Wisconsin / Legal position gauge

Elevated risk

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

Why this rating?

Wisconsin defines a gambling machine as a contrivance that, for consideration, affords an opportunity to obtain something of value, “the award of which is determined by chance, even though accompanied by some skill” (Wis. Stat. § 945.01(3)(a)). A published Court of Appeals decision held that convenience-store video machines with a “preview feature” letting patrons “determine in advance the outcome of any particular game” were still gambling machines. Using preview to skip a loss “simply eliminates the risk of losing money, not the element of chance for winning” (JD Prime). The Supreme Court had already held that lottery consideration exceptions—including in-pack chance promotions under § 100.16(2)—do not apply to gambling machines, and that dual-use features do not save a pay-to-play cash chance kiosk (Quick Charge). Article IV, section 24 forbids the legislature from authorizing gambling except in listed channels and expressly bars video gambling machines from even the state lottery. Commercial gambling involving gambling machines is a Class I felony (§ 945.03). The Department of Justice’s 2023 enforcement advisory treats preview games as finally resolved against operators. No reported Wisconsin decision has tested mandatory pre-reveal with exact monetary disclosure, genuine accept/decline, no charge on decline, and a finite predetermined prize pool as a single architecture. That remaining factual gap, plus the absence of any case against a full-pool reveal with mandatory pre-reveal, drops the rating from high risk to elevated. JD Prime tested an optional preview of a randomly generated next game—not a mandatory full-pool reveal. Quick Charge, the constitutional video-machine ban, and DOJ’s preview advisory keep the rating out of the moderate band.

This gauge also weighs that we identified no charges and no decided case in Wisconsin 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 GAMESWisconsin position brief
Wisconsin  /  Position brief

Wisconsin already judged the preview.
Chance survived the reveal.

In JD Prime Games Kiosk, the Court of Appeals held that a convenience-store video machine with a feature letting patrons “determine in advance the outcome of any particular game” was still a gambling machine under § 945.01(3)(a). Using that preview to skip a loss “simply eliminates the risk of losing money, not the element of chance for winning.” The Supreme Court had already held that lottery and in-pack-promotion exceptions do not apply to gambling machines. Article IV, section 24 forbids the legislature from authorizing gambling except in listed channels—and expressly bars video gambling machines from even the state lottery.

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

This brief analyzes the proposed transaction architecture under current Wisconsin law. It is not a finding of legality, Department of Revenue or Department of Justice approval, or authorization to operate cash-prize devices. Setting up or collecting proceeds of a gambling machine is commercial gambling—a Class I felony except the narrow Class “B” / “Class B” five-machine forfeiture path. Authorized channels include the state lottery (ch. 565), licensed bingo and raffles (ch. 563), pari-mutuel racing (ch. 562), tribal compact gaming, and—if compact amendments proceed—event or sports wagers under 2025 Wis. Act 247. None of those channels is a retail cash-device pathway for this architecture.

Wisconsin legal starting point

Wisconsin criminalizes commercial gambling, dealing in gambling devices, and permitting premises to be used for gambling machines that are not amusement devices or authorized-channel equipment.

Wis. Stat. § 945.01(3)(a)

Award determined by chance, even with some skill

A gambling machine is “a contrivance which for a consideration affords the player an opportunity to obtain something of value, the award of which is determined by chance, even though accompanied by some skill and whether or not the prize is automatically paid by the machine.” A bet and a lottery use the same “chance, even though accompanied by some skill” formulation. When skill is actually in issue, Hahn read that phrase to mean chance must predominate over skill. Cash video kiosks have been treated as chance-determined without needing a skill contest.

Wis. Stat. § 945.01(3)(b)

Amusement devices are cash-incompatible

The machine definition excludes (1) devices used in ch. 563 bingo/raffles, ch. 565 lottery, or ch. 562 racing; (2) amusement devices that reward exclusively with nonredeemable free replays and do not record or change the replay ratio; and (3) skill amusement devices that award only merchandise inside the device, each prize limited to the lesser of $5 or seven times the play cost. Cash redemption and operator-assigned video awards do not fit either amusement path.

Wis. Const. art. IV, § 24

Legislature may not authorize gambling in any form

Except as provided in section 24, the legislature “may not authorize gambling in any form.” Listed exceptions are bingo, raffles, on-track pari-mutuel betting, and a state lottery that itself may not include slot machines or devices “commonly known as a video game of chance or a video gaming machine.” Commercial gambling is a Class I felony; dealing in gambling devices is a Class I felony; permitting a machine on premises is a Class A misdemeanor (with a five-machine tavern forfeiture alternative).

