A platform that sells digital artwork with a promotional sweepstakes
Five minutes to walk through what the platform actually is and how it works.
Thank you for taking a moment to understand this platform before drawing conclusions. We recognize the City's concerns about a real problem in Kansas City — unregulated slot-style machines that have operated in gas stations and convenience stores for years — and we share those concerns.
This walkthrough is intended to show that the platform our company operates, kiosks.systems, is structurally different from the machines the City has acted against. We are not asking the Council to trust our characterization. We are asking the Council to see how the system actually works.
A retail platform selling AI-generated digital artwork, with a promotional sweepstakes attached — structurally similar to McDonald's Monopoly, Coca-Cola's "1-in-6 wins," or Publishers Clearing House.
A "no-chance" or "pre-reveal" machine. A slot machine simulator. A game of chance. A device that determines outcomes at the moment of play.
In this walkthrough:
We'll show you the product, walk through what happens at the moment of purchase, demonstrate how prize reveals work, and explain how our architecture differs from the machines addressed in Ordinance No. 250832.
The product: digital artwork
Customers buy digital art. Artwork is the product. The sweepstakes is a promotional bonus.
Our platform offers the Ute Heritage Artwork Collection — AI-generated digital illustrations in a curated indigenous-themed style. Each piece is a unique, certificate-numbered digital asset owned by the purchaser. Customers can keep their artwork, view it in a personal gallery, or resell it within the platform.
Actual catalog contains thousands of unique pieces across six price tiers.
Important factual point: The artwork is not a token or a stand-in for gambling value. It is an actual owned digital asset. Purchasers receive a certificate number, the image file, gallery access, and the right to keep or resell the piece. If the sweepstakes didn't exist, the artwork would still be a product customers could buy.
The purchase moment
This is the single most important distinction between our platform and the machines the Council has acted against.
When a customer completes a purchase, two things happen simultaneously:
- The customer receives ownership of the digital artwork they purchased.
- A predetermined number of sweepstakes entries are assigned to their account, each with a fixed prize value that is already decided.
The prize value for each entry is written to our database at that moment. It does not change. It cannot be affected by anything the player does afterwards.
The legal significance of this architecture:
In February 2026, U.S. District Judge John A. Ross ruled in TNT Amusements v. Torch Electronics that Torch's machines were illegal because they used a random number generator to introduce chance into the sequence of prizes. Our platform was designed specifically in response to that ruling. There is no random number generator in our reveal pathway. Prizes are bound before any player interaction. The player cannot affect the outcome because there is nothing left to affect.
Two ways to see your prize
Both produce the exact same outcome, because the outcome is already decided.
After purchase, customers can view their prize values in one of two ways. This choice was added specifically to make the pre-determined nature of the system visible to anyone.
You have 25 sweepstakes entries. How would you like to see your prizes?
Both buttons below reveal the prizes associated with these 25 entries. Because every prize is already decided in our database, both buttons yield identical results. Try them.
A customer who selects "Instant Reveal" sees their prizes in about two seconds. A customer who selects an animated reveal sees the same prizes over 30 seconds. The prizes are identical. The only difference is the presentation.
Watch a reveal play out
The prize is already decided. The game is just the animation showing you what you won.
Below is a simplified version of one of our reveal animations — "Plinko Drop." Before the chip falls, the prize is already locked in. The chip's path is guided to land in the correct slot. No random number generator runs during play.
What the player does: Watches. There is no input that affects the outcome.
What the system does: Reads the prize value that was written to the database at the moment of purchase, then guides the chip's animation to land in the slot matching that value.
How we differ from Torch-style machines
Direct comparison with the class of device the Council's ordinance targets.
Torch Electronics' machines were ruled illegal in February 2026 because they used a random number generator to determine the sequence of prizes available for reveal. Torch ceased operations in Missouri on April 10, 2026. Our platform's architecture is fundamentally different — and was designed that way on purpose.
| Feature | Torch-Style "No-Chance" Machine | kiosks.systems Platform |
|---|---|---|
| Primary product | Pretend "phone card" or nominal item. Value is in the gambling credit. | Digital artwork. Unique, certificate-numbered, ownable, transferable. Artwork has value independent of the sweepstakes. |
| When is the prize decided? | By a random number generator during play. Each spin could be anything until the RNG determines it. | At the moment of purchase. Written to the database before any play. Cannot be changed. |
| Random number generator at point of play? | Yes. This was the basis of the federal ruling. | No. Not in the reveal path. Not at all. |
| Game visuals | Video poker, keno, slots, blackjack — simulated casino games. | Coin Pusher, Plinko, Prize Wheel, scratch cards, gardens, treasure digs — family-friendly animations. |
| Can player skip the game? | No. The game is the mechanism. | Yes. "Instant Reveal" bypasses games entirely. |
| Device | Purpose-built gambling cabinet. | Web application. Runs in any browser. Same app works on the in-store kiosk, a home PC, or a phone. |
| Published odds? | No public disclosure. | Yes. Complete prize pool schedule published at kiosks.systems/rules. |
| Free entry option? | No. | Yes. One free entry per hour, identical odds to paid entries. |
| Audit trail? | Opaque. No regulator access. | Full audit trail. Every entry, every prize, every payout logged and available on request. |
We agree with the Council: devices that use random number generators to award cash prizes in convenience stores are a problem for Kansas City. The Council's concerns — community impact, exploitation of vulnerable residents, lack of regulation — are legitimate.
Our platform does not do any of those things. We were built to not do those things.
Compliance and consumer protection
The controls that are already in place today.
- Complete prize schedule published online
- Odds of winning disclosed per tier
- "Instant Reveal" makes pre-determination visible
- Official Rules linked on every screen
- Phone-verified accounts only
- Per-location compliance notices
- Clear signage: Law Enforcement info, Patent info
- Missouri RSMo Ch. 407 framework
- Every entry, prize, and ledger movement logged
- Append-only records; no delete pathway
- Open to regulator/law enforcement review
- Full source code available to counsel
- Pre-generated "books" of 20,000,000 entries
- Finite, disclosed prize pool per book
- Prize winners determined at book generation
- No dynamic prize creation possible
In closing
What we ask, and where to learn more.
We believe the Council's action against unregulated gaming machines was the right response to a real problem. Those machines harmed Kansas City residents, operated outside any oversight, and lacked even basic protections for consumers.
Our platform was designed to be different — not as a workaround, but because the gambling device model is the wrong model for a legitimate promotional sweepstakes. We operate a retail business that sells a real product, discloses its prize structure publicly, offers free participation, and is fully auditable.
We ask the Council and its advisors to examine our platform on its own terms rather than by association with the machines the ordinance was written to address. We believe that examination will show our platform does not fall within the scope of Section 50-16.
We welcome questions, site visits, technical review, and direct engagement with Council members and staff. The full platform is available for inspection at any time.
Thank you for taking the time to understand what our platform actually is.
We are committed to being good partners to the City of Kansas City, and to operating a platform that Kansas Citians — and their Council — can be comfortable with.