Ohio / Legal position gauge

Elevated risk

Editorial assessment from Ohio-specific research—not legal approval. Licensed Ohio counsel must review before any deployment decision.

Why this rating?

Ohio’s General Assembly, after the internet-café wave, wrote the electronic reveal into the criminal definition. A scheme of chance includes “the use of an electronic device to reveal the results of a game entry if valuable consideration is paid, directly or indirectly, for a chance to win a prize,” and then lists nine instances in which consideration is deemed paid (R.C. 2915.01(C)). A device that pays cash “shall not be considered a skill-based amusement machine and shall be considered a slot machine” (§ 2915.01(UU)(2)). Sweepstakes terminal devices are defined to include machines that select from a predetermined finite pool or reveal a predetermined entry (§ 2915.01(AAA)), and a sweepstakes terminal may not award cash (§ 2915.02(A)(5)(a)). The Eighth District treated “internet time” plus a post-purchase reveal as a slot-machine scheme of chance (Thorne). The Tenth District held that a predetermined one-million-entry electronic “raffle” with pay-then-reveal is not a statutory raffle (V&FCC). The Casino Control Commission continues to seize cash-paying cabinets as illegal slots. No reported Ohio appellate decision has tested mandatory pre-reveal with exact monetary disclosure, genuine accept/decline, and no charge on decline. That timing gap keeps the rating below high risk; the reveal statute, cash-as-slot rule, and active device enforcement keep it out of the moderate band.

This gauge also weighs that we identified no charges and no decided case in Ohio against a game that used a full-pool reveal together with mandatory pre-reveal. Banilla, Torch, and JD Prime used an optional viewer of the next assigned result after money was already on the machine. Café terminals paid first, then revealed. Those fact patterns are not this architecture and do not, by themselves, set the rating.

Scale: High risk → Elevated risk → Moderate risk → Unsettled → Moderately favorable → Favorable → Strong position. These are editorial categories, not probabilities of approval or findings of legality.

Source review date: . Has this exact model been tested? · Counsel checklist · Authorities

NCG GAMESOhio position brief
Ohio  /  Position brief

Ohio wrote the reveal into the statute.
Not when the player may decline.

R.C. 2915.01(C) does not stop at “consideration, chance, and prize.” After internet cafés, it says a scheme of chance includes using an electronic device to reveal a game-entry result if valuable consideration is paid, directly or indirectly, for a chance to win a prize—and then lists nine ways that consideration is deemed paid. A cash-paying cabinet cannot be a skill-based amusement machine; it is a slot machine. The NCG position is that those sentences assume payment buys an unresolved chance. They have not been applied to a transaction that discloses the exact monetary result before the player can commit funds and charges nothing on decline.

Has this been tested? What remains for Ohio counsel
Working position

This brief analyzes the proposed transaction architecture under current Ohio law. It is not a finding of legality, Casino Control Commission approval, Lottery Commission authorization, or Attorney General registration. Establishing, promoting, or operating a scheme of chance or a game of chance conducted for profit is gambling under R.C. 2915.02. Authorized channels include the state lottery and video lottery, four constitutional casino facilities, licensed sports gaming, pari-mutuel racing, licensed charitable bingo, narrowly limited charitable festival games of chance, and merchandise-only skill-based amusement machines.

Ohio legal starting point

Ohio generally prohibits gambling and then carves out lottery, casino, racing, sports, charitable bingo, and merchandise-only skill amusement.

R.C. 2915.01(C)

Scheme of chance includes the electronic reveal

A scheme of chance is a slot machine (unless Chapter 3772), a lottery (unless Chapter 3770), a numbers game, a pool conducted for profit, or another scheme in which a participant gives valuable consideration for a chance to win a prize. The definition then includes using an electronic device to reveal a game-entry result if consideration is paid, directly or indirectly, for that chance. Nine listed facts deem consideration paid—including casino-style electronic reveals of more than half the prizes, buying extra entries on the device, and prize-money payouts above 20% of location gross. Bingo, skill-based amusement machines, and pools not conducted for profit are excluded from the term.