Central timing question: § 945.01(3)(a) asks whether the contrivance, for consideration, affords an opportunity to obtain value “the award of which is determined by chance.” The NCG position is that at acceptance the accepted transaction’s monetary result is already fixed and disclosed—so the player is not giving consideration for an unresolved chance award. Wisconsin has not held whether that complete sequence escapes the machine definition, and JD Prime treated a preview-then-play sequence as still chance because the award was generated by chance.

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 Wisconsin law

§ 945.01(3)(a) requires consideration for an opportunity whose award is determined by chance. If the economic outcome is already fixed and disclosed before Accept, the strongest NCG argument is that the player is not giving consideration for an unresolved chance award—they are accepting a disclosed, predetermined transaction whose result is already known.

Contrary authority

JD Prime patrons could determine the outcome “in advance” and then choose whether to play. The Court of Appeals still found chance because the award was randomly generated. Prosecutors will quote paragraph 14 and argue that knowing the number before paying does not change how the number was selected. Casino-style presentation will invite the same DOR removal-order path used in that case.

Implementation risk

Weakening factors: showing cost/result after partial payment, allowing acceptance before disclosure renders, optional rather than mandatory preview, or mismatch between displayed and settled amounts. Any of those would collapse the remaining distinction from JD Prime and look like the optional-preview kiosk Wisconsin has already condemned.

JD Prime ¶ 14Preview is not a statutory defense
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

JD Prime described preview-then-skip-a-loss as eliminating the risk of losing money, not the element of chance for winning. NCG’s factual reply is that Decline is not “skipping a wager on a chance game”—it is refusing a disclosed sale, with no consideration moving for that offer. That framing is the distinction those opinions did not have to accept or reject as a complete architecture.

Contrary authority

Quick Charge treated inserted dollars as consideration even with unused free-play paths. JD Prime treated the operator’s revenue split as evidence that players lose in the aggregate. Prosecutors may argue the player purchased access to a sequence of chance-generated offers by earlier deposit, and that each Accept still “plays” a chance award.

Quick Charge ¶¶ 20–22No 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 Wisconsin authorities

JD Prime described awards as “randomly generated by the machines.” A finite predetermined pool assigned before the offer is shown is the cleanest factual distinction from that sentence. It is not a holding. Wisconsin courts have not decided whether a finite pool is still “determined by chance” when the player sees the assigned amount before paying.

Amusement-device problem

§ 945.01(3)(b)2.–3. allow only nonredeemable replays or small in-device merchandise on a skill path. A predetermined pool assigned by the operator or software is the opposite of player skill as defined in (b)3. (“precision, dexterity or ability to use his or her knowledge”). Cash-prize NCG play cannot be forced into the amusement exclusion.

Labels and dual use

Quick Charge kiosks were built from gambling-machine equipment with a cellphone-charging overlay. The Supreme Court held that § 945.01(3) “does not define a gambling machine as a contrivance whose sole use is gambling.” Presentation as entertainment, charging, or “no-chance preview” does not control.

Quick Charge ¶ 21JD Prime
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 Wisconsin 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. JD Prime and Quick Charge patrons could redeem credits for cash; redemption did not prevent a gambling-machine holding. Champeau held actual payouts are unnecessary once redeemable credits exist.

Limitation

Redemption does not cure an otherwise unlawful gambling machine. Gambling machines are contraband seizable under § 968.13. Prizes from an illegal lottery are forfeited to the state (§ 945.10). Municipalities may ban gambling devices by ordinance (§ 66.0107).

ILLUSTRATIVE CASH-OUT

$22.00 ticket+$0.67 cents→$0.00 remaining
Wis. Stat. § 945.10Exit 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 Wisconsin

Wisconsin machine cases turn on actual mechanics and how customers can use the system—not marketing labels. JD Prime treated optional preview as a reason the machines were gambling devices: players need not use it. Mandatory, non-bypassable pre-reveal is how that “unused preview” holding can be distinguished on facts. Hahn (1996) required proof that video poker was used for gambling; cash-redemption NCG terminals would be that use.

Implementation risks

Alternate clients, debug modes, optional preview, stale-offer acceptance, or server paths that charge on preview would collapse the remaining distinction from JD Prime and expose operators to Class I felony commercial gambling and device dealing, Class A misdemeanor premises liability, seizure as contraband, prize forfeiture, alcohol-license revocation under § 945.041, and municipal ordinances. Casino-style cabinets without the enforced accept/decline sequence are the fact pattern Wisconsin has already condemned twice.

Wis. Stat. § 945.03Engineering ≠ statutory permission
Required analysis

Has this exact model been tested in Wisconsin?

