PRIME SKILL LOGIC 1.9.8 | NEW YORK
Prime Skill LOGIC puts the decision before the individual paid Play.
For each game and stake combination, the next relevant result is fixed in a persistent 1,000-result list. The player can use Info/? and X = A/B - C to identify that result without consuming a paid Play, then choose whether to Play, switch game or stake, continue inspecting, decline, or use Payout/reset.
Once the player commits, the selected result does not change.
For the exact system described here, Prime Skill's established product fact is that chance does not determine whether the award is granted. How New York law classifies those combined mechanics is a separate legal question. Machine operation in New York remains on HOLD.
THE MECHANICS
Prime's position does not depend on calling the product a "skill game." It depends on what the system lets the player know and choose before each individual paid commitment.
Each game and stake combination has its own fixed list of 1,000 results and its own persistent position. Switching to another combination does not consume the result left behind.
Info/? presents the instructions and information needed to identify the next result. The system requires Info/? when the player enters a game and after a game or stake change.
The player uses X = A/B - C. The answer identifies the next relevant board in the 1,000-result table. The calculation produces an exact whole number, the player may use a calculator, and there is no time limit for inspection.
The table shows the value associated with the next result in credits. Inspection does not consume a paid Play or advance the selected list position.
The player can accept the identified result, switch game or stake, keep inspecting, decline the route, or use Payout/reset.
When the player chooses Play, the stake is deducted and the selected result is consumed. The result shown after commitment is the result identified before commitment. It does not change.
The current system requires Info/? on game entry and after game or stake changes. It does not technically force the player to reopen Info/? or prove a correct calculation before every repeated paid Play at the same game and stake. That limitation matters to the evidence and remains part of Prime's New York analysis.
Payout/reset zeros the local balance and local game information. Server audit records remain. A new deposit after Payout creates new lists.
How an additional deposit affects an already active session is not stated as a public product claim because the current technical sources conflict. Status: BRAK WIEDZY.
WHY PRIME IS DIFFERENT
New York's closest adverse machine analogy is Matter of Pace-O-Matic v New York State Liquor Authority. That cash-play game included a skill task, but the monetary prize amount in a later phase was randomly selected and was not revealed through the skill task before play. The court held that the agency could treat prize amount as part of the outcome.
Prime's combined facts are different. The next award-relevant result is fixed, can be identified without consuming a paid Play, can be rejected or avoided before commitment, and does not change after commitment.
| Question | Ordinary chance-based machine | Pace-O-Matic adverse analogy | Prime Skill LOGIC 1.9.8 | Why it matters |
|---|---|---|---|---|
| When is the award-relevant result known? | After value is committed | The later monetary prize was not revealed through the skill task before play | Before the individual paid Play, through free inspection | Knowledge before commitment bears on whether value is risked on an uncertain outcome |
| What determines the value shown to the player? | A chance-dependent machine event | The machine randomly selected the later prize amount | The fixed list position and identified result | Prime's position focuses on a known transaction, not an unrevealed prize |
| Can the player reject the result? | Not after initiating the event | The relevant prize amount was not available for informed rejection | Yes, before commitment the player can switch, inspect, decline or reset | Real avoidance supports player control or influence |
| Can the result change after commitment? | The event resolves after commitment | The prize remained unresolved through the skill phase | No | Post-commit immutability makes the commitment point auditable |
| Does automatic multi-Play apply? | Often available | Not the issue decided in the case | AUTO_START is OFF for New York | One action should map to one individual paid Play |
| Is the system approved for New York operation? | Only if lawfully authorized | The device was rejected on licensed premises | No approval is claimed and operation is on HOLD | A factual distinction is not a license or immunity |
ADVERSE THEORY — NOT ESTABLISHED PRODUCT FACT
An enforcer could define the economic outcome broadly, focus on upstream arrangement of finite lists, or emphasize cash, credits, reels, jackpots, multipliers, free spins, redemption and server components. An enforcer could also invoke New York's electronic-sweepstakes statute as an analogy because that statute addresses server-based devices, finite pools and predetermined reveals.
That theory is not Prime Skill's product fact. Penal Law § 156.40 still defines a sweepstakes through a prize whose determination is based upon chance. Prime's established product fact for the exact system is that chance does not determine whether the award is granted.
NEW YORK LAW
Prime's New York position is a DEFENSIBLE INTERPRETATION, not confirmed authorization. It depends on proving the exact mechanics at the individual paid commitment. Labels, cabinet appearance and a generic skill claim do not decide the issue.
FORMAL AGENCY PROCESS
SAPA § 204 allows a person to petition a New York agency for a declaratory ruling on a rule or statute that agency enforces, or on whether the agency should act under a rule. A valid ruling binds that agency within its scope, subject to prospective change, court review and superseding legislation.
