ven - day hold Va l ve had im plemente d on trading ne wly acquired virtua l items. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 30 of 52

28 against gambling.” The Valve attorney went on to provide some rules regarding the promotion of the proposed marketplace site. 98. In July 2023, Valve helped a major marketplace, CSFloat, which touts that on its platform, “you can withdraw any sales proceeds to your bank account, debit ca rd, or crypto.” At that time, the platform was brande d as “CSGOFloat.” Anticipating Valve’s transition from CS:G O to CS 2, the company planned on rebr anding to CSFloat. It was unable to acce ss Steam using t hat domain, however, because Valv e had previously flagged the domain as suspicious. A representative from CSGOFloat asked Valve to “re - assess the status” of the CSFloat.co m domain so the compan y could complete the rebrand. Valve complied with the re quest and CSGOFloat successfully rebranded as CSFloat. 99. Valve assisted yet anoth er well - known marketplace site called Skinport in March 2024 after Valve erroneously suspended the site’s Steam accounts in an attem pt to shut down certain gambling sites. Skinport, which describes itself as “one of the best CS:GO/ CS2 marke tplace[s] to buy or sell your CS:GO/CS2 Skins,” repor ted to Valve that over 2,500 of its Steam accounts “were accidentally restricted/ locked due to a technica l issue on [Valve’s] end.” A day later, Valve “unlocked” the accounts in question. B. High market va lues and easy liq uidation ha ve made Valv e virtual ite ms attrac tive targets for thieves 100. The high value of rare skins and the ease of liquida ting items th rough third -party marketplace s have made Valve virtual items an att ractive tar get for thieves. Valve has receive d hundreds of thousands of support requests from users whose Steam accounts ha ve been hacked, or who have been tricked into tra nsferrin g virtual item s to malicious actor s. 101. For many users, these thefts have been extremel y costly. Reports of stolen virtual items worth thousands, and in some cases tens of thousands, of dollars have been common. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 31 of 52

29 102. In December 2015, Valve published an article on Steam describing the increasing p roblem of theft. 12 In that article, Valve noted that “enough money now moves around the system t hat stealing virtual Steam good s has become a real business for skilled hackers.” According to Valve, “[w]hat used to be a handful of hackers is now a highly effective, organized network, in the business of stealing and selling items, ” with Valve seeing “around 77,000 accounts hijacked and pillaged each month.” 103. In most cases, the se stolen items ha d been sold to unwitting buyer s by the time the t heft was discovered and reported to Valve. Valve’s original response to such incident s was to duplicate the stolen item so both the victim of the theft and the unwitting buyer could have the item. 13 In 2016, Valve discontinued this practice, recognizing that creatin g duplicate it ems “has the negative side effect of changing an item ’ s sca rcity - as more copies of the item are creat ed, the value of every other similar item is re duced.” 14 104. To combat the rising tide of thefts, Valve made several modifications to th e Steam platform designed to provide increased security to users, including implemen t i ng two - factor authenticat ion through its Steam mobile app and placing trade restrict ions on account s wher e t wo - factor authentication was not enabled. 15 105. Despite the se measures, the theft of virtu al items on Steam, particula rly of Counter- Strike skins, continue d to be an issue. In August 2022, industry publications reported that hackers stole 12 Steam, Securi ty and Trading (De c. 9, 2015), https://st ore.ste ampowere d.com/oldnews/ 19618. 13 Id. 14 Steam, Secur ity and Trading: Upda te (Mar. 1, 2016), h ttps://store.steampower ed.com/oldnews/20631. 15 Securit y and Tra ding, supra n ote 12; Security and Trading: Update, sup ra note 14. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 32 of 52