R.C. 2915.01(QQ), (UU), (F)

Cash amusement is a slot machine

A slot machine includes any electronic device capable of accepting anything of value from a player who gives it “in the hope of gain,” or to conduct bingo or a scheme or game of chance. A skill-based amusement machine may award only merchandise or merchandise vouchers, with a $10 wholesale cap per play, distributed on site. If the device pays cash, or if a chance event the player cannot alter determines success, or if a source other than the player controls the outcome or prize value, it “shall be considered a slot machine.” Gambling devices include tickets representing a chance in a scheme of chance and apparatus designed for a game of chance.

Ohio Const. art. XV, § 6

Lotteries forbidden except as authorized

The Constitution forever prohibits lotteries except the state education lottery, charitable bingo, and casino gaming at four specified facilities. Statute then licenses video lottery, sports gaming, and pari-mutuel racing. R.C. 2915.02 does not prohibit “gambling expressly permitted by law,” and carves out limited 501(c)(3) festival games of chance and licensed charitable bingo. Sweepstakes terminal devices require Attorney General registration and may not award cash or merchandise over $10 wholesale per entry.

Central timing question: A scheme of chance requires consideration for a chance to win a prize. The NCG position is that at Accept the accepted transaction’s monetary result is already fixed and disclosed—so the player is not paying for an unresolved chance. Ohio has not held whether that sequence escapes § 2915.01(C). Thorne and V&FCC involved payment before the electronic reveal of a predetermined result. A “game of chance” uses a different test—“largely by chance,” read as chance predominating / more than fifty percent (Progress Vending; OAG 2004-029). Scheme of chance does not use that predominance phrasing.

Safeguard 1

Exact cost and result are known before acceptance.

Before the player becomes financially committed to a transaction, the system discloses the exact transaction cost and exact monetary result. Accept processes only those disclosed terms.

Why this matters under Ohio law

§ 2915.01(C) requires consideration for a chance to win a prize. Slot-machine clause (QQ)(a) requires giving value “in the hope of gain.” If the economic outcome is already fixed and disclosed before Accept, the strongest NCG argument is that the player is not paying for an unresolved chance or hoping for an unknown gain—they are accepting a disclosed, predetermined transaction.

Contrary authority

Thorne customers could have a cashier or automated system “instantly reveal” winning entries—but they had already paid for network time and received sweepstakes points. The court did not treat post-purchase reveal as removing chance or consideration. V&FCC patrons likewise chose “reveal” only after buying a $1 ticket. Prosecutors will argue casino-style presentation still frames the session as paying for chances, and that (C)(3)’s casino-simulate deeming trigger looks at how prizes are revealed, not at Accept timing.

Implementation risk

Weakening factors: showing cost/result after partial payment, allowing acceptance before disclosure renders, or mismatch between displayed and settled amounts. Any of those would collapse the timing distinction from Thorne and V&FCC and look like the statutory “electronic device to reveal the results of a game entry.”

R.C. 2915.01(C)Timing of “for a chance” is critical
Safeguard 2

Viewing the offer does not require payment.

The player may see the disclosed offer—including zero or negative-net outcomes—without paying for that transaction. Declining imposes no charge for that offer.

Why timing of consideration matters

Thorne and V&FCC involved payment (or purchase of time/tickets) before the result was known. NCG separates inspection from commitment: no consideration moves for a declined offer. That is the factual distinction those opinions did not have. The nine “deemed paid” instances in § 2915.01(C) were written for sham product sales and pay-then-play cafés, not for a no-charge decline after exact disclosure.

Contrary authority

Prosecutors may argue the player purchased access to a sequence of offers by earlier deposit, and that each Accept still “gives” credits for a chance at the next unknown result. Thorne treated unused network minutes as evidence that the real product was the chance. A genuine sweepstakes under § 2915.01(BBB) requires that consideration not be required to enter; paid Accept after a reveal is not that model—and a sweepstakes terminal still may not pay cash.

