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
"Predetermined outcome" isn't a marketing phrase. It's the system's architecture, and it's what the laboratory verified at the source-code level.
Every Line of Code, Reviewed
We didn't stop at paperwork. 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?
A certification is only as strong as the person who signs it. Ours is signed by a gaming-compliance veteran with more than 35 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. He went on to serve as Executive Director at Gaming Laboratories International, the largest independent gaming test lab in the world.
The expert who tested machines for the regulators now certifies that ours aren't gambling.
Since 2000, Farley has owned Eclipse Compliance Testing, an authorized independent regulatory compliance testing laboratory active across 250+ regulated gaming markets, certifying casino gaming systems, state lotteries, and tribal gaming equipment with source-code review, on-site inspections, audits, and forensic evaluations. ECT holds ISO/IEC 17025 and ISO/IEC 17020 accreditations and is a member of the International Gaming Standards Association.
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 bachelor's degree in engineering.
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 isn't a binder in a filing cabinet. It's 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's not a promise. It's our warranty.
The Documentation
Don't take our word for any of this. 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 these machines legal?
Yes. Gambling means paying for an unknown outcome. Our machines let players preview all possible results before playing, removing chance. That's why they're classified as predetermined-outcome video games, not gambling.
Is it available in all 50 states?
Yes. Foxfire is certified legal in all 50 U.S. states. Eclipse Compliance Testing (ECT), the same third-party lab used by state gaming authorities and the lottery industry, reviewed the actual source code and certified that the machine contains no randomness and is not a gambling device.
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?
We have signage on our machines and require the payout to go to someone 18 years or older.
Certified. Documented. Ready To Earn.
No setup costs. No risk. No red tape.
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.
