No. The obligated party is the public business entity Loterías y Apuestas del Estado,which is the person responsible for the management, exploitation and marketing of the lottery game (paragraph u) of article 2.1), regarding the operations of payment of prizes.

Section 2 of article 2.1 is applicable, which states that "the obligated parties are also subject to the obligations established in it with respect to the operations they carry out through agents or other persons acting as mediators or intermediaries of them".

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