Thorne ¶¶ 41–46No payment on decline
Safeguard 3

Monetary results and reel positions are predetermined.

Monetary outcomes are fixed before acceptance within a finite predetermined pool. Reels, symbols, and entertainment layers cannot modify the disclosed monetary result after acceptance.

Distinction from Ohio authorities

Predetermination is not a statutory defense in Ohio. Section 2915.01(AAA) defines sweepstakes terminal devices to include predetermined finite pools and stored prize results delivered at reveal. V&FCC ¶¶ 11–14, 27–29: prizes were assigned before any ticket was sold; “game play” (keno, poker, spinning reels) did not change the result; the court still held the machines were not raffles because winners were not drawn from tickets actually sold. NCG’s distinction is not predetermination alone—it is predetermination plus disclosure before financial commitment plus a free decline.

Cash and player-control problem under skill amusement

§ 2915.01(UU)(2) is express: cash payout = slot machine. Outcome or prize value controlled by a source other than the player = slot machine. Success determined by a chance event the player cannot alter = slot machine. A finite pool assigned by the operator or software fails those clauses. Do not market NCG as a skill-based amusement machine.

Electronic instant bingo is not a path

Electronic instant bingo also uses a predetermined finite deal—but only after the participant purchases the ticket, and only for licensed veteran/fraternal Type II/III bingo at the organization’s principal place of business. The reveal may not use spinning reels that resemble a slot machine, and the device may not dispense cash (§ 2915.01(CCC)). That licensed charitable product is not a retail cash-cabinet exemption.

V&FCC§ 2915.01(UU), (AAA), (CCC)
Safeguard 4

The player may stop and redeem—including cents.

Eligible remaining credits may be redeemed without further play. Redemption includes fractional dollars; balances are not rounded down to trap value in the machine.

Effect on Ohio analysis

Full redemption supports the argument that only accepted transactions consume value and that the player retains a genuine exit. It may mitigate “trapped balance” or forced-continued-play theories. Thorne patrons cashed winning points at one cent each; redemption did not prevent conviction.

Limitation

Redemption does not cure an otherwise unlawful scheme of chance or slot machine. Premises used for gambling in violation of § 2915.02 are a nuisance subject to abatement under R.C. 3767.01–.99 (§ 2915.03(C)). The Casino Control Commission’s skill-game and illegal-device program seizes or disables cash cabinets as unlicensed slots. A seizure or raid is not a judicial holding on NCG architecture.

ILLUSTRATIVE CASH-OUT

$22.00 ticket+$0.67 cents→$0.00 remaining
R.C. 2915.03Exit rights ≠ legality
Safeguard 5

Software enforces non-bypassable rules.

Mandatory pre-reveal, accept/decline, no post-acceptance RNG, predetermined reels, and redemption rules are architecturally enforced—not merely published as disclaimers.

Why enforcement matters in Ohio

Ohio café, raffle-kiosk, and skill-game matters turn on actual mechanics and how customers used the system—not marketing labels. Thorne disregarded “network access time.” V&FCC disregarded “electronic raffle.” The Attorney General’s internet-café program and the Casino Control Commission’s skill-game rules look at what the device does. Software enforcement is how the timing distinction can be proved if charges are brought under §§ 2915.02–2915.03 or civilly by the Commission or local nuisance actions.

Implementation risks

Alternate clients, debug modes, stale-offer acceptance, or server paths that charge on preview would collapse the distinction from Thorne and V&FCC and expose operators to first-degree misdemeanor gambling (fifth-degree felony with a prior gambling offense), gambling-house liability, gambling-device possession, nuisance abatement, and Commission seizure. Casino-style presentation without the enforced accept/decline sequence is the fact pattern Ohio has already condemned and legislated against.

