[tcfunk]

I think it's pretty easy to define, actually. Were they paid in some way to do those things? If yes, then it was advertising.

[mminer237]

It sounds like the most common way to do these things is to have one company operate one gambling and one non-gambling site and just tell people they operate the other site on each. No money's changing hands, so that's not advertising. Then you can advertise to go to your non-gambling site, and they can organically navigate to the gambling site which was disclosed, not advertised. You would almost have to ban companies which have any interest in a gambling product from advertising anything at all.

[Teever]

That sounds like a conspiracy and the penalties for conspiracy are much more severe than just illegal advertising.