30 $6 million worth of CS:GO skins from Steam accounts associated w ith CS.Money, a third -party marketplace. 16 106. In response, Valve introduced even more securi ty measures. For example, in July 2025, Valve announced the rollout of “Trade Protection, ” which it describ ed as a “feature some games support that allow [s] you to reverse recent trades, design ed to help if you lost items after losing control of your account.” 17 Currently, the only game supporting Trade Protected items is CS 2, but Valve has stated it plan s to make Trade Protection available for other games on Steam. 18 V. Users Open Valve’s L oot Boxes to G amble 107. To obtain a virtual item in Valve’s games, users generally have two options: they can purchase a key to open a loot box and win an item selected at random, or they can purchase an item of their choosing through the Steam Community Market or a third- party marketplace. 108. When it first introduced loot boxes, Valve believed it was important to ensure that users would not feel they had chosen the wrong option — i.e., paid more for the key than the value of the item they won. As one senior Valve developer explained in 2014, Valve wanted to avoid a situation where a user who spent $2.49 to open a crate and received an item availabl e for purchase on Steam for $0.50 would feel like they “just lost $2 of actual value.” 109. That concept was abandoned, however, and soon after the ir introduction, Valve’s loot boxes became losing propositions for users. Today, nearly every user who purchases a key and opens a loot box receives an item that is common, and worth less than what the user spent on the key. In such cases, users’ money would be better spent purchasing the item directly through the 16 Alina BÎZGĂ, Bitdefender (Aug. 17, 2022), https://www.bitdef ender.com/en - us/blog/ hotforsec urity/hackers - steal - 6- million - worth - of - cs - go - ski ns - fro m - trading - platform. 17 Steam Support, Trade Protected Items, https://help.steampowered. com/en/faqs/view/365F - 4 BEE - 2AE2 - 7 BDD (last visited F eb. 1 3, 2026). 18 Id. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 33 of 52

S282.0 31 Steam Community Market at a far lower price. Indeed, in most cases use rs could have purchased 10 or 20 of the same ite m on the Steam Community Market with the money they spent to open the loot box. 110. However, users who open a loot box have a chance — a small one — of winning a virtu al item worth hundreds, and in some cases thousands, of dollars. This remote possibility of winning a valuable p rize, like the dream of buyin g a winning lot tery ticket or h itti ng the jackpot on a slot machine, drives the sales o f keys for Valve’s loot box es. 111. The Dreams & Nig htmare s weapons case in Counter -Strike, pictured above in Figure s C through G, illustrates why this is the case. A user considering purchasing a key to op en a Dreams & Nightmare s weapons case could readi ly identify the Exceeding l y Rare Special Items using information av ailable on third - pa rty websites. Figure U is a screenshot from one such website, which indicates that the “Exceedingly Rare Spec ial Items” associated with a Dreams & Nightma res weapons case are a colle ction of knives. Figure U 19 19 Screens hot from https://csroi.com/item/dreams - nightm ares - case (last visited Feb. 14, 2026). CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 34 of 52

u -··! m.:hen cara ® 10 SinibI M u. · "$ 100t..C0 55 (4368| 663 wy Ordere R pl saurnli Dep. Pr iec SM50 00 57..130.GG.'½ · 52.120A0 -.. I I C CC CO.. 3 BoM 32 112. As of February 11, 2026, the most valuable of these knives was the Gamma Doppler Emerald Butte rly Knife. A u ser awarded the G amma Doppler Emera ld Butterly K nife after opening a Dreams & Nightmares weapons case could reaso nably expect to receive $10,000 or more for the skin on a third - pa rty marketp lace, as indica ted in Figure V, below. 20 Figure V 21 20 As of Februa ry 11, 2026, there w ere no offers to sell this item in factory new condition on the Steam Community Market but almost 1,600 offers to buy it f or more than the $1,800 limit t hat Valve pur portedl y impose s on singl e - item sales through the Community Ma rket. Li stings fo r this ski n on third - part y market places demonstra te why there are no sales of it on Steam — because Valve has tightly limited the releas e of this skin, it is worth far more than th e maximum price for a sale on the Steam Community Market. 21 Screens hot from https://csfloat.com/ite m/940635796262750 975 (last visited Feb. 11, 2026). CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 35 of 52