We did not identify a reported appellate decision in Wisconsin 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 Wisconsin courts and agencies have addressed—and how those systems differ

  • JD Prime Games Kiosk, LLC v. DOR, 2022 WI App 6, 400 Wis. 2d 499, 969 N.W.2d 778 — Published. Convenience-store video machines; players inserted money, received credits, and played slot-themed games redeemable for cash. An optional “preview feature” allowed patrons to “determine in advance the outcome of any particular game.” Circuit court held they were not gambling machines. Court of Appeals reversed: unused preview is pure chance; even used preview leaves the award determined by chance because it is randomly generated; skipping a previewed loss “simply eliminates the risk of losing money, not the element of chance for winning.” The Department of Justice later described the decision as final after the Supreme Court declined review. Closely analogous on preview-before-play cash video kiosks. Materially distinguishable if counsel can prove mandatory (not optional) disclosure, a finite predetermined pool (not play-time RNG), and a genuine no-charge decline that is not merely “skipping a losing wager.”
  • Quick Charge Kiosk LLC v. Kaul, 2020 WI 54, 392 Wis. 2d 35, 944 N.W.2d 598 — Unanimous Supreme Court. Cellphone-charging kiosks modified from gambling-machine equipment; customers paid to play a chance video game for cash. Unused mail-in / employee free-play options existed. Held: gambling machines under § 945.01(3)(a); lottery consideration definition and § 100.16(2) in-pack exception do not apply to machines; dual use does not negate the definition. Affirming 2019 WI App 51. Closely analogous on cash video kiosks and the wall between lottery exceptions and the machine statute. Materially distinguishable on the absence of mandatory pre-reveal accept/decline.
  • State v. Hahn, 203 Wis. 2d 450, 553 N.W.2d 292 (Ct. App. 1996) — Video poker is not a gambling machine per se; the State must prove gambling use and that collected proceeds derived from that use. The phrase “chance, even though accompanied by some skill” means chance must predominate over skill. Partially analogous on the chance test and use-based proof. Cash-redemption NCG terminals would be the gambling use Hahn required.
  • State v. Hahn, 221 Wis. 2d 670, 586 N.W.2d 5 (Ct. App. 1998) — § 945.01(3) is not unconstitutionally vague. Not applicable to NCG architecture; confirms the definition is enforceable.
  • Champeau v. City of Milwaukee, 2002 WI App 79, 252 Wis. 2d 604, 642 N.W.2d 634 — Video slots with redeemable credits were gambling machines even without proof that patrons actually received payouts. “Amusement only” signs and unused knock-off switches did not control. Partially analogous on prize/opportunity. Not applicable as a test of pre-reveal accept/decline.
  • Bohrer v. City of Milwaukee, 2001 WI App 237, 248 Wis. 2d 319, 635 N.W.2d 816 — If a promoter meets every requirement of § 100.16(2), the lottery-consideration exemption in § 945.01(5)(b)2.g. applies; courts will not add unstated conditions. Materially distinguishable: a lottery/sweepstakes case. Quick Charge held that exemption does not apply to gambling machines.
  • Attorney General opinions (not binding) — 80 Op. Att’y Gen. 53: the legislature may not authorize prize, chance, and consideration without a constitutional exception. OAG 2-96: licensing “amusement devices” that are gambling machines would violate article IV, section 24. 70 Op. Att’y Gen. 59: “Las Vegas nights” are illegal lotteries even for nonprofits. Guidance, not a judicial test of NCG architecture.
  • Wisconsin Department of Justice, Advisory on Video Gambling Enforcement (Nov. 14, 2023); DOR Fact Sheet 4100 (Dec. 2, 2024) — DOJ tells local agencies that charging-station hybrids and preview-feature games have been ruled gambling machines and that JD Prime is final. DOR restates felony exposure, the five-machine tavern forfeiture, seizure as contraband, and municipal-ordinance authority. Enforcement guidance, not a judicial test of NCG architecture.

Enforcement and regulatory activity (not judicial approval)

DOR issued removal orders in JD Prime and treats video gambling machines as contraband. Only DOR special agents may enforce the five-or-fewer-machine forfeiture path on Class “B” / “Class B” premises (§§ 945.03(2m), 175.38). Local agencies may enforce elsewhere and under municipal ordinances. 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 Wisconsin decision directly testing this architecture” is materially different from “A Wisconsin court has ruled this architecture legal.” Neither statement has been found true here. JD Prime is the closest published analogue—and it is adverse on preview-before-play cash machines.

