Churchill Downs Business Model Canvas
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Unlock the strategic blueprint behind Churchill Downs with our Business Model Canvas. This concise, actionable analysis reveals value propositions, revenue streams, partnerships and growth levers to inform investors, strategists, and operators. Download the full Word/Excel canvas to benchmark and adapt its winning model.
Partnerships
Partnerships with state racing commissions and horsemen’s groups enable Churchill Downs’ licensed racing and pari-mutuel operations, setting purse structures and calendars that supported a Kentucky Derby that in 2024 drew over 150,000 spectators and produced a multi‑hundred‑million‑dollar all‑sources handle.
Deals with TV networks, streaming platforms and data distributors extend event reach and monetization. Broadcast rights amplify the Kentucky Derby brand globally; Derby record attendance of 170,513 in 2015 underscores scale. Content syndication fuels wagering interest and sponsorship value, while cross-promotion drives traffic to TwinSpires, launched in 2007, and on-site venues.
Partnerships with betting engines, risk management, geolocation, KYC/AML, payments, and cybersecurity vendors power Churchill Downs digital wagering, ensuring compliant, secure bets. Scalable cloud and data partners support peak Derby and sports calendars and enable rapid scaling during high-handle events. Vendor ecosystems accelerate feature rollout and timely compliance updates, while reliability and high uptime underpin customer trust and platform availability.
Payment, affiliates & marketing
Property, hospitality & suppliers
Local governments, developers, and suppliers underpin Churchill Downs expansions and daily operations, with strong community ties facilitating permitting and workforce sourcing; the Kentucky Derby alone draws about 150,000 attendees, amplifying demand for premium hospitality and events. Hospitality partners elevate premium experiences and conferences, while food, beverage, and gaming equipment vendors ensure consistent service quality and regulatory compliance.
Strategic partnerships with racing commissions, broadcasters, wagering tech, payments and local developers enable licensed racing, global distribution, secure digital wagering and on-site hospitality; the 2024 Kentucky Derby drew over 150,000 spectators and generated a multi‑hundred‑million‑dollar all‑sources handle.
| Partner Type | Role | 2024 Metric |
|---|---|---|
| Racing commissions | Licensing, purses, calendars | Derby attendance >150,000 |
| Broadcasters | Global reach, sponsorship | All-sources handle >$200M |
| Wagering vendors | Risk, KYC, platform | TwinSpires launched 2007 |
What is included in the product
A concise, pre-written Business Model Canvas for Churchill Downs that maps customer segments, channels, value propositions, revenue streams and cost structure to reflect racetrack, wagering, media and hospitality operations. Ideal for presentations and investor discussions, it includes competitive advantages, SWOT-linked insights and practical validation using real-world company data.
High-level, editable Business Model Canvas that relieves the pain of fragmented strategic planning by consolidating Churchill Downs' racing, betting, hospitality, media and real-estate revenue streams into a single, shareable one-page snapshot for faster decisions and team alignment.
Activities
Plan, schedule and execute live race meets anchored by the Kentucky Derby, which typically draws about 150,000 spectators and drives more than $200 million in total wagering; manage racing surfaces, entries and officiating to meet integrity and safety standards. Deliver on-site guest services, security and concessions across venues. Coordinate sponsors, media and hospitality to monetize marquee exposure and partner activations.
Run and maintain TwinSpires pari-mutuel, online sports betting and iCasino operations, supporting the platform that contributed to Churchill Downs Incorporated’s reported $1.95 billion in 2023 revenue. Oversee odds, liquidity and product UX to optimize handle and retention while ensuring real-time data delivery and a 99.9% production availability target. Handle KYC, payments and responsible gaming workflows processing millions of transactions annually to meet regulatory and AML standards.
Operate slots, table games and historical racing machines across Churchill Downs venues under state rules while leveraging the 150th Kentucky Derby (2024) as a flagship demand driver. Drive same-store growth through targeted promotions and loyalty programs to boost visit frequency and spend. Continuously optimize floor mix, hosts and amenities to lift per-visitor yield. Maintain robust surveillance, cage operations and compliance frameworks to meet regulatory standards.
Regulatory, compliance & licensing
Secure and renew racing, gaming and online licenses across jurisdictions, maintain AML, RG and cybersecurity programs, report taxes and manage audits, and engage regulators and policymakers proactively to protect operating permits and integrity of wagering operations.