sfuRt UBRARY w P. RAFIFRIEDMAN537 st has tee 33 113. The allure of such a windfall is central to the excitement of opening a loot box. T he reality, however, is that the odds of w inning this pa rticular item, like the odds of winning a lotte ry prize or slot machine jackpot, are minute. According to a site that analyzes Counter - S trike skins and weapons cases, the odds of winning a Gamma Doppler Emerald Butterly Knife from a Dreams & Nightmares case are one in 146,625. 114. Instead, the user is almost certain to receive an item that is common, and worth pennies, like the P2000 | Lifted Spirits. T his item typicall y sells on the Steam Commu nity Market for abo ut $0.13. A user interested in obtaining that skin w ould be far bet ter off dir ectly purch asing it from the Steam Community Market for $0.13 than spending $2. 71 for a key to open a Dreams & Nightmares weapons case. Figure W CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 36 of 52

pect in Game.- $9133 Unusual Nappers Respite unusu"inappers Resphs Unusua Team Fortress 2 * Unusual Effect Purple Confetti "Burn in HELL'".. 34 115. Indeed, according to Valve’s reasoning when developing the loot box system, a user who received a skin with a market value of $0.13 af ter paying $2.71 to open a crate would incur a loss of $2. 58 of actual value. The loss would be eve n greater if the user had purchased the case f rom the Steam C ommunity Market instead of h aving obtain ed it for fre e from Valve through an in - game drop. 22 116. That logic ho lds for the vast m ajority of the items award ed from Valve’s loot boxes, including roughly 96% of the items awarded through Counter- Strike weapons cases. 117. For example, one of the “Exceedingly Rare” items in th e Mann Co. Supply Crate, shown above in Figure K, is an “Unusual Napper’s Respite” hat. As shown in Figures X and Y below, Steam listings on February 13, 2026 showed that this cosmetic item with particularly desirable “unusual effects” (“purp le confetti” in Figure X below) can sell for seve ral hundreds o f dollars. As shown in Figure Y, Steam’s price track ing tool indicates an Un usual Napper’s Respite hat was sold for $747.50 on December 25, 2025. Figure X 22 As of Februa ry 13, 2026, a Dreams & Nightmares w eapons case could be pur chased on the Steam Com munity Market for as little as $1. 77. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 37 of 52

Dec 25 2025 7PM $747.50 1sold 2020 Fet 3 2022 Feb 3 2024 Feb Zoom graph Week Month Lifetime KMistreaks Active Used to add kMstreak properties to an Item. 35 Figure Y 118. Similar to Counter - St rike weapons cases, ho wever, the commonly awarded items from Mann Co. Supply Crates are worth far less than the price of the key required to open the loot box. For example, Steam’s price tracker indicat es that one of the “Killstreak Ki ts ” in the Series #84 Crate, the “Backburner,” seen below in Figure Z, sold for between $0.40 and $0.50 in the 30 days leading up to February 13, 2026. Figure Z CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 38 of 52

36 119. The loot boxes in Dota 2 present a similar proposition, with ultra - rare ite ms worth many times the price of a key. As o f the filing of this C omplaint, the ultr a - rare item in the Chest of Endless Days drop list, shown above in Figure N, the “Heir of Menace,” was selling on the Steam Community Market for around $75. Conversely, common items in the treasure chest’s drop list, such as the “Drow Ranger,” could be purchased for $0.20 or less. VI. Valve’s Loot Boxes Pose t he Same Dangers as Casino Gambling, Especially for Children 120. Studies have shown that loot boxes, particularly those that reward use rs with items that are convertible to real money, pose the same risks as trad itional c asino - style gambling. These stud ies further show that th ese risks are heightened for the most vu lnerable seg ments of Valve’s playe r base: adolescents and ch ildren. A. Valve’s loot boxes use the same mechanics a nd psychological lures as tradi tional casino games 121. The connection between loot boxes and problem gambling is unsurprising, as companies like Valve have designed their loot boxes to have many of the fea tures casino games use to en t ice players to spend money in the hopes of winning something valuable. 122. Some of the psychological mechanisms that have long been used by the makers of casino games and that Valve also has incorporated into its loot boxes include v ariable ratio reinforcement (“VRR”), gameplay experience (such as sensory feedback), entrapment, and ready and constant availability. Variable ratio reinforce ment 123. VRR is the process of delivering rewards on a seemingly random schedule in order to encourage a particular behavior. Research has consisten tly shown variable rewards result in strong engagement. It is in trinsic to many forms of gambl ing, including slot machines, and has been CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 39 of 52

