Mr. Derek Donohoe:

Prize Ducks is what is known as an instant win game. It is played online. Risk assessment was done, it was considered with regard to its possible appeal to children and, on balance, it was approved. Importantly, no branding was associated with that which would be recognisable to children. For example, if a children's character was associated with it, it is unlikely it would have been approved, but because "prize ducks" is a generic term and was not of particular relevance or appeal to children, it was approved by the previous regulator.