- Licensing: multi-jurisdiction renewals
- Compliance: AML, RG, cyber programs
- Finance: tax reporting & audits
- Advocacy: regulator & policymaker engagement
Marketing, analytics & expansion
Churchill Downs drives customer acquisition and retention through omnichannel marketing while using data science for segmentation, targeted bonusing, and dynamic pricing to lift handle and ADR; 2024 revenue reached about $1.84B, funding upgrades and market entries.
The company invests in property upgrades, new-market expansion, and pursues M&A and partnerships to scale operations and cross-sell gaming, racing, and media.
- Omnichannel acquisition/retention
- Data-driven segmentation, bonusing, pricing
- Property upgrades & new markets
- M&A and partnerships to scale
Plan and stage live racing (Kentucky Derby ~150,000 attendees; >$200M Derby wagering) while managing surfaces, entries and officiating for safety and integrity.
Operate TwinSpires digital wagering and iCasino supporting CDI’s reported ~$1.84B 2024 revenue; target 99.9% platform availability and real-time data.
Run casinos, hospitality and loyalty to drive per-visitor yield and pursue M&A, property upgrades and market entries.
| Metric | 2024 / Note |
|---|---|
| Derby attendance | ~150,000 |
| Derby wagering | >$200M |
| CDI revenue | ~$1.84B (2024) |
| Platform availability | 99.9% target |
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Business Model Canvas
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Resources
Founded in 1875 and held each year on the first Saturday in May, the Kentucky Derby is an iconic global sports brand that enables premium pricing and high-value sponsorships for Churchill Downs Incorporated (ticker CHDN). Proprietary marks, broadcast and media rights provide defensible, monetizable IP. The Derby anchors annual customer acquisition and concentrated media attention. It differentiates and uplifts the broader venue, wagering and hospitality portfolio.
Tracks, casinos and historical racing machine facilities operated under state licenses form Churchill Downs' core operating assets, underpinning wagering and gaming revenue; Kentucky Derby weekend draws roughly 150,000 on-site attendees and generates over $300 million in betting handle (2024). Physical footprints in strategic regional markets deliver recurring cash flow from racing, gaming and hospitality. Zoning, permitting and community goodwill create material barriers to entry for competitors. On-site capacity supports large-scale events, premium suites and integrated hospitality revenue streams.
TwinSpires tech stack, mobile apps, and trading systems enable scale by processing millions of wagers with enterprise-grade infrastructure. Customer, wagering, and event datasets power personalized experiences and targeted promotions across channels. Real-time feeds and risk tools maintain integrity and high availability for live racing. Advanced analytics convert behavioral and wagering insights into measurable revenue growth.
Regulatory relationships
Longstanding ties with state racing commissions and legislators give Churchill Downs stability and access to licensing pathways. A robust compliance record across racing and interactive wagering builds regulatory trust and minimizes enforcement risk. Diversified multi-jurisdictional licensing spreads regulatory exposure while active policy engagement helps shape favorable frameworks for pari-mutuel and online betting.
- Regulatory relationships: stability
- Compliance record: trust
- Multi-state licenses: risk diversification
- Policy engagement: influence
People & operations know-how
Racing officials, traders, marketers and property teams operate integrated, high-stakes events and wagering platforms that enable Churchill Downs to run complex daily and marquee meet operations; event production expertise delivers the world-class experiences showcased at the 150th Kentucky Derby (May 4, 2024). Hosts and VIP teams deepen high-value customer relationships while in-house project and construction skills support venue expansions and capital projects.
- Teams: racing, wagering, marketing, property
- Flagship: 150th Kentucky Derby, May 4, 2024
- Capabilities: event production, VIP hospitality, project/construction
Iconic Kentucky Derby brand (150th run May 4, 2024) enables premium pricing, sponsorships and global media rights.
Physical assets—tracks, casinos, HRMs—drive recurring cash flow; Derby weekend draws ~150,000 onsite and ~$300M betting handle (2024).
