Special Disclaimer: This article is an original work by Attorney Shao Shiwei. It reflects only the personal views of the author and does not constitute legal consultation or legal advice on any specific matter. For article reprints, legal consultations, or business exchanges, please add: sswls66
At 3:00 a.m. (Beijing Time) on June 15,the UEFA Euro 2024 will kick off with great enthusiasm.As a sponsor of the UEFA Euro, Ant Group has launched numerous promotional activities in connection with the tournament.
In the field of digital collectibles, “Jingtan,” a platform under the group, officially launched UEFA Euro blind boxes, which have received a strong market response.
Therefore,does the combination of aleatory football matches with NFT digital collectibles entail legal risks related to gambling??
Author: Attorney Shao Shiwei
01
Analysis of the Gameplay Mechanics of the UEFA Euro Blind Boxes
The figure below presents the introduction to the “UEFA Euro Official Collectible Cards.”
From June 14 to June 19, Jingtan will release the 2024 UEFA Euro Official Collectible Cards Group Official Series card blind boxes daily at 12:00 p.m. Each group is limited to 15,028 units, priced at RMB 40 per unit, for a total of six groups.
Among the six groups, each group comprises four teams, including one seeded team.This year'sseeded teams are Germany, Spain, Portugal, France, Belgium, and England.
Cards are divided into five tiers: C, R, SR, SSR, and HR. The drop rates for each tier are detailed in the figure below.
Cards of different tiers correspond to different prizes,with the most attractive being PFP collectibles, Easter egg HR cards, and physical gold coins.
If you draw an HR card or a seeded-team SSR card, you may receive physical gold coins, PFPs, and limited-edition digital collectibles, subject to certain conditions.
However, the probability of drawing an HR card is extremely low, at only 0.2%. Drawing one entitles you to physical gold coins valued between RMB 2,500 and RMB 10,000.
The drop rate for SSR cards is 8%. Let us do a quick calculation: purchasing 100 blind boxes at RMB 40 each would statistically yield approximately eight SSR cards. Among these eight SSR cards, the probability of drawing a seeded-team SSR card is 8% × ¼ = 2%. Therefore, theoretically, spending RMB 2,000 (i.e., buying 50 blind boxes at RMB 40 each) should yield one seeded-team SSR card.
Users holding seeded-team SSR cards are eligible for additional official airdropped PFPs from Jingtan. Based on previously released PFPs by Jingtan,the prices of certain collectibles once surged to over RMB 8,000,which may be one of the reasons why seeded-team SSR cards have attracted significant attention. After all,if a PFP obtained via airdrop after spending RMB 2,000 can be resold for several thousand yuan, the profit would be quite satisfactory.
Only the top 50 holders of SSR card seed teams are eligible to receive physical gold coins valued between RMB 2,500 and RMB 10,000. Users holding single-digit quantities of SSR card seed teams are highly unlikely to rank within the top 50. The number of SSR card seed teams required to secure a top-50 ranking depends on users’ enthusiasm for and participation in this activity.The probability of receiving physical gold coins thus becomes nuanced.
In addition, the platform provides substantial utilities for SSR cards. Users holding SSR cards associated with the six goals officially recognized as the best goals of the UEFA European Championship may additionally receive “Best Goal Video Digital Collectibles.” If an SSR card is associated with the UEFA European Championship winner, users may receive a limited airdrop of 350 units of the Henri Delaunay Trophy Digital Collectible.
The drop rate for SR cards is 6%. Based on the six gameplay mechanisms described above, these cards currently carry no utility rights or benefits. Whether any will be added in the coming days depends on whether the platform issues further announcements.
The drop rates for R cards and C cards are 35.9% and 49.9%, respectively. In response to user feedback, the platform has added the following benefits.
The notice uses the phrase “small stakes, large potential gains,” demonstrating the organizer’s precise grasp of the gambling-like characteristics.。
02
Gambling-related risks: “small stakes, large potential gains”
Let us discuss “small stakes, large potential gains.”
In our previous article, “How Can Play-to-Earn Blockchain Games Avoid Being Classified as Gambling?,” Attorney Shao analyzed thatif a game involves gambling, it must simultaneously satisfy three elements:
1. Prerequisites for participation: Users are required to pay to purchase in-platform props or game currency;
2. Mode of operation: The gameplay involves elements of chance, whereby users participate in the game by "staking small amounts to pursue large gains," and there is a possibility of loss;
3. Outcome of returns: Users realize value, directly or indirectly, and obtain fiat currency;
In light of the foregoing rights and benefits officially empowered by the platform, the probability of users obtaining gold coins is extremely low. Users must draw an HR card with a 0.2% probability. The total prize pool comprises only 168 + 50 = 218 units. From a probabilistic perspective, even if most users obtain gold coins, the costs incurred (i.e., purchasing blind boxes) will far exceed the value of gold coins worth RMB 2,500–10,000. If users draw cards other than HR cards, they receive profile picture (PFP) assets or other collectibles. The currently available other collectibles consist of six "Best Goals" items and 350 limited-edition digital collectibles of the Henri Delaunay Trophy, which are accessible to only a very small number of users. Therefore, it can be said that users participating in this event are essentially seeking to obtain the official Jingtan sports PFP collectibles.
Let us further examine the market conditions for Jingtan PFPs on the X-Meta platform. Upon opening the X-Meta homepage, one immediately observes that the platform is sparing no effort in vigorously promoting the Jingtan UEFA Euro Cup offerings.
A search for previously issued Jingtan PFPs reveals that the prices of certain collectibles have been speculated up to more than RMB 8,000.
Although the official stance is that "any form of compensated transfer is not supported," we must examine the substance of the matter. Given last year's announcement adjusting the transfer window from 90 days to 24 hours, and the fact that the platform has not eliminated the current situation in which users engage in compensated transfers of collectibles on other consignment platforms, it is evident that the platform has still left "room for maneuver" for compensated transfers between users.
Although digital collectibles are defined as digital assets with collectible value, in the current market, the primary motivation for most domestic users to purchase digital collectibles is seldom genuine appreciation or a desire to collect. To put it plainly, users purchase a digital collectible because they see its potential for appreciation, intending to resell it later. Moreover, from the users' perspective, the shorter the holding period, the better; they would prefer to buy at a low price today and sell at a high price tomorrow.
Based on the foregoing analysis of the mechanics of the UEFA Euro Cup blind boxes launched by the official Jingtan platform, the reason for users' enthusiastic response to the UEFA Euro Cup blind boxes is their focus on the market value of the sports-edition Jingtan PFPs. Furthermore, Jingtan has made its first attempt at community operations for this UEFA Euro Cup event by establishing official off-platform community groups, demonstrating the platform's emphasis on this activity.
Amidst frenzied speculation by users in the consignment market and the support of related communities, the platform can attract greater traffic, which in turn fuels rising PFP prices in the consignment market. However, the official stance itself prohibits compensated transfers.Can losses resulting from users' "assumption of risk" be attributed to the platform?This is indeed quite intriguing.
The article concludes with a lively comments section, allowing readers to gauge the enthusiasm surrounding the Jingtan & UEFA Euro Cup campaign:

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