Regulatory overview

I. Overall business structure

• A Missouri LLC will own and operate the kiosks.
• Each kiosk functions as a retail sales terminal for unique digital NFTs.
• A time-limited promotional sweepstakes (for example, 60–90 days) runs ancillary to NFT sales.
• All kiosks connect to a single centralized, U.S.-hosted secure server managing:
  • Sweepstakes prize pool
  • Entry records
  • Randomization
  • Audit logs
• The kiosk itself does not determine or store prize allocation logic.

II. NFT sales (primary business activity)

• Users purchase unique NFTs via touchscreen kiosk using fiat or cryptocurrency.
• NFTs are minted instantly and delivered to the user’s own wallet or a custodial wallet with appropriate disclosures.
• Purchase price is transparent.
• NFTs are owned outright and transferable.
• No representation is made regarding investment value or future profit.
• The NFT sale stands independently of the sweepstakes promotion.

III. Sweepstakes structure (ancillary promotion)

• The sweepstakes is structured to eliminate consideration for the chance element.
• Fixed promotional period with clearly disclosed start and end times.
• Finite, predetermined prize pool with total approximate retail value disclosed in official rules.
• Prizes may include cash, NFTs, or merchandise.

IV. Sweepstakes entry model

A. No consideration requirement

• The sweepstakes is structured so that participation does not require purchase.
• Each entry — whether paid or free — is treated identically.

B. Free entry access (unlimited on-kiosk)

• Every kiosk prominently displays “Enter Free – No Purchase Necessary.”
• Free entries may be obtained instantly at the kiosk.
• Free entries are available in unlimited quantities.
• No NFT purchase, payment information, or wallet is required.
• Free entries are processed through the same central server as paid entries.
• Each entry has identical odds.
• Reasonable anti-fraud controls (for example, CAPTCHA, identity verification, device monitoring) may be implemented to prevent automated abuse but will not restrict legitimate consumer participation.
• Optional mail-in alternative method of entry may also be provided but is not required for access.

C. Paid entries (promotional benefit only)

• NFT purchases award sweepstakes entries (for example, 100 entries per $1 spent).
• Entries are fungible and identical regardless of source.
• Purchase does not alter odds per entry.
• No multipliers, tiering, weighting, or preferential treatment exists.

Counsel review is requested regarding: whether entry volume tied to purchase price presents consideration risk; whether structural parity is sufficient under Missouri law.

V. Prize randomization and allocation

• One shared finite prize pool across all kiosks.
• At the moment entries are issued (paid or free), the central server:
  • Uses a cryptographically secure RNG
  • Assigns prize values to entries
  • Removes assigned prizes from the remaining pool (without replacement)
• No sequential prize list exists on any kiosk.
• The kiosk does not determine prize allocation.
• No house-edge or payout-percentage targeting model exists.
• All prize allocation occurs server-side and is fully auditable.

VI. Optional reveal interface (entertainment only)

• Users may optionally “reveal” batches of entries.
• Reveal animations are short, skippable, NFT-themed, and non-gambling in appearance (no reels, spins, slot sounds, levers, or casino visuals).
• A “Skip Animation” option is always visible.
• Outcome is predetermined at entry issuance.
• Unrevealed entries auto-award at promotion end.

The reveal interface does not: influence prize allocation; simulate wagering; or operate as a gambling mechanic.

VII. Operational safeguards

• ADA-compliant kiosk hardware.
• Encrypted communication between kiosk and server.
• No local prize logic.
• Full audit logs retained.
• Identity verification and anti-fraud systems in place.
• AML/KYC program as applicable.
• Independent RNG audit recommended.

VIII. Key legal positioning

The proposed structure is designed to ensure:

• No consideration is required for participation.
• Free entries are unlimited and meaningfully equivalent.
• Each entry has identical odds.
• Prize allocation occurs independently of payment.
• The kiosk functions as a retail sales terminal.
• The system does not operate as a gambling device under RSMo §572.
• The structure differs fundamentally from the device architecture described in the February 13, 2026 Torch ruling.