Gala Coral Group Ltd, t/a Gala Bingo, (Gala Bingo) explained that the promotion offered to credit customers' accounts with a bonus of up to £10, depending on the size of their initial deposit, which would be released upon completion of a "5x wagering requirement". The customer would therefore have to play through their deposit amount five times on the Alice's Wonderland game in order to obtain their bonus.

Gala Bingo stated that the promotional e-mail had been sent to a distribution list of currently registered players, most of whom would have received a similar sign-up bonus with wagering requirements when they first registered and would therefore be familiar with this kind of condition. They also believed that customers would understand that they had to play through their deposit a certain number of times from the wording of the ad, which said customers needed to "play" the game in order to "release [their] 100% bonus of up to £10".

Gala Bingo further stated that the e-mail contained numerous links, including the "PLAY NOW" button, which took players directly to a "splash page" detailing full terms and conditions for the promotion. They acknowledged that customers who received the e-mail would be able to participate in the promotion without clicking through to the terms and conditions page, but believed it was unlikely anyone would do so given the prominence of the links. They said a total of 809 players had taken up the offer and they had not received any other complaints that the ad was misleading. They stressed that they did not intend to mislead their customers, but felt that their approach of having full terms and conditions "one click away" from the initial ad was in line with standard industry practice and provided sufficient clarity to comply with the advertising codes.