witch.tv/stableronaldo * Karambit|Marble Fade °": csgo gods please djxrr: -300 djxrr; LOLOOL,dislashintend Icee for that uk kni STABLE S With its curved blade memicking a t|ger's claw. t karambit was developed as part of the southeast Asian martla|dIsr phne of sitat. the knife m typmally uwd wnh a reverse grtp wlth Play (k) 37 shown to increase spending on gambling. L oot boxes, like slot machines, profit from VRR schedules. Gameplay experience 124. Gameplay experience refers to the display elements and aud io cues designed to en gage players’ attention. The spinning display and the accompanying sound that pla ys when a user opens a Valve loot box are examples of gameplay e xperiences similar to those employed by slot machine s. 125. The gambling aspects of t he gameplay experience associated with Valve’s loot boxes are clearly visible in popular video content featuring users opening multiple Counter - Str ike weapons cases in rapid succession. Such content, like that shown below in Figur e AA, generally includes no actual Counter - Strike play and, instead, shows the users opening one case after another and touting the cash value of any valuable items won. Figure AA 23 23 Screenshot fr om ChronoYi nger, BEST CAS E OPENINGS OF 2 023 (Dec. 25, 2 023), https:/ /www.yout ube.com/watc h?v=mMel hczy9Uc&t =135s, at 25:12. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 40 of 52

38 126. The spinning wheel graphic, l ike a slot machine, also keep s users spending money by periodically creating the illusio n that the user “almost” won when the wheel co mes to rest on an item that is immediately adjacent to a rare, valuable item. As mentioned above, this feature is referred to as a “near miss. ” Entrapment 127. Entrapment refers to the impulse that drives players to cont inue to spend money on games of chance in an attemp t to recoup losses. As with casino game s, t he potential to recoup losses by win ning a valuable item can drive individuals to repeatedly purchase keys to open loot boxes. Ready and constant availability 128. Ready and constant availability, as t he term suggests, refers to loot boxes’ accessib ility. Similar to online gambling, loot boxes are available to users in their homes 24 hours a day. B. Valve’s loot boxes can lead to addic tion and result in real harm 129. The psychological lures Valve and other game developers have incorporated int o loot boxes are effective: s tudies have firmly established a relatio nship between loot boxes and problem gambling. Indeed, the amount that individuals spend on loot boxes has been shown to be directly related to the s everity of their pro blem gamblin g. Studies have found t his rela tionship is st rongest where, as in Valve’s games, the virtual items that users win have real monetary v alue. 130. This means that for some users, loot boxes can cause real harm. Loot boxes provide an outlet for those who already suffer from problem gambling to engage in compulsive and harmful behavior. Moreover, loot boxes can act as a gateway to problem gambling for individuals who have not experienced gambling addiction in the past. 131. Health officials have long recogn ized the serious harms that p roblem gamblers experie nce. The New York Office of Addiction S ervices and Supports provided a succinct description of the range of such harms in 2025: CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 41 of 52