R.C. 2915.02Engineering ≠ statutory permission
Required analysis

Has this exact model been tested in Ohio?

We did not identify a reported appellate decision in Ohio directly testing this complete transaction architecture—mandatory pre-reveal, exact monetary disclosure before financial commitment, genuine accept/decline with no charge on decline, no post-acceptance randomness, finite predetermined pool, predetermined reels, software-enforced safeguards, and cent-level redemption.

What Ohio courts and agencies have addressed—and how those systems differ

  • Cleveland v. Thorne, 2013-Ohio-1029, 987 N.E.2d 731 (8th Dist.) — Cyber cafés sold “network access time” and gave sweepstakes points used on VS2 casino-style terminals, or instantly revealed at the cashier; winnings cashed at one cent per point. Convictions for gambling, operating a gambling house, and possession of criminal tools affirmed. Terminals treated as slot machines that indirectly accepted value to participate in a scheme of chance. Partially analogous on electronic reveal, cash prizes, and rejection of a product-sale cover. Materially distinguishable because consideration occurred before the result was known and there was no accept/decline with zero cost on rejection of a disclosed result. Municipal-ordinance charging tracked Chapter 2915 definitions then in force; the 2013 H.B. 7 electronic-reveal and sweepstakes-terminal amendments followed this wave.
  • Ohio Veterans & Fraternal Charitable Coalition v. DeWine, 2018-Ohio-4679 (10th Dist.) — Electronic “raffle” machines with bill acceptors, a one-million-entry finite pool, prizes pre-assigned before any sale, and post-purchase “reveal” or keno/poker/reel “game play” that did not change the result. Held not a “raffle” under § 2915.01(CC) because winners were not drawn from tickets actually sold. Partially analogous on predetermined finite pool and a reveal step. Materially distinguishable on payment-before-reveal, the raffle-definition issue, and absence of a no-charge decline after exact disclosure. The court did not hold that every predetermined pool is lawful or unlawful gambling; it held these machines were not statutory raffles.
  • Westerhaus Co. v. City of Cincinnati, 165 Ohio St. 327, 135 N.E.2d 318 (1956); Stillmaker v. Dept. of Liquor Control, 18 Ohio St.2d 200, 248 N.E.2d 607 (1969) — Price, chance, and prize. Lottery requires predominant chance; gambling is broader and can exist even where skill is substantial if the result is not certain. Free replay can be a prize. Partially analogous on the three elements. Materially distinguishable: pinball/replay under former numbering (including then-§ 2915.15 / G.C. 13066); not a pre-reveal accept/decline architecture and not a construction of current § 2915.01(C) or (UU).
  • Progress Vending, Inc. v. Dept. of Liquor Control, 59 Ohio App.2d 266, 394 N.E.2d 324 (10th Dist. 1978) — Pinball whose play was found skill-predominant was not a “game of chance” under § 2915.01(D). Partially analogous on the “largely by chance” test. Not applicable as a test of NCG cash architecture; current (UU)(2) independently treats cash-paying devices as slot machines.
  • 2013 Op. Att’y Gen. No. 2013-012; 2004 Op. Att’y Gen. No. 2004-029; 2004 Op. Att’y Gen. No. 2004-021; 1985 Op. Att’y Gen. No. 85-013 — AG opinions are not binding precedent. 2004-029 reads “largely or wholly by chance” in the then-skill-amusement definition as more than fifty percent chance. 2013-012 and 85-013 address incidental prize promotions tied to bona fide insurance or loan products, not retail cash cabinets. 2004-021 treats a private lottery-pooling venture as its own scheme of chance. Not a judicial test of NCG architecture.
  • Ohio Attorney General, internet-café / sweepstakes-terminal registration (R.C. 2915.02(F)–(J); Ohio Adm.Code 109:9-1) — Operators of sweepstakes terminal device facilities must register or obtain a certificate of compliance. Criminal enforcement of Chapter 2915 is with local law enforcement, not a license that legalizes cash prizes. Regulatory process, not a judicial test of NCG architecture.
  • Ohio Casino Control Commission, skill-based amusement (R.C. 3772.03; Ohio Adm.Code 3772-50) — Type-B/C operator, vendor, and Type-C location licenses; merchandise prizes only; currency and gift cards excluded from “merchandise prize” in the Commission’s rule. Commission and local partners have seized or disabled thousands of suspected illegal slot machines statewide (Commission statements through 2026). Enforcement and licensing, not a holding on pre-reveal accept/decline.