The Gaming Commission's 9 NYCRR § 5000.8 requires a written petition sent by certified mail, a complete and precise fact statement verified under oath, the legal provisions relied upon and disclosure of the petitioner's interest. The Commission may decline. An ordinary letter, email, opinion or announcement is not a declaratory ruling unless it expressly qualifies under the rule.
No Prime Skill petition has been filed and no ruling has been issued. Whether the Commission will accept jurisdiction over this independent physical retail kiosk and Penal Law article 225 is BRAK WIEDZY. A Commission ruling would not automatically bind prosecutors, police, courts, municipalities, the State Liquor Authority or another agency. It would not by itself create a stay, immunity or placement authorization.
Read SAPA § 204 (opens in new tab)
Read the official Gaming Commission Chapter III rules (opens in new tab)
EVIDENCE BOUNDARY
This page applies only to Prime Skill LOGIC 1.9.8 with AUTO_START OFF and only where the actual system matches the mechanics described here.
X = A/B - C must identify the exact next result.BRAK WIEDZY until a signed manifest exists.CORE_CONFLICT and is not a public product claim.ENFORCEMENT REALITY
New York actively enforces gambling and consumer-protection laws. In June 2025, the Attorney General announced that 26 online sweepstakes-casino platforms would stop selling cash-redeemable sweepstakes coins to New Yorkers.
Those online platforms used a different channel and different mechanics. The action does not decide Prime Skill LOGIC. It does show that labels and promotional structures will not prevent scrutiny where the state sees cash-redeemable gambling.
Read the Attorney General's 2025 enforcement announcement (opens in new tab)
Prime's response is proof of the exact commitment point, not a claim of zero risk.
FOR VENUES
The New York page is ready for implementation. The machine is not authorized for New York operation.
No venue should treat this page as approval, availability, a placement offer or permission to accept cash, initiate paid Play, redeem credits or make payouts.
Alcohol-licensed premises carry a separate enforcement channel. ABC Law § 106(6) states that an on-premises licensee may not suffer or permit gambling, and the State Liquor Authority lists gambling among frequent retail violations. Exact consequences depend on the license and facts.
Read ABC Law § 106 (opens in new tab)
Read State Liquor Authority enforcement guidance (opens in new tab)
Local zoning, fire, electrical, signage, business and nuisance requirements depend on the exact address. No New York location has been approved. Status: BRAK WIEDZY.
Prime has a defensible interpretation based on the exact pre-Play mechanics. No controlling New York decision identified through August 21, 2026 authorizes this exact cash-accepting, redeemable-value system. Machine operation remains on HOLD.
No. Prime claims no New York approval, license, placement authorization or immunity.
No. No petition has been filed and no declaratory ruling has been issued.
No. Whether the Commission will accept jurisdiction is BRAK WIEDZY. A ruling would bind the Commission within its lawful scope, not automatically every prosecutor, police agency, court, municipality, liquor authority or other agency.
It identifies the next relevant result for the selected game and stake from the displayed values and the persistent 1,000-result table.
No paid Play is consumed by inspection. The player can review the information and choose another route before the individual paid commitment.
No. The current system requires Info/? on game entry and after a game or stake change. It does not technically require a new Info/? interaction or proof of a correct calculation before every repeated Play at the same game and stake.
Under the established product facts for the exact system, no.
No. For the exact system covered by the established product facts, chance does not determine whether the award is granted. A different regulator or prosecutor characterization is addressed in the labeled adverse-theory section above and is not an established product fact.
OFF. AUTO_START ON remains NO-GO for New York.
Not under the current status. One public machine is not a statutory safe harbor, and New York law includes a public-place device presumption.
No. It authorizes this website copy for implementation only. It does not authorize transport, placement, activation, cash-in, paid Play, payout or operation.
PROOF BEFORE PLACEMENT
Prime's New York position depends on evidence that the result was fixed, identifiable, avoidable and unchanged before each individual paid commitment. Review the commitment-point record before making any operational assumption.
This page describes Prime Skill LOGIC 1.9.8 only in the New York AUTO_START OFF configuration and presents Prime Skill's interpretation of public New York law as of August 21, 2026. It is not a New York license, approval, declaratory ruling, court ruling, placement authorization, immunity, guarantee of legality, guarantee of outcome or statement of zero enforcement risk. No Prime Skill declaratory-ruling petition has been filed and no agency ruling has been issued. Website-copy authorization applies only to implementation of this page. It does not authorize transport, placement, activation, cash-in, paid Play, payout or operation of a machine in New York. The analysis depends on the exact build and the exact combined mechanics described here. Location, alcohol-license, local-law, tax, financial and operational facts require separate verification. No nonpublic technical report is named, quoted, linked, badged or offered for download.