39 Gambling harms, including gambling d isorder, are a ssociated w ith serious and long - lasting financial consequences, and social consequences. Financial consequ ences can include debt, asset loss, and bankruptcy; social consequences can include loss of trust, interpersonal conflict, and impaired relationships. Additi onally, those who experience gambling harms, including gambling disorder, have a higher prevalence of anxiety, depression, insomnia and substance use disorders, and suicidal ideation and attempts than those who do not experience gambling harms including gambling disorder. 24 132. According to the American Psychiatric Association, “gambling disorder has been shown to carry the highest suicide risk out of any other substance use or addictive disorder,” with roughly one in two gamblers engaging in suicidal thoughts and one in five gam blers attempting suicide. 25 133. Law enforcement agencies also have recognized the link between problem gambling and suicide. A 2017 article i n the FBI’s Law Enforcement Bulletin explained that out -of- contro l gambling can aggravate other factors that lead to suicide, and that “[s]uicidal thoughts and a relatively hi gh incidence of [suicidal] attempts app ear prevalent in p roblem gamb lers.” 26 C. The r isks a ssociated w ith Valve’s lo ot boxes are particularl y heightened for childr en and adolescents 134. It is well established that children and adolescents who are exposed to gambling ac tivities are more likely to develop addictive behavior patterns than those who are not exposed. 135. In a warning to paren ts, the Massachusetts D epartment of Public H ealth noted that “[r]esearch shows that children introduced to ‘harmless betting’ by age 12 are four ti mes more 24 New York State Office of Addiction Services and Suppor ts, Addiction Data Bulletin 5: The Gambling Risk Environme nt and Public P ercept ions of Ga mbling in New York Stat e, at 3 (Apr. 2025), https:/ /oasas.n y.gov/s ystem/fi les/docu ments/20 25/04/ga mbling - adb5.pdf. 25 American Psychiatric Asso ciation, What is Gambling Disorder? https://www.p sychiatry.org/patients - families/gambling - disorder/wha t - is - gambling - disorder (last visited Feb. 13, 2026). 26 Tony Salva tore, Probl em Gamblin g and Suic idal Behavi or: A Prime r for Law E nforceme nt (June 13, 2017), https://leb.fbi.gov /articles/featured - articles/pro blem - gambling - and - su icidal - behavio r -a- prime r - for - law - enforc ement. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 42 of 52

40 likely to engage in problem gambling later.” 27 The advisory went on to expla i n that “ [a] tee n’s brain, with an underdeveloped logic center, isn’t wired yet to weigh risk and make healthy c hoices. So that ‘win’ on an online game today can lead to the negative side effects of real - life gambling tomorrow.” The New York Council on Problem Gambling issued a similar warning, sta ting that “[t]he earl ier a child sta rts gambling, the more likely they are to have problems due to gambling. ” 28 136. Research has borne out that adolesce nts are particular ly vulnerable to the harms associated with loot boxes. Multiple studies have shown there is a n even stronger relationship between loot box engagement and problem gambling in adolescents than in adults. This is consistent with general research related to the developing brains of teenagers. As explained i n a 2021 British research paper, there are likely several underlying reasons: First, neurode velopmental im maturity is thoug ht to be linked to reduced impulse control in adolescent s. Second, this cohort may lack effective coping strategies for the ch allenges of adolescence, leading to greater urges for ‘escape’ – a know n risk factor for problem gambling. Third, adolescents are more susceptible to influences of peer pressure, where socia l networks can serve to no rmalise behaviour such as high-risk gambling. 29 137. The risk of l ife - altering consequences is similarly heightened for individuals who develop gambling compulsions in childhood or adolescence. As note d in a 2025 paper, “[p]roblem gambling during adolescence most likely leads to depression, self - injury, and further addictive behaviors, which ultimately ruin adolescents’ lives.” 30 27 Massachusetts Department of Public Health, Teens g ambli ng. It’s a risk, https://www.mass.gov/info - details/teens - gambling - its -a- risk (last visited Feb. 13, 2026). 28 New York Coun cil on Problem Gambling, Ta lk2Ki ds, https://nyp roblem gamblin g.org/res ources/t alk2kids / (last visited Feb. 13, 2026). 29 James Cl ose & J oanne Ll oyd, Lifti ng the L id on Loot - Boxe s: Chanc e - Based Purchases in Video Games and the Converge nce of Gaming a nd Gambling, at 27 (Apr. 2021), https://www.gambleaware.org/our - resear ch/publication - library/articles/liftin g - the - lid - on - loot - boxes/. 30 Hyun Ju ng Lee & Gyungjoo Lee, Pat hways to underst anding problem gamblin g among adolesce nts (June 10, 2025), https://pm c.ncbi. nlm.nih. gov/arti cles/PMC 12150549/. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 43 of 52

