Conclusion
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Based on the facts provided by the Developer, the Firm concludes that the Game is unlikely to violate any anti-gambling laws, either on a state or federal level. The Firm also concludes that based on the facts provided by the Developer, the Game demonstrates sufficient utility to have value independent from investment, and therefore is not likely to be considered a “security” for
the purposes of federal law (from either the Domicoin or the NFT perspective). Sincerely,
Dan Artaev
Managing Partner
Artaev at Law PLLC