Enforcement and regulatory activity (not judicial approval)

H.B. 7 (2013) added the electronic-reveal sentence, the nine deemed-consideration instances, and the sweepstakes-terminal device scheme. The Attorney General’s Charitable Law Section still publishes internet-café registration forms and warns that unregistered terminal facilities are illegal. The Casino Control Commission’s 2025 annual report describes skill-game licensing as a tool against “illegal gaming machines masquerading as skill games,” and 2026 search-warrant releases describe cash cabinets as illegal slots. We did not identify an Attorney General opinion specifically approving mandatory pre-reveal, accept/decline, cash-redemption terminals. Absence of a decision testing this complete architecture is not a judicial determination of legality.

Critical distinction

“No reported Ohio decision directly testing this architecture” is materially different from “An Ohio court has ruled this architecture legal.” Neither statement has been found true here. Thorne is the closest published analogue on electronic cash reveal—and it is adverse on payment-before-reveal. The statute that followed is more specific, not less.

No direct Ohio appellate precedent identified
Strongest contrary arguments

What Ohio prosecutors and regulators could argue.

1. The statute already includes the electronic reveal

§ 2915.01(C) does not wait for a court to decide whether a café kiosk is a scheme of chance. It includes using an electronic device to reveal a game-entry result if consideration is paid, directly or indirectly, for a chance to win. Counsel must explain why payment after a mandatory disclosure is not consideration “for a chance,” and why the nine deeming triggers—especially casino-style reveal of most prizes and payouts over 20% of location gross—do not attach to the location as a whole.

2. Cash is a slot machine by force of (UU)(2)

Skill-based amusement is the only Chapter 2915 machine exemption that looks like a retail cabinet—and it is unavailable the moment the device pays cash, or the moment software rather than the player controls the result. Casino Control licensing will not cover a cash NCG cabinet.

3. Thorne already involved an instant reveal

Patrons could skip the casino game and have winning entries revealed immediately—after they had paid. A published appellate opinion treated that as gambling. Counsel must explain, with facts, why disclosure before commitment and a free decline are legally different from Thorne’s post-purchase reveal.

4. Predetermined pools are in the sweepstakes-terminal definition

§ 2915.01(AAA) lists predetermined finite pools and stored results as defining features of a sweepstakes terminal device. V&FCC refused to treat a predetermined electronic pool as a raffle. Predetermination is something Ohio already legislated about—not a novel defense.

5. Slot-machine “hope of gain” and the constitutional definition

(QQ)(a) reaches devices that accept value from a player who gives it in the hope of gain. Article XV, § 6(C)(9) defines casino slot machines to include devices that, upon payment of consideration, make individual prize determinations by skill, chance, or both. Prosecutors may argue session-level hope and cabinet presentation, not the accepted ticket’s already-known number.

6. Gambling house, nuisance, and felony enhancement

§ 2915.02 is a first-degree misdemeanor (fifth-degree felony with a prior gambling offense). § 2915.03 adds gambling-house liability and R.C. Chapter 3767 nuisance abatement. Possessing a gambling device with purpose to violate § 2915.02 is itself a § 2915.02(A)(7) offense. Local ordinances, as in Thorne, may track the same elements.