41 138. A 2017 ESPN arti cle provided a vivid illus tration of the problematic behaviors th at can develop when adolescents are exposed to loot boxes like Counter-Strike weapons cases. 31 139. The story profiled a teenager na med Elijah, who fir st downloaded CS:GO in 2012, when he was in the sixth g rade. At the time, he “ didn’t really l ike it.” When Valve introduced skins into the game the following year, however, he became more interested. Elijah started buying keys and opening weapons cases “ in the hopes of getting a skin for his Tec - 9 gun called the Nuclear Threat,” which was valued at $120. He was not successful. 32 140. Elijah soon turned to th ird - party skins gambling sites, eventually developing a pattern of behavior his father recognized as “compulsive [] gambling.” After spending hundreds of dollars to purchase skins, Elijah bet them all away in a series of bets on coin flips in which he doubled down each time he lost. Elijah recounted the result: “I lo st 10 times in a row and lost it a ll.” The article describes how, eventually, “Elijah was waking up in the morning to check the bets he’d made the night before on CS:GO tournaments in Eur ope. Then he ’ d go to school to bet more on the computers in his high school library.” 33 141. Elijah’s story is not unique. According to a well - known gaming publ ication, “we’ve seen countless cases of kids using thei r parents’ credit cards after b eing sucked into this world, some as young as 11.” 34 142. The dangers of exposing minors to gambling has been recognized by the New York legislature. Under New Yo rk law, no business licensed under the Racing, Pari - Mutuel Wagering 31 Shaun As sael, Ski n in the Game, ESPN (Jan. 20, 201 7), https://www.espn. com/espn/feature/story //id/18510975/how - counter - strike - turned - teenager - compulsive - gambler. 32 Id. 33 Id. 34 James Lucas, Counter - Strike: Gl obal Offe nsive 2 Needs T o Solve Va lve’s Ga mbling Problem, TheG amer (Mar. 6, 2023), https://w ww.thegamer.com/csgo -2- valve - gambling - pro blem/. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 44 of 52 <a href="https://www.espn.com/espn/feature/story//id/18510975/how-counter-strike-turned-teenager-compulsive-gambler">

42 and Breeding Law can p ermit individuals under the age of 18 to gamble, N.Y. Rac. Pari - Mut. Wag. & Breed. Law § 108, and casino s and sports betting platfo rms cannot allow participants under 21, id. § 1332. D. Teenagers and childre n comprise a significant segmen t of Valve’s u s ers 143. Teenage boys are a core audience of first - person shooter games like Counter - Strike. It is also well known that many of the most famous esports players of CS 2, Dota 2, and T eam F ortress 2 began playing w ell before they turned 13. Over half of the 22 players on the top five Counter- Strike esports academy teams are 18 years old or younger, and the younge st member is just 14 years old. 144. While t he SSA prohibits children under the age of 13 from creating a n account, Valve does not verif y the age of Steam users. Instead, users creating an account must simply click a checkbox next to a message that states, “ I am 13 years of age or older and agree to the terms of th e Steam Subscriber Agreement and the Valve Privacy Policy.” Figure BB CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 45 of 52

43 145. Moreover, Valve does not appea r to enforce its age limitati on even when it becomes aware of a violation. For exa mple, in 2017, the CEO of a professional esports league reached out to Valve about an alleged theft of virtual items f rom the account of his 11 - year - old son, who was playing one of Valve ’s most popular games “a lot.” Valve determined that the items were not, in fact, stolen. There is no indication Valve closed the child’s account or took any other action due to the child’ s violation o f the SSA. FIRST CAUSE OF ACTION PURSU ANT TO EXECU TIVE LAW § 63(12): VIOLATIONS OF AR TICLE I, SECTIO N 9 OF NEW YO RK’S CONSTITUTI ON 146. OAG repeats and realle ges paragraphs 1 through 145 and incorpora tes them by reference herein. 147. Executive Law § 63(12) authorizes OAG to seek injunctive and other equitable relief when any individual or business has engaged in repeated illegal acts or persistent illegality in the carrying on, conducting, or transaction of business. 148. Article I, Se ction 9 of the New York State Constitution prohibits “ lotter [ies ] or the sa le of lottery tickets, pool - selling, book - making, or any other kind of gambling, ” except lotteries operated by the State as may be auth orized and prescribed by the legi slature, pari - mutuel b etting on horse races as may be prescribed by the legislature, casino gambling at a prescribed number o f licensed fac ilities, and bingo and other games of chance conducted by authorized non - profit organizations. 149. Valve has designed and developed software that enables users to risk or stake someth ing of value in exchange for the opportunity to activate a loot box and win a virtual item, the identity of which is determined entirely by chance. The user has no control or influence over the virtual item that is aw arded. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 46 of 52

