Q: Can a small business host online raffles/lottos?
I have an online based game for kids and young adults 13 and up. It's through an LLC registered in the state of Washington and I'd like to have many minigames including a monthly raffle for rare in game items and a weekly lotto. It would all be strictly a free in-game currency for virtual prizes. The only thing I'm unsure of is although the currency is free, there is an indirect way that user can convert the "cash" currency to the free currency, meaning that there is a way - however indirect - that people could spend real money on these lottos/raffles.
Is something like this allowed with Washington state gambling laws? I'm having a hard time finding specifics on in-game currencies.
A: Maybe. Online prize law is not a well developed area of law yet, and involves not only the consumer protection act, but banking and sometimes securities laws as well. The state statute RCW 19.170 (http://app.leg.wa.gov/RCW/default.aspx?cite=19.170&full=true) governs promotions, disclosures and violations with regard to consumer protection. RCW 19.240 (http://app.leg.wa.gov/RCW/default.aspx?cite=19.240&full=true) governs gift certificates. You might want to start there, or consult an attorney who practices in the area of gaming law. Go to the Washington State Bar Association website and search for lawyers who practice in the area of entertainment law, which is the broader heading under which gaming falls. (https://www.mywsba.org/Default.aspx?tabid=191&ShowSearchResults=TRUE&Status=Active&AreaOfPractice=Entertainment). From there you can sort by location to find someone near you.
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