Nine states have banned the sweepstakes model. Your players are still there.
OK — 1 Nov
NVWAWVLAMIMN
Red: ban in force · Outlined: enacted, not yet effective · Gold: closed by enforcement, no statute
Every one of those statutes turns on redeemable value. Not on games, not on gambling, not on the word casino — on redemption. Remove it and the element the legislature drafted its ban around is not present.
Flickloot is that platform, built and running. It is what a compliant free-play product looks like when someone actually builds one.
The legislatures wrote the exemption themselves
This is not a loophole, and it is not an argument that needs making. It has already been made, in statute, by the states doing the banning.
New York S5935A → Racing, Pari-Mutuel Wagering and Breeding Law §912, in force 5 December 2025
Nevada does not regulate social games where no prizes are awarded. New Jersey’s A5447 went further and specified the lawful shape directly — no cost to the player, prizes confined to food, drink, or merchandise under $20. Maine’s LD 2007 reaches for indirect consideration, which cannot exist where nothing was ever sold.
The industry read those carve-outs, priced them, and discarded them inside an afternoon, because a product with no redemption generates no revenue. That is a commercial judgement, and a defensible one. It is not a legal finding, and the two have been conflated for a year.
What an operator locked out of nine states actually owns
Eight of those bans are in force today; Oklahoma’s SB 1589 joins them on 1 November 2026, the legislature having overridden the governor’s veto in May. What is left behind in each of them is the same: registered accounts. Acquisition cost already paid. A brand those players recognise. And no lawful way to reach any of it.
The choice is to write those markets off, or to run a play-only product into them. The second option is legal in all fifty states, requires no licence, and has never been built properly by anyone in this market — which is what this platform is.
Geo-gate that cites the statute
Blocked users are told which law blocks them, by bill number and effective date. Wired to a tracker that is maintained weekly, not annually.
Controls that bind
Session limits, reality checks, and a self-exclusion no support agent can reverse — because no support process exists to lobby.
One currency, never sold
Granted on an allowance, refilled slowly, capped. No shop, no packs, no offer wall, no ad-watch. Nothing to buy on the screen where every competitor puts the purchase prompt.
Washington is the constraint, and it is the one most operators have not priced
Under Kater v. Churchill Downs, a virtual chip that cannot be redeemed for anything is still a thing of value if the player bought it. The extended play is the prize. Big Fish Games settled for $155 million.
Kater’s trigger is the sale, not the redemption. Any social casino that sells coins carries Washington exposure whatever it does about cash-out. The design that survives everywhere is not merely non-redeemable — it is non-purchasable, and that is a harder line than the industry has been willing to draw.
Nothing on this platform is ever sold, to anyone. That single decision is what makes the rest of it possible.
The consultancy behind it
This site maintains the state-law tracker — every ban and every enforcement action, sourced to bill text and labelled by confidence, updated in the week a status changes. It publishes the Readiness Framework in full, because a framework kept behind a contact form is a lead magnet rather than a standard.
And it publishes a working platform, because a compliance argument that has never been implemented is an assertion. Every feature here was built by one person, without a licence, a testing house, or a budget. The features the industry calls impractical took a few weeks of evenings.
Audits and fractional compliance
The law tracker
Twelve games, each carrying its own arithmetic
Every game page publishes the maths it runs on — paytable, return, and how the figure was derived.
If you came here to play
You can, free, with no account and no money — and the machine publishes its own reel weights, its paytable and its target return of 94.6%. A button runs a hundred thousand spins in your browser so you can check the number rather than trust it.
Gold Coins cannot be bought, redeemed, cashed out, or transferred. They have no value of any kind and never will — see the no-value statement.