The Goat Pen

105. Full Tilt Poker’s repeated representations that (1) player funds were held separately from operating accounts, (2) player funds were “safe” and “available,” and (3) it did not allow play on credit but instead allowed play only with “cleared” funds were, in reality, lies. In truth and in fact, Full Tilt Poker provided no protection whatsoever to deposits it received from players in the United States and other countries, and simply used the funds it claimed it was holding on account for its players to cover business expenses and to pay hundreds of millions of dollars in distributions to professional poker players affiliated with Full Tilt Poker and others who owned interests in Tiltware LLC. As a result, according to a balance sheet prepared by Full Tilt Poker, as of March 31, 2011, Full Tilt Poker owed players from around the world over approximately $390,695,788 but had only approximately $59,579,413 in its bank accounts. Full Tilt Poker relied on new deposits from players to ensure its ability to fund withdrawals to players’ accounts.

106. Rather than protect player funds as promised, Full Tilt Poker distributed hundreds of millions of dollars to its owners. Beginning in April 2007 and continuing through April 2011, Tiltware LLC’s Board of Directors, to wit, the FTP Insider Defendants, authorized the distribution of approximately $443,860,530 to the owners of Tiltware LLC, including themselves.