7. Current Commission enforcement posture

The Casino Control Commission publicly reports thousands of seized or disabled suspected illegal slots—more than the four licensed casinos’ inventories combined—and continues 2025–2026 warrant operations against cash cabinets. Presentation that resembles slots will invite the same investigative path even if backend logic differs. An allegation or seizure is not a holding.

NCG factual responses and residual risk

Responses: at acceptance the monetary result is fixed and known; declines cost nothing; no post-acceptance RNG; Thorne and V&FCC involved payment-before-outcome mechanics; skill amusement is not the NCG theory—the timing of § 2915.01(C) “for a chance” and (QQ) “hope of gain” is. Residual risk: the reveal-inclusive statute, nine deeming triggers, cash-as-slot rule, predetermined-pool terminal definition, published Thorne authority, nuisance/felony exposure, and aggressive Commission device enforcement remain material pending Ohio counsel review. The timing distinction is supportable; it is not settled.

ThorneAdverse authority must be addressed, not dismissed
Complete transaction analysis

Chronology: when is the player financially committed?

“The player accepts or declines a fully disclosed, predetermined transaction. No later random event alters the monetary result. The legal question is whether Ohio treats that sequence as consideration for a chance under § 2915.01(C)—or as something materially different from the pay-then-reveal terminals in Thorne and V&FCC.”

This is the position to test—not an Ohio legal conclusion. Compare to Thorne (pay for time/points, then reveal) and V&FCC (pay $1, then reveal a pre-assigned prize; not a raffle).

  1. 1 / POOLFinite pool predetermined
  2. 2 / REQUESTPlayer requests next offer
  3. 3 / REVEALExact result disclosed
  4. 4 / TERMSCost and result both known
  5. 5 / CHOICEAccept or decline
  6. 6 / SETTLENo post-accept RNG
  7. 7 / EXITRedeem remaining cents
Authorities

Primary Ohio sources.

Verified . Binding precedent and current statutes distinguished from Attorney General opinions, administrative rules, and enforcement activity. Current § 2915.01 text is the H.B. 96 (136th G.A.) version effective September 30, 2025; the electronic-reveal and sweepstakes-terminal language entered in H.B. 7 (130th G.A.) effective September 4, 2013. Cases may cite older paragraph letters.

  1. [1]
    Ohio statute · definitions

    R.C. 2915.01 ↗

    Scheme of chance and electronic-reveal / deemed-consideration list (C); game of chance (D); gambling device (F); slot machine (QQ); skill-based amusement machine and cash-as-slot rule (UU); merchandise prize (VV); sweepstakes terminal device including predetermined pools (AAA); sweepstakes (BBB); electronic instant bingo (CCC). Official codes.ohio.gov text; last legislative update noted on the statute page March 2, 2026.

  2. [2]
    Ohio statute · gambling offense

    R.C. 2915.02 ↗

    Prohibits establishing or promoting a scheme of chance or game of chance conducted for profit; sweepstakes-terminal cash and over-$10 merchandise prizes; registration; gambling-device possession. Expressly-permitted-by-law and limited charitable-festival exceptions. M1 / F5 penalties. H.B. 7 (2013) text still shown as current on codes.ohio.gov as of this review.

  3. [3]
    Ohio Court of Appeals · published

    Cleveland v. Thorne, 2013-Ohio-1029 ↗

    987 N.E.2d 731 (8th Dist. 2013). Internet-café VS2 terminals; pay for “network time,” then casino-style or cashier reveal; cash-out of winning points. Convictions affirmed. Official Eighth District ROD PDF.

  4. [4]
    Ohio Court of Appeals · published

    V&FCC v. DeWine, 2018-Ohio-4679 ↗

    (10th Dist. 2018). Predetermined one-million-entry electronic “raffle” with pay-then-reveal held not a raffle under § 2915.01(CC). Official Tenth District ROD PDF.

  5. [5]
    Ohio Constitution

    Ohio Const. art. XV, § 6 ↗

    Lotteries forever prohibited except the state education lottery, charitable bingo, and casino gaming at four specified facilities. Includes the constitutional “slot machines” definition used for casino gaming.