TwinSpires tech and data scale wagering operations, real‑time risk tools and personalized marketing to boost revenue.
| Metric | 2024 |
|---|---|
| Derby attendance | ~150,000 |
| Derby betting handle | $300M |
Value Propositions
The Kentucky Derby, marked by its 150th running in 2024, delivers a once-in-a-lifetime live and broadcast spectacle that anchors Churchill Downs’ marquee racing experiences. Premium hospitality and a century-plus heritage attract high-value fans and sponsors, boosting sponsorship and VIP revenue streams. Rich storytelling and tradition deepen emotional connections across generations. This flagship event elevates the prestige of the broader Churchill Downs portfolio.
Customers receive secure, regulated wagering across horse racing, sports, and casino, leveraging compliance as sports betting expands to 36 states in 2024. Transparent operations and responsible‑gaming tools increase confidence among users. Fast payments and reliable uptime drive satisfaction and retention. Churchill Downs’ heritage since 1875 lowers perceived risk through strong brand reputation.
Seamless movement between Churchill Downs venues and apps increases convenience, with mobile accounting for over 80% of digital wagers in 2024. Unified accounts, rewards, and promos drive engagement and retention, as omnichannel customers deliver roughly 2x higher lifetime value per 2024 industry data. Customers can play, watch, and bet anywhere legal, and cross-sell between racing, casino, and sports boosts ARPU and frequency.
Local convenience & amenities
Casinos and HRM properties around Churchill Downs deliver nearby dining, entertainment, and promotional offers that drive foot traffic and ancillary spend.
Floor mix and event programming are tailored to local demographics, with loyalty perks and dedicated hosts personalizing visits to increase dwell time and repeat trips.
Clean, secure facilities and targeted promotions encourage higher visit frequency and local market retention.
- Local entertainment & dining
- Tailored floor mix & events
- Loyalty perks & host services
- Safe, clean environments
Exclusive content & access
Proprietary racing content and the 150th Kentucky Derby in 2024 create scarcity for Churchill Downs’ Derby-week events, driving premium pricing for experiences. VIP packages and behind-the-scenes access deliver status signals to high-net-worth attendees and corporate clients. National media partnerships extend reach with curated experiences, while sponsors secure high-visibility platforms tied to marquee moments and large live audiences.
- Scarcity: 150th Kentucky Derby 2024
- Status: premium VIP/behind-the-scenes access
- Reach: national media partnerships
- Sponsors: high-visibility event platforms
The 150th Kentucky Derby in 2024 anchors premium live/broadcast experiences, driving sponsorship and VIP revenue. Secure, regulated wagering across 36 states (2024) and >80% mobile digital wagers boost retention and ARPU. Omnichannel accounts deliver ~2x higher LTV. Casinos/HRMs increase ancillary spend via tailored events and loyalty.
| Metric | 2024 |
|---|---|
| Kentucky Derby | 150th |
| States with legal sports betting | 36 |
| Mobile digital wagers | >80% |
| Omnichannel LTV | ~2x |
Customer Relationships
Churchill Downs Incorporated leverages integrated loyalty links between on-site experiences and TwinSpires online wagering to drive cross-channel engagement. Tiered benefits boost frequency and wallet share by rewarding higher spenders. Targeted offers use behavioral and transaction data to personalize promotions. Visible status recognition (VIP tiers) increases retention among frequent bettors.
VIP hosts and concierge at Churchill Downs deliver personal service and priority event access for high-value patrons, notably during the 150th running of the Kentucky Derby in 2024 when on-site demand peaked above 150,000 attendees.
Hosts customize comps, travel, and premium floor experiences to individual preferences, driving higher spend per capita and repeat visitation.
Deep relationships reduce churn and stimulate word-of-mouth that attracts similar high-net-worth segments to premium packages.
In-app help, FAQs and chat streamline issue resolution for Churchill Downs, supporting its growing digital wagering business and contributing to online handle growth (digital handle reached over $5.0B in recent years). Account tools for deposits, limits and preferences reduce manual work; automation can lower cost-to-serve by ~25% and speed improves NPS by roughly 8–12 points.
Responsible gaming engagement
Responsible gaming engagement at Churchill Downs emphasizes proactive tools and education to build trust, with accessible limits, timeouts and self-exclusion options for customers. Continuous monitoring flags risky behavior for timely intervention, and 2024 compliance measures align with evolving regulator standards and public expectations.
- Proactive RG tools
- Accessible limits/timeouts/self-exclusion
- Behavioral monitoring
- 2024-aligned compliance
Community & event engagement
Local sponsorships and charity initiatives by Churchill Downs, highlighted during the 150th Kentucky Derby in 2024, reinforce goodwill in Louisville and beyond and help preserve favorable community licensing relationships.
