Skillz Platform Inc. v. Voodoo SAS, et al.

CourtDistrict Court, S.D. New York
DecidedFebruary 12, 2026
Docket1:24-cv-04991
StatusUnknown

This text of Skillz Platform Inc. v. Voodoo SAS, et al. (Skillz Platform Inc. v. Voodoo SAS, et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Skillz Platform Inc. v. Voodoo SAS, et al., (S.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -----------------------------------------------------------------X SKILLZ PLATFORM INC.,

Plaintiff, REPORT AND RECOMMENDATION -against- 24-CV-4991 (VSB) (JW) VOODOO SAS, et al.,

Defendants. -----------------------------------------------------------------X To the Honorable Vernon S. Broderick, United States District Judge: Plaintiff Skillz Platform Inc. (“Skillz”) seeks a preliminary injunction prohibiting Defendants Voodoo SAS, Esport Newco SAS, and Esport Newco US Corp. (collectively, “Defendants”) from making allegedly false representations in Defendants’ advertising and from using bots in their gaming applications. Plaintiff also seeks expedited discovery to more fully discover the scope of Defendants’ alleged use of bots and misconduct so that it can present such evidence during a preliminary injunction hearing. For reasons set forth below, Skillz has not established that it is imminently likely to suffer irreparable injury in the absence of preliminary relief. Further, because Plaintiff has failed to establish irreparable harm and the parties are well into discovery, Plaintiff’s expedited discovery request is DENIED. Accordingly, the Court recommends that Plaintiff’s motion for a preliminary injunction be DENIED. BACKGROUND A. Procedural history

On July 1, 2024, Plaintiff filed the initial complaint in this action against Defendants. Dkt. No. 1 (“Compl.”). On August 22, 2024, Plaintiff filed its initial motion for a preliminary injunction and expedited discovery, along with supporting papers, including the declaration of Casey Chafkin (Dkt. No. 25 [“First Chafkin Decl.”]). Dkt. Nos. 22–25. On September 20, 2024, Defendants filed their opposition with supporting papers. Dkt. Nos. 43–46. On October 2, 2024, Plaintiff filed an amended complaint. Dkt. No. 49 (“Am.

Compl.”). On October 8, 2024, Plaintiff filed its notice of renewed motion for a preliminary injunction and expedited discovery.1 Dkt. No. 50. In support of the 0F motion, Plaintiff filed a memorandum of law (Dkt. No. 51 [“Pl. Mem.”]), the declaration of Craig Carpenito (Dkt. No. 52 [“First Carpenito Decl.”]), and the declaration of Casey Chafkin (Dkt. No. 53 [“Second Chafkin Decl.”]).2 On October 29, 1F

1 As part of its renewed preliminary injunction motion, Plaintiff withdrew its initial preliminary injunction motion filed at Dkt. No. 22. 2 In the Second Chafkin Declaration at Dkt. No. 53, Mr. Chafkin asserted that “[o]ther than [his] change in title, the statements made in . . . [the First Chafkin Declaration at Dkt. No. 25] remain accurate.” While Defendants object to the use of this declaration, the Court nonetheless relies on portions of the First Chafkin Declaration. Due to “the expedited and nonfinal nature of preliminary-injunction proceedings,” courts can rely on “procedures that are less formal and evidence that is less complete than in a trial on the merits.” Fed. Trade Comm'n v. Tapestry, Inc., No. 24 Civ. 3109 (JLR), 755 F.Supp.3d 386, 411 (S.D.N.Y. 2024) (citation omitted). And “[i]nsofar as a piece of evidence contains hearsay, or otherwise may lack indicia of reliability, the Court accounts for that fact in deciding how much weight to assign that piece of evidence.” Id. 2 2024, Defendants filed their opposition (Dkt. No. 69), along with the declaration of Dmitri Williams (Dkt. No. 70 [“Williams Decl.”]), the declaration of Harold K. Gordon (Dkt. No. 71 [“Gordon Decl.”]), the declaration of George Edwards, Ph.D. (Dkt. No. 72

[“Edwards Decl.”]) and objections to Plaintiff’s evidence in support of its preliminary injunction motion (Dkt. No. 73). On November 12, 2024, Plaintiff filed a reply memorandum in further support of its motion (Dkt. No. 80), along with an additional declaration of Craig Carpenito (Dkt. No. 81 [“Second Carpenito Decl.”]) and a response to Defendants’ evidentiary objections (Dkt. No. 82). On November 19, 2024, Defendants requested leave to file a sur-reply, which the Court granted. Dkt. Nos.

83–84. On November 27, 2024, Defendants filed a sur-reply in further opposition to Plaintiff’s motion for a preliminary injunction. Dkt. No. 85. The Court considers Plaintiff’s motion for preliminary injunction fully briefed. On April 22, 2025, Judge Broderick referred this case to the undersigned for General Pretrial and specific non-dispositive motions. Dkt. No. 88. On August 7, 2025, Judge Broderick issued an amended order referring Plaintiff’s renewed motion for preliminary injunction to this Court for a report and recommendation. Dkt. No.