  6. [6]
    Ohio statute · gambling house

    R.C. 2915.03 ↗

    Using or recklessly permitting premises to be used for gambling in violation of § 2915.02. M1 / F5. Premises constitute a nuisance subject to abatement under R.C. 3767.01–.99.

  7. [7]
    Ohio Supreme Court · binding

    Westerhaus Co. v. City of Cincinnati, 165 Ohio St. 327 ↗

    135 N.E.2d 318 (1956). Gambling is generally price, chance, and prize. Lottery requires predominant chance; gambling is broader and can exist even where skill is substantial if the result is not certain. Free replay may be a prize. Former G.C. / R.C. numbering (including then-§ 2915.15).

  8. [8]
    Ohio Court of Appeals · published

    Progress Vending v. Dept. of Liquor Control, 59 Ohio App.2d 266 ↗

    394 N.E.2d 324 (10th Dist. 1978). Skill-predominant pinball was not a “game of chance” under § 2915.01(D). See also Stillmaker v. Dept. of Liquor Control, 18 Ohio St.2d 200, 248 N.E.2d 607 (1969) (replay pinball as gambling device per se under then-current law).

  9. [9]
    Ohio Attorney General · opinion / not binding

    2004 Op. Att’y Gen. No. 2004-029 ↗

    Reads “largely or wholly by chance” in the then-skill-amusement definition as more than fifty percent chance, citing Progress Vending and Ohio Vending Operators Group. Not a judicial holding and not an approval of cash terminals. See also 2013 Op. Att’y Gen. No. 2013-012 and 1985 Op. Att’y Gen. No. 85-013 (incidental prize promotions).

  10. [10]
    Ohio Administrative Code · skill games

    Ohio Adm.Code 3772-50 ↗

    Casino Control Commission skill-based amusement licensing. Rule 3772-50-01 excludes currency, digital currency, and gift cards from merchandise prizes. Amplifies R.C. 3772.03 and 2915.01.

  11. [11]
    Ohio Casino Control Commission · licensing

    OCCC, Skill-based amusement licensing ↗

    Type-B/C operator, vendor, and Type-C location licenses required before conducting skill-amusement gaming. Merchandise-only; not a cash-cabinet license. See also the Commission’s 2025 annual report on skill-game enforcement.

  12. [12]
    Ohio Attorney General · internet cafés

    OAG, Services for Internet Cafés / Sweepstakes ↗

    Registration and certificate-of-compliance forms for sweepstakes terminal device facilities. Criminal enforcement of Chapter 2915 is with local law enforcement. See Ohio Adm.Code 109:9-1.

  13. [13]
    Ohio statute · casino control

    R.C. 3772.01–.03 ↗

    Casino Control Commission created under art. XV, § 6(C); casino game and casino gaming definitions; Commission authority includes skill-based amusement machines. Related authorized channels: R.C. Chapter 3770 (lottery / video lottery), Chapter 3775 (sports gaming), Chapter 3769 (pari-mutuel racing).

  14. [14]
    Ohio Attorney General · charitable gaming note

    OAG Charitable Law, Charitable Gaming ↗

    Internet café / sweepstakes operations are not charitable gaming. Games of chance and raffles are separately limited. Policy guidance, not a judicial holding.

Disclaimer: This brief is research and issue-spotting for professional discussion—not legal advice, Casino Control Commission approval, Lottery Commission authorization, Attorney General registration, or permission to operate. No Ohio Attorney General opinion specifically addressing mandatory pre-reveal NCG architecture was identified. Attorney General opinions are not binding precedent. Seizures, search warrants, and charging decisions are not holdings. Ohio counsel should verify all citations, effective dates, local enforcement practices, liquor-permit and nuisance exposure, exclusivity questions around the four casinos and video lottery, and the actual deployed software before any compliance representation.