Derby festivals and fan activations draw roughly 150,000 annual attendees, social content drives year-round digital engagement, and community ties underpin stable local support for racetrack operations.
- Goodwill: local sponsorships, charity partnerships
- Affinity: 150,000 Derby attendees (2024)
- Engagement: year-round social content
- Stability: community support for licensing
Churchill Downs blends loyalty, VIP concierge and targeted digital offers to deepen retention and increase spend; 150th Derby drew ~150,000 attendees (2024) and digital handle exceeded $5.0B. Automation cuts cost-to-serve ~25% and faster support can lift NPS 8–12 pts. Proactive RG tools and 2024-aligned compliance reduce regulatory risk.
| Metric | Value |
|---|---|
| Derby attendance (2024) | ~150,000 |
| Digital handle | >$5.0B |
| Cost-to-serve reduction (automation) | ~25% |
| NPS lift (faster support) | 8–12 pts |
Channels
Race tracks, casinos, and hotel/restaurant/meeting facilities deliver direct, in-person experiences that drive spend and dwell time. On-site signage and dedicated hosts actively cross-sell wagering, gaming, and F&B, increasing per-guest revenue. Events funnel attendees into loyalty programs and digital channels, boosting repeat visitation. Physical presence across flagship venues reinforces Churchill Downs brand and local market dominance.
TwinSpires and related apps are Churchill Downs’ primary wagering touchpoints, with the TwinSpires app exceeding 1 million downloads and accounting for the bulk of digital ADW activity. Responsive web platforms support discovery, live streaming and account management across devices. Push notifications, email campaigns and personalized homepage modules drive repeat bets and higher lifetime value. Digital channels scale efficiently across state markets and racing jurisdictions.
TV and OTT partners distribute live races and features, with Derby coverage reaching over 10 million viewers and acting as a mass acquisition channel that drove weekend attendance near 150,000 and wagering handle exceeding $400M. Shoulder programming (preps, replays, analysis) sustains year‑round engagement and boosts monthly digital active users. Integrated calls‑to‑action across broadcasts and streams funnel viewers directly to wagering platforms, increasing conversion and handle per user.
Affiliates & partners
Affiliate networks, media buyers, and influencers extend Churchill Downs reach beyond racing fans; affiliates accounted for roughly 16% of e-commerce orders in 2024 (Awin), boosting ticketing and betting lead gen. Performance-based partnerships can reduce CAC by up to 30% versus fixed buys, while co-branded campaigns tap partner audiences for higher conversion and retail co-promotions typically lift local foot traffic by ~10–15%.
- affiliate: 16% e‑commerce share (2024)
- performance: CAC down ~30%
- co‑brand: higher conversion
- retail promos: +10–15% local traffic
Social & CRM
Always-on content builds community and education around racing and wagering, driving year-round TwinSpires consideration; lifecycle email/SMS programs target retention and reactivation with 2024-average email open rates ~21% and SMS CTRs ~7%. Segmentation tailors offers and timing to customer value cohorts; social engagement amplifies brand storytelling and event-driven spikes (Derby/Casino promos).
- Always-on content: community + education
- Lifecycle email/SMS: retention/reactivation (email ≈21%, SMS CTR ≈7%)
- Segmentation: personalized offers/timing
- Social: storytelling and event amplification
On-site venues drive spend and cross-sell, boosting per-guest revenue and repeat visits. TwinSpires app (≈1M+ downloads) and web platforms supply core ADW volume and efficient digital scaling. Derby/TV reach (~10M viewers) fuels attendance (~150k) and peak handle (~$400M). Affiliates (16% e‑commerce), CAC down ~30%, email open ≈21%, SMS CTR ≈7%.
| Channel | 2024 KPI |
|---|---|
| TwinSpires app | ≈1M+ downloads |
| Derby/TV | ~10M viewers; attendance ~150k; handle ~$400M |
| Affiliates | 16% e‑commerce |
| Marketing | CAC −30%; email open 21%; SMS CTR 7% |
Customer Segments
Core pari-mutuel bettors engage year-round, supporting Churchill Downs Incorporated’s annual wagering ecosystem while valuing deep handicapping data, live streams, and promotions; CDI reported approximately $2.1 billion in revenue in 2024. The Kentucky Derby funnels casual fans—150,000+ on-site in 2024 and roughly 16 million TV viewers—into digital channels. Targeted education and onboarding convert newcomers into repeat bettors through guided content and promo offers.
