Not a Loophole.
The Law.
It's legal because one of the most credentialed gaming-device laboratories in the country looked at every line of code and signed a certification stating it is not a gambling device or a slot machine.
The Three-Element Test
In every state, gambling requires three elements: prize, chance, and consideration. Remove any one of the three, and it's no longer gambling under the law. We remove chance entirely.
Prize
Players can win real prizes. This element stays. It's what makes the games worth playing and keeps your customers coming back.
Chance
Eliminated before payment ever occurs. Every outcome is visible to the player before money is inserted. Nothing is random. Nothing is hidden.
Consideration
Players pay to play, like any arcade or video game. Payment for a known outcome is a purchase, not a wager.
Prize + Chance + Consideration = Gambling
Prize + Chance + Consideration = Video Game
How Chance Is Removed
The result of every play exists in the system before the play happens. That is the architecture, and it is what the laboratory verified at the source-code level.
Every Line of Code, Reviewed
We handed our source code to Eclipse Compliance Testing, the independent laboratory trusted with certifying casino gaming systems, state lotteries, and tribal gaming equipment, and asked them to verify it.
Who Is Nick Farley?
The certification is signed by a gaming-compliance veteran with nearly 40 years testing devices for regulators, casinos, lotteries, and tribal operators.
Nick Farley
Nick Farley began his career in 1987 as a test engineer for the New Jersey Division of Gaming Enforcement, the state agency that decides which gaming devices are legal to operate. For four years, his job was to scrutinize machines on behalf of regulators, not manufacturers.
The expert who tested machines for the regulators reviewed our source code.
Since 2000, Farley has owned Eclipse Compliance Testing, an independent regulatory compliance testing laboratory that the International Gaming Standards Association describes as serving over 250 regulated markets globally, with services spanning source-code review, on-site inspections, audits, forensic evaluations, and expert testimony. ECT holds ISO/IEC 17025 and ISO/IEC 17020 accreditation, certificates 2887.01 and 2887.02, active through August 2027 and listed in A2LA's public accreditation directory.
Farley's standing as a gaming-systems expert has been tested in court. In TNT Amusements, Inc. v. Torch Electronics, LLC (E.D. Mo. 2025), a federal judge examined his qualifications under Rule 702 and Daubert and denied the motion to exclude his testimony, noting his degree in electrical engineering and computer science from Stevens Institute of Technology and nearly 40 years testing electronic gaming devices.
In recognition of his contributions to gaming device compliance and classification, Farley was selected for inclusion in Marquis Who's Who, the standard biographical reference of accomplished professionals since 1899.
Test engineer, New Jersey Division of Gaming Enforcement. Begins a regulatory career examining gaming devices for the state (through 1991). Holds a degree in electrical engineering and computer science from Stevens Institute of Technology.
Executive Director, Gaming Laboratories International. Helps lead the largest independent gaming test lab in the world.
Takes ownership of Eclipse Compliance Testing. Independent regulatory compliance laboratory based in Solon, Ohio.
ISO/IEC 17025 accreditation, the international standard for testing laboratory competence.
ISO/IEC 17020 and GSA accreditations. Also receives the Warrior Award from the Oklahoma Indian Gaming Association and the Weatherhead Award.
Serving hundreds of regulated gaming jurisdictions, including the review and certification of Foxfire Games systems.
Compliance You Can Point To
The legal classification is visible on every machine, at every venue, every day.
Zero Legal Incidents.
And if a legal situation ever arises specifically around your machines, we provide legal representation at no cost to you. That is written into the warranty.
The Documentation
The documentation is provided with every installation, and you can start reading right now.
Machine Certification Plate
The Eclipse Compliance Testing certification plate mounted on every Foxfire cabinet.
Full Compliance Package
The complete ECT certification and supporting documentation, delivered with every installation. Want it before you sign? Just ask on your call.
Legal Questions
Are Foxfire machines legal?
A wager is paying for an outcome you do not know. Foxfire is the opposite. A player can see the upcoming result for any game, at any play amount, without inserting money or spending a credit, and can change games, change the amount, or walk away. Nothing is ever purchased blind. Eclipse Compliance Testing reviewed the source code and found no random number generator and no element of chance, and stated in its report: "This device is not a slot machine." Because gambling requires an element of chance, removing chance places the system outside that definition.
How do Foxfire machines work?
The outcome of each upcoming play already exists in the system before anyone plays. The machine displays it on screen, and a player can check it for any game at any play amount without paying anything. They then decide whether to buy a play whose result they can already see, switch games, change the amount, or walk away. Nothing is generated at the moment of play.
Do players have to pay to preview?
No. Previewing costs nothing. Not a coin, not a credit, no purchase of any kind. This is the point that distinguishes Foxfire from machines that only reveal the next result as part of a paid cycle.
Has a court or regulator ruled on Foxfire specifically?
No. We are not aware of any court decision, attorney general opinion, or regulatory ruling addressing Foxfire's system. What we have is an independent source-code certification from an accredited laboratory, and we would rather tell you exactly what that is than imply something broader.
Does the certification apply in every state?
The certification is a technical finding about the machine: no random number generator, no element of chance, verified at the source-code level. That finding does not change from state to state, because the machine does not change from state to state. How each state defines gambling is set by its own statute, which is why we publish the governing agency and controlling statute for all 50 states.
Do you provide legal documentation?
Yes. Each location receives the ECT certification and supporting documentation confirming the systems are legally classified as predetermined-outcome entertainment.
What happens if a question ever comes up at my venue?
Every machine carries its certification plate, and you'll hold the full documentation package on site. If a legal situation ever arises specifically around your machines, we provide legal representation at no cost to you.
What age is allowed to play?
Signage is posted on every machine, and payouts are only redeemed to someone 18 years or older.
Certified. Documented. Ready To Earn.
$0 install. $0 monthly. Payouts every two weeks.
Bring every question on this page to a 20-minute call.
We'll walk you through the certification, the documentation, and exactly how the machines would work in your venue.
