The long arm of the law: Canadian court orders offshore gambling site to block Manitoba users
August 26, 2025

By May M. Cheng and Alexander Watts

This article was originally published on Law360 Canada on July 18, 2025, 11:05 AM EDT .
You can read the original article here.

In a wake-up call for digital platforms offering online gaming services to Canadian consumers, a provincial court in Manitoba has issued a decision blocking a service provider for violating Canadian gambling laws.

In Manitoba Liquor and Lotteries Corp. v. IL Nido Ltd., 2025 MBKB 89, a well-known online entertainment and gambling platform was enjoined from operating in the province of Manitoba and ordered to use geo-blocking technology to prevent users in the province from accessing its services.

This is a stark reminder that online gaming remains highly regulated in Canada and foreign entities operating online must still comply with local laws.

Background Facts

The applicant, the Manitoba Liquor and Lotteries Corporation (MBLL), is Manitoba’s exclusive provider of lotteries, including online gambling products and services. MBLL is subject to both federal and provincial regulatory frameworks, and the profits from all gambling services are used to fund government-sponsored programs in the province that benefit Manitobans.

The respondent, Il Nido Ltd., is incorporated in Antigua and Barbuda and operates the websites Bodog.eu and Bodog.net; the first offers real-money gambling services, including betting on various sporting events or table and casino games, and the latter offers free versions under the same branding. A second respondent, Sanctum IP Holdings Ltd., owns the Canadian trademark registration for BODOG. Neither of the respondents responded to MBLL’s application or participated in the proceedings.

Violations of Canadian Law

Under sections 202 and 206 of the Criminal Code, all gambling in Canada is prohibited unless it falls within a statutory exception that is typically reserved for provincial authorities. The respondent’s Bodog.eu and .net platforms were accessible to Manitoba residents, but were not authorized or licensed to operate in Manitoba under Canadian law. The MBLL therefore sought an injunction to prohibit the respondents from offering unauthorized gambling services in Manitoba.

In addition, the MBLL sought an injunction under the Competition Act and Trademarks Act for falsely claiming that Bodog was a legal website in Canada. MBLL alleged that the respondents’ promotional materials violated:

  • section 52(1) of the Competition Act (by making false or misleading representations), and
  • section 7(d) of the Trademarks Act (by advertising false or misleading descriptions likely to deceive the public).

MBLL claimed that the respondents  misrepresented the lawfulness, character and quality of the Bodog platforms to deliberately mislead Manitobans by misrepresenting that:

  • “Bodog is a legal online casino in Canada”
  • Bodog is “one of the safest places to gamble online within the realms of the country”; and 
  • “Bodog is the most trusted site in Canada”

Manitoba Court of King’s Bench decision

The court found that the respondents knowingly made materially false representations to promote their business and services in Canada, in violation of s. 52(1) of the Competition Act. By advertising their platforms as legal and trustworthy for the purposes of attracting players in Manitoba, the respondents misled customers and engaged in conduct harmful to both the public and MBLL, including by diverting profits from online gaming outside the province.

The court also held that the respondents violated s. 7(d) of the Trademarks Act by using demonstrably false representations regarding lawfulness trustworthiness and safety of the online platforms in Manitoba. The court held that the demonstrably false representations used in association with the respondent’s trademark diminished the goodwill of MBLL’s marks and contributed to reputational harm.

Permanent injunction granted

Recognizing the limited ability to enforce monetary judgements against offshore entities, the court concluded that injunctive relief was the only effective remedy. The court also held that there was no impediment to exercising its discretion to grant the permanent injunction, citing the framework in Google Inc. v. Equustek Solutions Inc., 2017 SCC 34 at para. 66. Having found that MBLL’s legal rights were established, that damages were inadequate, and that no alternative remedy was available, the court granted a permanent injunction that included the following relief:

  • Prohibiting the respondents from operating or advertising their Bodog.eu and Bodog.net platforms in Manitoba;
  • Requiring that the respondents use geo-0blocking to prevent Manitoba residents from accessing their websites and gambling services; and
  • Restraining the respondents from using advertising to target Manitoba residents across digital and traditional media.

Importantly, the court noted the permanent injunction was narrowly tailored to target only unlawful conduct in Manitoba and relied on technology the respondents already had employed to geo-block the services.

Conclusion

It would seem that the resurgence of online gaming that took place during the pandemic is now facing a reckoning as legitimate Canadian gaming authorities take on foreign actors targeting the pocketbooks of Canadian residents. While legitimate Canadian gaming authorities intensify efforts to crack down on unauthorized platforms, businesses offering online gambling or related services should treat this case as a cautionary precedent. Claims about legality, safety or legitimacy must be truthful, verifiable and clearly tailored to avoid misleading the public; companies would be well advised to regularly review their advertising, trademark use and technological safeguards to ensure compliance. As the digital marketplace continues to evolve, this case signals that any business targeting Canadian consumers must operate within the bounds of Canadian law, or risk significant consequences. 

 

 

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