Sports bettors: legal-market fans seek competitive odds and deep markets; US legal sports-betting handle exceeded $100B in 2024, underscoring market scale. Live/in-play wagering and targeted promotions drive frequency and retention. Cross-sell from racing (TwinSpires) reduces acquisition costs versus pure-play apps. Fast payments and platform trust are decisive for lifetime value.
Local and regional gamers prize convenience and comps, driving repeat visits and on-property spend; Churchill Downs drew about 156,653 attendees for the 2024 Kentucky Derby, reflecting strong local/regional engagement. Expanded entertainment, dining, and events broaden appeal beyond gamblers to casual visitors. Dedicated hosts and tiered rewards measurably increase wallet share for high-value players, while safety and service remain non-negotiable baseline expectations.
Sponsors & advertisers
Sponsors buy access to Derby audiences and premium hospitality, linking brands to the 150th Kentucky Derby in 2024 which drew 150,000+ on-site fans and 10M+ TV/stream viewers. They value measurable reach and heritage association; custom activations and hospitality packages drive clear ROI. Multi-year deals provide revenue stability and deeper consumer data access.
- Audience: 150,000+ on-site (2024)
- Reach: 10M+ TV/stream viewers (2024)
- Value: heritage association + measurable activations
- Structure: custom activations, multi-year deals for stability
Horse owners, trainers, breeders
Horse owners, trainers and breeders require fair purses, consistent calendars and quality surfaces to race; they supply Churchill Downs with the horses and prestige that drive product value. Strong owner/trainer relationships deepen fields and increase betting interest; the 150th Kentucky Derby in 2024 carried a $3 million purse, underlining purse importance.
- Industry role: owners/trainers/breeders supply racing product
- Key needs: fair purses, safe surfaces, reliable calendars
- Impact: stronger fields boost fan engagement and handle
Core pari-mutuel bettors sustain year-round wagering; CDI reported ~$2.1B revenue in 2024. Kentucky Derby drives mass reach with 150,000+ on-site and ~16M TV/stream viewers in 2024, converting casual fans to digital channels. Sports bettors tap legal-market liquidity (US handle >$100B in 2024); owners/trainers demand fair purses (Derby purse $3M) and reliable calendars.
| Segment | 2024 Metric | Value |
|---|---|---|
| CDI Revenue | Annual | $2.1B |
| Derby Reach | On-site / Viewers | 150,000+ / ~16M |
| Sports Betting | US Handle | >$100B |
| Derby Purse | Top Race | $3M |
Cost Structure
Purse contributions and staff wages represent the largest recurring expenditures, driven by guaranteed purses for stakes races and base salaries for racing, hospitality, and track crews. Event operations, security, and licensed racing officials add significant per-event costs, rising with field sizes and night cards. Hosts and customer service staffing scale with attendance and simulcast activity, while efficient scheduling and cross-training reduce overtime and temporary labor premiums.
State gaming taxes, pari-mutuel commissions and license fees are significant cost drivers for Churchill Downs; in 2024 state gaming taxes commonly ranged 20–50% of gross gaming revenue while pari-mutuel commission schedules and licensing levies further compress margins. Compliance reporting and audit requirements add measurable overhead in staffing and systems. Jurisdictional variance materially affects EBITDA by jurisdiction. Active tax planning and gaming-mix management are therefore critical to margin preservation.
Platform development, cloud, and cybersecurity consumed significant capital in 2024, with Churchill Downs Incorporated allocating roughly $120 million to technology and data-related CAPEX and IT operating expenses to support TwinSpires and wagering platforms.
Marketing & media
Acquisition, sponsorships, and affiliate payouts are ongoing cost lines for Churchill Downs, funding customer growth and partner revenue shares while remaining subject to ROI discipline.
Derby broadcast production is a substantial, peak-event expense; CRM and creative investments focus on retention and lifetime value.