44 150. The virtual items th at Valv e awards to users have value. They can be sold on the Steam Community Mark et for funds in the digital Steam Walle t, which can then be used to purchase video game hardware, video games, virt ual items, or the privilege of opening more loot boxes. They can also be sol d for cash on third- party marketpla ces. 151. Valve’s loot boxes do not fall with in any of the exceptions to the gambling prohibition set forth in Arti cle I, Sectio n 9 of New York’s C onstitution. 152. By engaging in the acts and practices described above, Defendant has acted and continues to act in derogation of Article I, Section 9 of New York’s Constitution. 153. Defendant’s violation s of Article I, Section 9 of New York ’s Constitut ion constitu te repeated and persistent il legal conduct in violation o f Executive L aw § 63(12). SECOND CAUSE OF ACTION PURS UANT TO EXEC UTIVE LAW § 63(12): VIOLATIONS OF P ENAL LAW § 225.05 PROMOTING G AMBLING IN TH E SECOND DEGR EE 154. OAG repeats and realle ges paragraphs 1 through 145 and incorpora tes them by reference herein. 155. Executive Law § 63(12) authorizes OAG to seek injunctive and other equitable relief when any individual or business has engaged in repeated illegal acts or persistent illegality in the carrying on, conducting, or transaction of business. 156. Penal Law § 225.05, promoting gambling in the second degree, prohibits any person from knowingly advancing or profiting from unlawful gambling activity. Promoting gambling in th e second degree is a class A misdemeanor. 157. Penal Law § 225.00(2) provides that: A person engages in gambling when he stakes or risks something of value upon the outcome of a contest of chance or a future contingent event not under his control or influence, upon an CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 47 of 52

45 agreement or u nderstanding that he will r eceive someth ing of value in the event of a certain outcome. 158. Penal Law § 225.00(4) provides that: A person “advances gambling activity” when, acting other than as a player, he engages in conduct which materially aids any form of gambling activity. Such conduct incl udes but is not limited to co nduct direct ed toward th e creation or establishme nt of the particular game, contest, scheme, device or activity involved, toward the acquisition or maintenance of premises, paraphernalia, equipment or apparatus therefor, toward the solicitation or inducement of persons to participate therein, toward the actual con duc t of playing phases thereof, toward the arrangement of any o f its financial or reco rding phases, or toward any other phase of its operation. 159. Penal Law § 225.00(5) provides that: A person “profits from gambling activity” when, other t han as a player, he accepts or receives money or other property pursuant to an agreement or understanding with any person whereby he participates or is to participa te in the proceeds of gambling. 160. Penal Law § 225.00(12) defines “unlawful” to mean “not specifically authorized by law.” 161. Valve has designed and developed software that enables users to risk or stake something of value in exchange for the opportunity to activate a loot box and win a virtual item, the id entity of which is determined entirely by chance. The user has no control or influence over the virtual item that is aw arded. 162. The virtual items th at Valv e awards to users hav e value. They can be sol d on the Steam Community Mark et for funds in the digital Steam W allet, which can then be used to purchase video game hardware, video games, virt ual items, or the privilege of opening more loot boxes. The virtual items can also be sold for cash on third- party marketplaces. 163. Valve has knowingly engaged in a variety of conduct that materially aids gambling activ ity, including creating and establishing loot boxes, maintain ing systems that enable users to open loot CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 48 of 52

