Lopoca Gaming Ltd., a company founded in Malta on June 15, 2010, operates as a subsidiary of Cyprus-registered Lopoca Ltd. The company's website lists a Malta address, aligning with a Malta Gaming Authority (MGA) license, MGA/CL3/709/2010. However, the exact operational base remains unclear.

The website domain, "lopoca.com," was registered on March 20, 2010, listing Klaus Saurugger of Lopoca LTD as the owner. While a Cyprus address is provided, investigations reveal it belongs to FiduciTrust Services, a firm offering mail forwarding. This suggests Lopoca lacks a physical presence in Cyprus.

Saurugger identifies himself as Lopoca's CEO in affiliate newsletters. His LinkedIn profile places him in Malta, consistent with the MGA license. Saurugger's prior experience includes telecommunications and insurance, with no apparent background in multi-level marketing (MLM) before Lopoca. This marks Lopoca as his first executive venture in the MLM sector.

Lopoca presents itself as an online gaming company. It offers casino games, sports betting, an "IQ Game," and a "Nugget Game" involving virtual share trading. The casino and sports betting platforms function as standard offerings.

The Nugget Game is described on the Lopoca website as a "totally unique, Maltese Gaming License Sanctioned game." It involves members and players trading "Nuggets" on an internal "Nugget Market." The MGA license, however, covers gaming operations, not the legality or structure of an investment or MLM scheme. The internal trading of virtual shares, without external market value or clear underlying assets, raises questions about its true nature. Such systems often rely on new participant funds to pay off earlier ones.

The IQ Game requires affiliates to purchase access weekly for €10 to qualify for commissions. All other games are available to retail customers, but the IQ Game acts as a mandatory internal purchase for those seeking to earn from the compensation plan.

Lopoca's compensation plan pays affiliates for signing up and spending money on gaming services. It also pays commissions for recruiting new affiliates. Retail activity, where non-affiliates use Lopoca games, also generates payouts.

To qualify for MLM commissions, Lopoca affiliates must generate at least one "residual commission point" each week. Lopoca's compensation plan materials state this is "most easily accomplished by purchasing a (IQ) voucher" weekly. This links commission eligibility directly to an ongoing internal purchase rather than genuine retail sales or profit from external gaming activity.

Affiliates also need to register a single "qualified partner" in both their left and right teams. This partner must also meet commission qualification requirements, effectively mandating recruitment and replication of the IQ voucher purchase. This structure places emphasis on continuous internal spending and recruitment for commission eligibility.

The reliance on weekly internal purchases for commission qualification, combined with a "Nugget Game" that involves members trading virtual shares on an internal market, mirrors characteristics of pyramid and Ponzi schemes. In these models, new money from participants funds payouts to earlier participants, with little to no external value generation. Participants face significant risk of capital loss when recruitment slows or the internal market collapses.