- Acquisition: ongoing paid media and sponsorships
- Sponsorships: long-term partner commitments
- Affiliate payouts: performance-based
- Broadcast: peak Derby production costs
- CRM/creative: retention-focused
- Allocation: ROI-governed
Capex & maintenance
Capex and maintenance at Churchill Downs require material investment: venue upgrades, expansions and gaming equipment drove a company-guided 2024 capex program of about $200 million, while track surface renewals and facility upkeep remain recurring annual expenses. Regulatory-driven improvements (safety, ADA, wagering rules) can be mandatory and timing often aligns with major event cycles like the Kentucky Derby season.
- 2024 capex ~ $200M (company guidance)
- Recurring track/facility maintenance: annual spend
- Regulatory upgrades: mandatory timing/cost spikes
- Capex timing aligned to event cycles (Derby)
Purse payouts, wages, event operations and regulatory taxes drive most recurring costs; 2024 guidance showed ~200M capex and ~120M tech/IT spend. State gaming taxes commonly 20–50% of GGR and pari-mutuel fees materially compress margins, making tax planning and wagering mix critical. Acquisition, sponsorships, broadcast Derby production and maintenance add peak and variable expenses tied to attendance and racing calendar.
| Item | 2024/$ |
|---|---|
| Capex | ~200,000,000 |
| Tech/IT | ~120,000,000 |
| State gaming tax | 20–50% GGR |
Revenue Streams
Pari-mutuel takeout—commissions on wagering—constitutes Churchill Downs’ core revenue, with marquee events like the Kentucky Derby driving handle spikes that regularly surpass $100 million. Fixed fees from advance-deposit wagering platforms deliver predictable, recurring revenue that smooths seasonal volatility. Expanding international simulcast distribution broadens sources and captures offshore pool liquidity, enhancing overall takeout yield.
Slots, tables and historical racing machines deliver steady hold across Churchill Downs properties, with 2024 operations focusing on unit-level yield management to maximize win per device. Loyalty programs and targeted promotions increased visit frequency and wallet share through 2024 campaign metrics. Property mix and dynamic pricing optimize capacity and revenue per unit while cross-selling non-gaming spend—F&B, hotels and retail—boosts overall guest spend.
Net gaming revenue from sportsbook and iCasino provides high-growth upside for Churchill Downs, with online channels benefiting as sports betting became legal in 37 states by 2024. Bonuses and tight hold management directly shape margins and NGR per user. Cross-sell between racing, sportsbook and iCasino lowers blended CAC and increases LTV. Geographic expansion delivers scale as each new state adds incremental GGR and marketing efficiency.
Media rights & sponsorships
Broadcast deals and streaming licenses monetize Churchill Downs reach, with the 2024 Kentucky Derby telecast drawing about 16 million viewers, driving higher CPMs across linear and OTT platforms.
Derby sponsorships command premium rates, with marquee partners paying multi-million-dollar packages tied to on-site activation and exclusive categories in 2024.
Branded content and integrations expand inventory across race-day feed, social and in-venue screens, while multi-year media and sponsorship agreements smooth cash flows and reduce revenue volatility.
- 2024 TV audience ~16M
- Multi-million-dollar Derby sponsorships
- Streaming + OTT increase inventory
- Multi-year deals stabilize cash flow
Admissions, F&B & hospitality
Ticketing, suites and premium packages monetize live attendance—2024 Kentucky Derby drew over 150,000 attendees, concentrating high-yield ticket sales; suites and corporate packages command significant per-capita revenue. Food, beverage and merchandise add incremental margin by converting large crowds into repeat on-site spend. Special events and festivals expand calendar utilization beyond racing days. Corporate hospitality programs deepen B2B ties and drive recurring suite and event bookings.
Pari-mutuel takeout remains core, with Derby handle spikes >$100M and predictable ADW fees smoothing seasonality. Gaming (slots/tables/HRMs) and F&B/hospitality drive steady per-capita yield—Derby attendance >150,000 in 2024. Digital sports betting/iCasino supply high-growth NGR as sports betting legalized in 37 states by 2024; broadcast + sponsorships monetize audience (~16M TV viewers).
| Revenue Stream | 2024 Metric | Note |
|---|---|---|
| Pari-mutuel | Derby handle >$100M | Core takeout |
| Attendance | >150,000 | High per-capita spend |
| Broadcast/Sponsors | TV ~16M | Higher CPMs |
| Sportsbet/iCasino | Legal in 37 states | High NGR upside |