Author Avatar



Share post:

Avazoo is a gambling MLM company. Chairman Hans Reinisch is in charge.

Reinisch is depicted on Avazoo’s website by what appears to be an old photo of him with Jay Leno.

This struck me as unusual.

Reinisch lives in Florida, according to his LinkedIn profile. He claims to have been involved with Avazoo since 2012.

At the time of writing, Avazoo’s official YouTube channel had sixty videos. None of the titles mention Hans Reinisch.

This also struck me as weird, given that he is promoted as the face of Avazoo.

“Company Update,” a new video uploaded to Avazoo’s channel, attracted my attention.

The video lasted about a half-hour. I queued it up since I didn’t want to risk updates outdating my review as soon as it was published.

The video’s description:

“Avazoo Founder & COO Dave Cutler will be Live at 8:00 PM New York Time (EST) with the Company Update, giving essential and critical updates about Avazoo”.

Hmm. That’s not Hans Reinisch.

So, who is Dave Cutler?

Cutler is the CEO of AppTech Gateway and lives in Las Vegas, Nevada.

The FTC sued David G. Cutler in 2004 for conducting an “illegal business fraud.”

One of the companies implicated in the plan, B&C Ventures, Inc., was situated in Nevada.

That alone isn’t enough to corroborate that this was Avazoo co-founder Dave Cutler.

In addition to Cutler, the FTC sued Cindy Gannon, Paul D. Bonnallie, Tisa Christiana Spraul, and Michael J. Hatch.

Paul Bonnallie appears in a shot with Cutler in a $300 Avazoo advertisement in Black Tie Magazine:

Tisa Christiana Spraul leads Avazoo’s Global Operations:

I could not confirm whether Cindy Gannon or Michael Hatch are associated with Avazoo.

However, three of the five defendants who the FTC sued for fraud in 2004 are implicated.

They’re back!

I’m not sure how much genuine participation Hans Reinisch has in Avazoo. On the surface, he looks to be little more than a token CEO for Avazoo’s website.

Stay tuned for a comprehensive assessment of Avazoo’s MLM opportunity.

Avazoo’s Products

Avazoo has no retailable products or services.

Affiliates can only promote Avazoo affiliate membership.

Compensation Plan

Avazoo sells tickets to a rumored $1 billion lottery.

There are 50 million tickets available, with prices ranging from $20 to $100.

  • Beginner – 5 million tickets for $20 each;
  • Associate – 5 million tickets sold in lots of three for $50 each;
  • VIP – no ticket limit beyond the hard 50 million ticket cap, sold in bundles of ten for $100 each;
  • Syndicate – $1500 for one entry, with three extra entries for each affiliate recruited within ten days of purchase (note that any winnings over $2500 are split among the syndicate);
  • Corporate – $2500 for one entry, plus two more entries for each affiliate recruited within ten days of purchase (limited to 250 recruits, and any winners over $25,000 are split among all Corporate group members).

To keep their place, they must retain a total of 100 free tickets.

Lottery Winnings

Avazoo claims to be offering a 100 million-dollar lottery prize, which will be paid out to a single winning ticket.

The affiliate who recruited the affiliate who holds the ticket also receives $100 million.

There are also a total of one hundred $1 million second prize draws. The referring affiliates of the winning second prize draw each receives $100,000.

Monthly Prizes Associates and higher Avazoo affiliate tiers are eligible for “monthly bonuses prizes.”

Avazoo’s website features a page dedicated to monthly bonuses and awards, but no specifics are provided.

It’s unclear whether Avazoo has awarded any monthly bonuses since introducing its lottery in late 2020.

Referral Commissions

Avazoo pays referral commissions on ticket sales down two tiers of recruitment (unilevel):

  • level 1 (personally recruited affiliates) – 10%;
  • level 2 – 5%.

If an Avazoo affiliate does not have a referring affiliate, they are assigned to an existing MLM commission qualifying affiliate for a 10% commission.

Virtual Shares

If an Avazoo affiliate is and remains qualified for MLM commission, they will receive a virtual share every two weeks.

There is no information about Avazoo’s virtual shares.

Joining Avazoo Avazoo affiliate membership is linked to a $20 to $2500 lottery ticket purchase.

Summing Up

In 2006, David G. Cutler, Paul D. Bonnallie, and Tisa Christiana Spraul settled the FTC’s fraud accusations against them.

False business opportunity promoters have gone out of business.

Consumers were duped out of tens of thousands of dollars by the group.

The order released today enters a $15 million judgment against the business defendants, who have few surviving assets. Their remaining assets, however, will be turned over to the FTC.

The orders for each individual defendant also include a $15 million judgment against each person, which is suspended due to their incapacity to pay.

The settlements forbid the defendants from breaching the FTC Act, the Franchise Rule, and the Do Not Call sections of the Telemarketing Sales Rule.

To be clear, a fraud settlement order granted in 2006 does not inherently imply that Avazoo is a hoax.

Avazoo is a sham since it is an unlawful lottery packaged in a pyramid scheme.

We’ll start with Avazoo’s pyramid scheme component because it’s the most obvious.

Avazoo is a pyramid scheme since everyone is an affiliate and has access to the compensation plan.

Now let’s go on…

Avazoo makes a big fuss about its lottery being illegal.

