Every sweepstakes ban turns on redemption. All eight of them.
Eight states have written the sweepstakes casino out of their law since October 2025, and each of the eight statutes attaches liability to the same element.
The same hinge, eight times
Montana’s SB 555 attaches to paying out a monetary equivalent. New Jersey’s A5447 defines the sweepstakes as an exchange of currency for a prize or prize equivalent. New York’s Section 912 targets the dual-currency redemption mechanic. Maine’s LD 2007 prohibits an online game that uses a dual-currency system of payment and simulates casino-style gaming, and defines that currency element broadly enough that its reach to a non-redeemable model is unsettled. California’s AB 831 prohibits the dual-currency model and extends criminal liability down the supply chain. Indiana, Tennessee and Connecticut follow the same shape.
Not one of them prohibits a game. They prohibit a redemption.
The definitions do the work, not a carve-out
New York’s §912 defines an online sweepstakes game as one that is available online, that utilizes a dual-currency system of payment allowing the player to exchange the currency for cash prizes, cash awards, cash equivalents or a chance at them, and that simulates casino-style gaming. Verified The limbs are joined. A game with a single currency that cannot be turned into money has nothing to exchange, so the definition does not reach it on the face of the text. That is a reading of the statute, not a ruling.
This paragraph previously claimed the statute contained a sentence excluding games that award no cash prizes or cash equivalents, and labelled it Verified. That sentence appeared in an earlier draft of S5935 and is not in the enacted law. Corrected 8 September 2026; see the errata.
Nevada is often described as leaving free social games alone because NRS 463 was already wide enough, and New Jersey’s A5447 as specifying the shape of a lawful free-play promotion. Unverified Neither has been re-read against primary text since this correction, so neither is stated here as a finding. Both are on the tracker.
The counter-argument, taken seriously
The obvious objection is that this reasoning proves too much: if removing redemption made a product lawful everywhere, the industry would simply have removed redemption. It has not, therefore the analysis must be wrong.
The analysis is not wrong. The industry has not removed redemption because redemption is the entire commercial model. Sweeps Coins are the reason a player buys a Gold Coin package. Strip them out and the revenue goes to zero, which is a business problem and not a legal one. VGW’s own conduct is the tell — it pulled Sweeps Coins from New Jersey and New York and left its Gold Coin games running in both. Verified The operator with the most to lose already conceded the point in production.
Washington is the exception, and it is the one that binds
Under Kater v. Churchill Downs (9th Cir. 2018), a virtual chip that cannot be redeemed for anything is nonetheless a thing of value where the player purchased it — the extended play is the prize. Big Fish Games settled for $155 million. Verified
Kater’s trigger is the sale, not the redemption. Which means the design that survives everywhere is not merely non-redeemable. It is non-purchasable as well. One currency, granted, never sold, never cashed out. That is the entire specification, and it fits in a sentence.
The statutes were written to catch redeemable value. A platform with none is not a loophole in them — it is the thing they were drafted around.