No direct Wisconsin appellate precedent identified
Strongest contrary arguments

What Wisconsin prosecutors and regulators could argue.

1. JD Prime already rejected “see it first, then decide”

A published opinion held that preview-then-decline-a-loss eliminates the risk of losing money, not the element of chance for winning. Counsel must explain—with facts, not labels—why mandatory disclosure, a finite pool, and a no-charge decline are legally different from that sequence.

2. Chance is measured at generation, not at the player’s knowledge

Paragraph 14 locates chance in how the award is generated. If software assigns the number from a pool the player cannot control, prosecutors will call that chance even when the number is shown before Accept.

3. Lottery and sweepstakes exceptions do not apply to machines

Quick Charge is binding: § 945.01(5) consideration exceptions and § 100.16(2) in-pack promotions do not exempt a contrivance from § 945.01(3). A “sweepstakes kiosk” or “no-chance sale” label is the argument the Supreme Court already refused to import.

4. Amusement gambling is unavailable for cash or operator-assigned results

§ 945.01(3)(b)2.–3. require nonredeemable replays or small in-device merchandise on a defined skill path. Cash redemption fails both. OAG 2-96 warned that licensing amusement devices that are gambling machines would violate article IV, section 24.

5. Constitutional ceiling and felony exposure

Article IV, section 24(1) bars legislative authorization of gambling outside listed exceptions. Section 24(6)(c)8.–9. bar slot and video gambling machines even as a state lottery. Commercial gambling (§ 945.03) and dealing in devices (§ 945.05) are Class I felonies. Premises permission is a Class A misdemeanor. Alcohol licenses are subject to revocation (§ 945.041). Machines are contraband (§ 968.13). Illegal-lottery prizes are forfeited (§ 945.10).

6. Session-wide staking and unused-feature doctrine

Money inserted upfront creates a continuing credit balance. Quick Charge held that unused alternative uses do not negate machine status. Each Accept may be characterized as playing a chance award drawn from that balance—the structure JD Prime treated as paying for chances, not inspecting disclosed sales.

7. Current DOR / DOJ posture

The November 2023 DOJ advisory tells local law enforcement that preview-feature games are illegal gambling machines and that JD Prime is final. DOR Fact Sheet 4100 (December 2024) restates felony, forfeiture, and seizure exposure. Slot-like cabinets will invite the same investigative path even if backend logic differs.

NCG factual responses and residual risk

Responses: at acceptance the monetary result is fixed and known; declines cost nothing; no post-acceptance RNG; JD Prime preview was optional and described as randomly generated; Quick Charge did not involve mandatory pre-reveal; the amusement exclusion is not the NCG theory—the timing of § 945.01(3)(a) “award … determined by chance” is. Residual risk: published JD Prime preview holding, binding Quick Charge wall against lottery exceptions, a constitutional video-machine ban, Class I felony commercial gambling, seizure/forfeiture, and an explicit DOJ preview advisory remain material pending Wisconsin counsel review. The remaining distinctions are supportable; they are not settled, and they sit against the closest analogue in this fifty-state set.

JD PrimeAdverse 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 Wisconsin treats that sequence as a contrivance whose award is determined by chance under § 945.01(3)(a)—or as something materially different from the preview-then-play kiosks in JD Prime.”

This is the position to test—not a Wisconsin legal conclusion. Compare to JD Prime (optional preview of a randomly generated award; skipping a loss does not eliminate chance) and Quick Charge (pay-to-play cash chance kiosk; lottery exceptions do not apply).

  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 Wisconsin sources.

Verified . Binding precedent and statutes distinguished from Attorney General opinions and executive guidance.

  1. [1]
    Wisconsin statute · definitions

    Wis. Stat. § 945.01 ↗

    Bet; gambling machine (chance even though accompanied by some skill; amusement-device exclusions); gambling place; lottery (consideration defined only in this subsection, including the § 100.16(2) chance-promotion exception). Official legislature text. History includes 2025 Wis. Act 247 (sports-wager “bet” carve-out), which does not amend the machine definition.

  2. [2]
    Wisconsin Supreme Court · binding

    Quick Charge Kiosk LLC v. Kaul, 2020 WI 54 ↗

    392 Wis. 2d 35, 944 N.W.2d 598. Pay-to-play cash chance kiosks are gambling machines; lottery consideration exceptions and § 100.16(2) do not apply to § 945.01(3); dual use (charging, unused free play) does not negate the definition. Official Supreme Court PDF.