Avazoo’s Billion Dollar Raffle IS LEGAL AND REAL! It is an event for which Avazoo’s founders have labored tirelessly for over a decade.

Avazoo’s legal assertions about its lottery are based on the fact that it is registered with the Cagayan Economic Zone Authority (CEZA).

To that aim, an April 2021 CEZA “interactive gaming license” certificate for NCGAC Limited is provided.

The Cagayan Economic Zone is located in the Philippines. You can obtain a CEZA license by incorporating a shell business and paying a fee.

That is fantastic news for the Philippines. It has no bearing on Avazoo’s legality in the United States.

Alexa currently ranks the United States as the third highest source of traffic to Avazoo’s website (16 %).

Avazoo is unlawfully operating a foreign lottery from within the United States, which is advertised to US residents.

Selling international lottery tickets to US residents is prohibited in and of itself.

Avazoo likewise claims legitimacy on the back of nameless firms, in a typical form of “legitimacy via association.”

Large Corporations are enthusiastically embracing the concept!

Look at this:

“We are delighted to welcome a plethora of organizations who have decided to be affiliated with the world’s first Billion Dollar Raffle as sponsors, advertising, or co-branding partners.

Soon, you’ll see their logos on our print ads, website, and joint TV commercials. Keep an eye out for them and check out their high-quality products and services.

We offer this support because we want you to understand that the majority of these significant corporations conduct extensive research before committing to and being affiliated with a very visible event like ours”.

The fact that they have done extensive due diligence and are confident that the organization and program are completely legitimate illustrates how genuine Avazoo is.

You may be confident that these firms work hard to defend their reputations by refusing to endorse any scams.

Major firms would not invest their advertising and marketing dollars in something that is not genuine, legal, and safe for consumers.

This should set your mind at ease concerning the legitimacy of Avazoo’s Billion Dollar Raffle.

Avazoo is a scam that operates an unlawful lottery and a pyramid scheme in the United States. 

Legitimacy through affiliation does not exist.

Then there’s the arithmetic underlying Avazoo’s lottery.

Avazoo claims to have sold a hard cap of 50 million paid tickets. The most costly ticket choice on Avazoo is $20 per ticket, for a total of $1,000,000,000. Remember that this sum will really be lower when the more expensive affiliate tiers are taken into account.

Based on the assumption that affiliates have a “one-in-three” chance of winning, here is Avazoo’s overall lottery payout structure:

When we combine all of the winners and payouts together, we get 17,262,118 winners and $1,450,416,670 ($1.4 billion).

And Avazoo predicts that every twelfth lottery will pay out $5 billion on the same ticket sales.

Where is this money coming from?!

In terms of the 1:3 odds of winning…

Nothing compares to what Avazoo has to offer in terms of lotteries around the world:

“Not only are we awarding the highest lump sum prize in history, but we have also devised a method to ensure that one out of every three persons will receive a cash prize!”

Avazoo posted the first video to their official YouTube account on December 9th, 2020, titled “Avazoo – The Billion Dollar Raffle Launches 2021.”

Over a year later, not a single draw has taken place.

Why? Because Avazoo claims it will not run its billion-dollar raffle until all fifty million available purchased tickets are sold.

Remember that “business update” video with Dave Cutler I mentioned at the start to this review?

In that video, Cutler indicates that he and Avazoo have or plan to join the MLM crypto bandwagon.

It’s as simple as tying useless NFTs to each ticket sale and promising riches.

Dave Cutler: “Tickets will be released in the form of an NFT beginning next week, one week today (March 29th).

Many individuals will benefit from it. If you know anything about these NFTs and what they can do for you financially, you’ll get it quickly”.

Cutler fails to tell that by issuing the NFTs, Avazoo receives a perpetual portion of any sales. It’s a low-cost moneymaker for Avazoo corporate.

Avazoo associates can put their face on their minted NFT for $100 more than the cost of a ticket.

Sounds like a terrific way to make an already worthless NFT even more worthless.

A permanent injunction was obtained as part of Dave Cutler, Paul Bonnallie, and Tisa Spraul’s 2006 FTC settlement. The order clearly prevents the three from committing any other violations of the FTC Act.

I’d argue that Avazoo’s numerous false marketing statements violate the FTC Act, wouldn’t you? 

The final degree of fraud that I haven’t discussed is Avazoo’s offered shares.

This is taken exactly from a corporate Avazoo webinar conducted by Kellie Felgate on March 29, 2021.

[21:13] “To earn commissions, you will need 400 free admissions and three ticket sales. In addition, you will earn a corporate stake.

If you have 400 free entry and three ticket sales, you will receive one company share every two weeks”.

Felgate does not go into any greater detail. Regardless, the sale of shares (virtual or otherwise) through an MLM organization constitutes a securities offering.

At the time of publishing, neither Avazoo nor Dave Cutler were registered with the SEC.

This indicates that Avazoo is committing securities fraud through its share offering on top of everything else.

FTC Act violations, lottery fraud, and securities fraud On US citizens, serial FTC Act violators are committing fraud.

Yeah, this isn’t going to end well.

iKapitol Review: Is A Fraud
Attiora Review: Is A Fraud

Leave a Comment

Your email address will not be published. Required fields are marked *