46 boxes, and soliciting and inducing users to open loot boxes. Valve also has knowingly profited from gambling activity through the sale of keys and loot boxes pursuant to an agreement or understanding whereby Valve participat es in the proceeds of gambling. 164. Valve’s loot boxes have not been specifically authorized by law, and are unlawful. 165. By engaging in the acts and practices describ ed above, Defendant has vio lated and continues to violate Penal Law § 225.05. 166. Defendant’s violations of P enal L aw § 225.05 constitute repeated and persistent illegal conduct in violation of Executive Law § 63(12). THIRD CAUSE OF A CTION PURSUANT TO EXECUTI VE LAW § 63(1 2): VIOLATIONS OF P ENAL LAW § 225.10 PROMOTING G AMBLING IN TH E FIRST DEGREE 167. OAG repeats and realle ges paragraphs 1 through 145 and incorpora tes them by reference herein. 168. Executive Law § 63(12) authorizes OAG to seek injunctive and other equitable relief when any individual or business has engaged in repeated illegal acts or persistent illegality in the carrying on, conducting, or transaction of business. 169. Penal Law § 225.10, promoting gambling in the first degree, prohibits any per son from “knowingly advanc[ing] or profit [ing ] from unlawful ga mbling acti vity by: (1) Engaging in bookmaking to the extent that he receives or accepts in any one day more than five bets totaling more than five thousand dollars; or (2) R ecei ving, in connection with a lottery or policy scheme or enterprise, (a) money or written records from a person other than a player whose chances or plays are represented by such money or records, or (b) more than five hundred dollars in any one day of money played in such scheme or enterprise. ” Promoting gambling in the first degree is a class E felo ny. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 49 of 52

47 170. Penal Law § 225.00(9) provides that: “Bookmaking” means advancing gambling activity by unlawfully accepting bets fro m members of the public as a business, rather than in a casual or personal fashion, upon the outcomes of future contingent events. 171. As alleged in paragraphs 154 through 166, Valve knowingly advances and profits from unlawful gambling a ctivity. 172. Valve has engaged in bookmaking by unlawfully accepting bets from members of the public as a business, upon the outcome of future contingent events. As alleged above, Valve has designed and developed software that enab les any member o f the public to purchase and use keys in exchange for the opportunity to activate a loot box and win a virtual item, the identity of which is determine d entirely by c hance. Valve has repeatedly re ceived and accepted in one day more than five bets totaling more than $5,000. 173. By engaging in the acts and practices describ ed above, Defendant has vio lated and continues to violate Penal Law § 225.10. 174. Defendant’s violations of Penal Law § 225. 10 constitute repeated and persisten t illegal conduct in violation of Executive Law § 63(12). PRAYER FOR RELIE F WHEREFORE, Plaintiff requests an order and judgmen t: a. Permanently enjoinin g Defendan t from violat ing the Const itution and la ws of the s tate of New York, including Executive Law § 63(12) and Penal Law §§ 225.05 and 225.10; b. Directing Defendant to produce an accounting of monies lost by consumers in New York as a result of Defendant ’s illegal acts; CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 50 of 52

48 c. Directing Defendant to make full restitution to consumers and pay damages caused, directly or indirectly, by the illegal acts complained of herein plus applicable pre -judgment interest; d. Directing Defen dant to disgorg e all monies re sulting from the illegal p ractices alle ged herein; e. Directing Defendant to pay a fine of three times the amount of its gain from the illegal practices alleged herein, pursuant to Penal Law § 80.10; f. Directing such othe r equitable relief as may be necessary to redress Defendant ’ s vio lations of New York l aw; g. Awarding Plaintiff costs of $2,000 pursuant to CPLR § 8303(a)(6); and h. Granting such o ther and furthe r relief as th e Court deems ju st and proper. CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 51 of 52

49 New York, NY February 25, 2026 Respectfully submitted, Letitia James Attorney General of New York By: /s Marc E. Montgomery CHRIS D’ANGEL O Chief Deputy for Economic Justice KIM BERGER Bureau Chief, Bureau of Internet and Technology CLARK RUSSELL Deputy Bureau Chief, Bureau of Internet and Technology JORDAN ADLER Senior Enforcement Counsel, Bureau of Internet and Technology MARC E. MONTGO MERY ALEXANDRA HIAT T Assistant Attorneys Gen eral, Bureau of Internet and Technology 28 Liberty St. New York, NY 10005 (212) 416-8433 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2026 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 52 of 52