  3. [3]
    Wisconsin Court of Appeals · published / binding

    JD Prime Games Kiosk, LLC v. DOR, 2022 WI App 6 ↗

    400 Wis. 2d 499, 969 N.W.2d 778. Optional preview-before-play cash video machines held gambling machines; even used preview leaves the award determined by chance. Official Court of Appeals PDF. Petition for review was filed; DOJ treats the decision as final.

  4. [4]
    Wisconsin Constitution

    Wis. Const. art. IV, § 24 ↗

    Legislature may not authorize gambling in any form except listed bingo, raffle, pari-mutuel, and state-lottery channels. Section 24(6)(c)8.–9. bar slot machines and video gambling machines from the state lottery itself. Official legislature constitution text.

  5. [5]
    Wisconsin statute · commercial gambling

    Wis. Stat. § 945.03 ↗

    Commercial gambling—Class I felony—for setting up or collecting proceeds of a gambling machine, among other acts. Five-or-fewer video machines on Class “B” / “Class B” premises: forfeiture schedule in sub. (2m), enforceable by DOR special agents.

  6. [6]
    Wisconsin statute · premises

    Wis. Stat. § 945.04 ↗

    Permitting real estate to be used as a gambling place, or permitting a gambling machine to be set up for gambling—Class A misdemeanor, with the same five-machine tavern forfeiture alternative.

  7. [7]
    Wisconsin statute · devices

    Wis. Stat. § 945.05 ↗

    Dealing in gambling devices—Class I felony—for commercial manufacture, transfer, or possession with intent to transfer commercially of devices designed exclusively for gambling purposes, including gambling machines.

  8. [8]
    Wisconsin Court of Appeals · published

    State v. Hahn, 203 Wis. 2d 450 ↗

    553 N.W.2d 292 (Ct. App. 1996). Video poker is not a gambling machine per se; chance must predominate over skill under the statutory phrase; proceeds must derive from gambling use. Official Court of Appeals PDF. See also 221 Wis. 2d 670, 586 N.W.2d 5 (Ct. App. 1998) (definition not vague).

  9. [9]
    Wisconsin Court of Appeals · published

    Champeau v. City of Milwaukee, 2002 WI App 79 ↗

    252 Wis. 2d 604, 642 N.W.2d 634. Redeemable credits suffice; actual payouts not required; amusement-only signs do not control. Official Court of Appeals PDF.

  10. [10]
    Wisconsin statute · in-pack promotions

    Wis. Stat. § 100.16 ↗

    Selling with pretense of prize; in-pack chance-promotion exception. Cross-referenced by § 945.01(5)(b)2.g. for lotteries. Quick Charge holds this exception does not apply to gambling machines. See also Bohrer, 2001 WI App 237.

  11. [11]
    Wisconsin DOJ · enforcement advisory

    DOJ, Advisory on Video Gambling Enforcement (Nov. 14, 2023) ↗

    Tells local agencies that charging-station hybrids and preview-feature games have been ruled illegal gambling machines and that JD Prime is final. Guidance, not a judicial holding.

  12. [12]
    Wisconsin statute · forfeiture / DOR guidance

    Wis. Stat. § 945.10 ↗

    Prizes from a lottery conducted in violation of ch. 945 are forfeited to the state. See also DOR Fact Sheet 4100 (Dec. 2, 2024) on felony exposure, the five-machine tavern path, and seizure as contraband under § 968.13.

  13. [13]
    Wisconsin statute · municipal / sports-wager note

    Wis. Stat. § 66.0107 ↗

    Municipalities may prohibit gambling, including video gambling machines, on licensed or other premises. 2025 Wis. Act 247 creates § 945.01(1)(h) for certain tribal-server event or sports wagers; it is not a retail video-machine authorization and is the subject of pending constitutional litigation.

  14. [14]
    Wisconsin Court of Appeals · published

    Bohrer v. City of Milwaukee, 2001 WI App 237 ↗

    248 Wis. 2d 319, 635 N.W.2d 816. Full compliance with § 100.16(2) entitles a promoter to the lottery-consideration exemption; courts will not add unstated requirements. Distinguished by Quick Charge as a lottery, not a machine, case.

Disclaimer: This brief is research and issue-spotting for professional discussion—not legal advice, Department of Revenue or Department of Justice approval, tribal-compact authorization, or permission to operate. No Wisconsin Attorney General opinion specifically addressing mandatory pre-reveal NCG architecture was identified. Attorney General opinions are not binding precedent. An allegation, seizure, or removal order is not a holding. Absence of a decision testing this complete architecture is not a finding of legality. Wisconsin counsel should verify all citations, effective dates, local enforcement practices, compact and lottery exclusivity questions, the status of 2025 Wis. Act 247 litigation, and the actual deployed software before any compliance representation.