127. On January 21, 2026, this Court held a hearing on Plaintiff’s motion for a preliminary injunction.

3 B. Factual background3 2F Plaintiff operates a mobile gaming platform called Skillz, which was founded in October 2012 in Boston, Massachusetts. Am. Compl. ¶ 70. Skillz’s gaming applications are available for free download on the Apple Store, the Samsung Galaxy Store, and the Google Play Store. Am. Compl. ¶ 84; First Chafkin Decl. ¶ 5. Skillz offers hundreds of games on its platform, including games where players can compete to win cash prizes. Am. Compl. ¶¶ 88, 93; First Chafkin Decl. ¶ 5. The Skillz platform enables third-party developers to match human users in head-to-head competitions and bracketed tournaments based on their relative skill

level so that players of the same skill level play against each other. Am. Compl. ¶¶ 85–86. Skillz uses algorithms to match players based on skill level and game history and does not use, operate, or enable computers or artificial competitors to compete in its cash games. Id. ¶¶ 92–93. Defendant Esport is a game developer that offers its games directly to end users through the Blitz Win Cash App (“Blitz App”). Williams Decl. ¶ 6. The Blitz App, which launched in mid-2021, is available on the App Store and Google Play

Store. Am. Compl. ¶ 38, Gordon Decl. ¶¶ 6, 12. On the Blitz App, players compete

3 Unless otherwise noted, the following description of the underlying facts relevant to the pending motion is drawn from (1) the parties' submissions in support of or in opposition to Plaintiff’s motion for a preliminary injunction, and (2) portions of the amended complaint which are assumed true for the purposes of this motion. References to these allegations should not be construed as a finding to their veracity.

4 in head-to-head matchups or in multi-player tournaments against others at similar skill levels, with the opportunity to win cash prizes. Gordon Decl. ¶¶ 4–6, Ex. C. Defendants Voodoo SAS, Esport Newco SAS, and Esport Newco US Corp. jointly

promote, operate, and own the Blitz App. Am. Compl. ¶ 16. The Blitz App’s pages on its website, the Apple App Store, and the Google Play Store describe the Blitz App as having “fair” and “skill-based” games that are played against “real players” with “no bots allowed.” Am. Compl. ¶¶ 1–2, 116–123. Defendants have used this language to advertise the Blitz App since at least April 2022. See Gordon Decl. ¶ 7, Ex. F. Plaintiff alleges that these advertisements are

false because Defendant uses bots in its gaming platforms. Am. Compl. ¶ 198. Plaintiff asserts that “[t]hrough its use of bots and false advertising,” Defendants are diverting users and revenue from Skillz and “stealing hundreds of millions of dollars” from consumers that play Defendants’ games. Dkt. No. 51 at 2. Plaintiff bases its allegations of Defendants’ bot use on “[a]t least one” of Defendants’ former employees who has confirmed Defendants’ use of bots in cash tournaments. Id. at 6; Am. Compl. ¶ 140.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Salinger v. Colting
607 F.3d 68 (Second Circuit, 2010)
Jackson Dairy, Inc. v. H. P. Hood & Sons, Inc.
596 F.2d 70 (Second Circuit, 1979)
Johnson & Johnson v. Carter-Wallace, Inc.
631 F.2d 186 (Second Circuit, 1980)
The Coca-Cola Company v. Tropicana Products, Inc.
690 F.2d 312 (Second Circuit, 1982)
Mazurek v. Armstrong
520 U.S. 968 (Supreme Court, 1997)
Markowitz Jewelry Co. v. Chapal/Zenray, Inc.
988 F. Supp. 404 (S.D. New York, 1997)
Gidatex, S.R.L. v. Campaniello Imports, Ltd.
13 F. Supp. 2d 417 (S.D. New York, 1998)
Marcy Playground, Inc. v. Capitol Records, Inc.
6 F. Supp. 2d 277 (S.D. New York, 1998)
USA Recycling, Inc. v. Town of Babylon
66 F.3d 1272 (Second Circuit, 1995)
State v. U.S. Dep't of Commerce
339 F. Supp. 3d 144 (S.D. Illinois, 2018)
Danone, Us, LLC v. Chobani, LLC
362 F. Supp. 3d 109 (S.D. Illinois, 2019)
Coscarelli v. Esquared Hospitality LLC
364 F. Supp. 3d 207 (S.D. Illinois, 2019)
Juicy Couture, Inc. v. Bella International Ltd.
930 F. Supp. 2d 489 (S.D. New York, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Skillz Platform Inc. v. Voodoo SAS, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/skillz-platform-inc-v-voodoo-sas-et-al-nysd-2026.