TENNESSEE | PRIME SKILL LOGIC 1.9.8 | AUTO_START OFF

SEE THE RESULT BEFORE YOU DECIDE TO PLAY

Effective May 22, 2026

Tennessee Public Chapter 1117

Tennessee Public Chapter 1117 expressly treats gambling, the operation or possession of gambling devices, and specified online or app-based gambling as unlawful. It also brings violations within the Tennessee Consumer Protection Act of 1977, with remedies that apply in addition to other penalties under state law.

The Act also covers conduct beyond operating a game. Its provisions address selling or distributing gambling devices, allowing them to operate on premises a person controls, and supporting, facilitating, or assisting gambling within Tennessee.

How the law applies to a particular system

Public Chapter 1117 does not identify, approve, or adjudicate Prime Skill LOGIC. It uses the existing Tennessee statutory definitions of “gambling” and “gambling device” in Tenn. Code Ann. § 39-17-501. Its definition of an “online sweepstakes game” begins with gambling in the form of a game, contest, or promotion and adds requirements concerning internet access, virtual or multiple currencies, prize exchange, and the simulation of gambling.

Applying these provisions to a particular system requires an assessment of its mechanics, configuration, transaction, and operating model under Tennessee law.

Prime Skill LOGIC’s product and legal position

In the Prime Skill LOGIC 1.9.8 configuration described in our Tennessee analysis, the result of an individual paid Play is fixed before the player commits. Players can inspect the information needed to identify that result without paying for the inspected result, then choose whether to accept or avoid the Play. The selected result does not change after Play begins.

Prime Skill’s documented position is that chance does not determine whether an award is granted in this exact system. The argument addresses the statutory relationship between chance and the return through the mechanics of each paid Play. It does not depend on a general “skill game” label or the cabinet’s appearance.

This product and legal position is specific to the system described above. It is not a Tennessee approval, license, safe harbor, placement authorization, or binding state determination. The exact build, configuration, venue, money flow, payout operation, and complete player experience remain material to any Tennessee analysis.

Read Tennessee Public Chapter 1117 (PDF) (opens in new tab)

Official Tennessee source: Public Chapter 1117, Senate Bill 2136, signed and effective May 22, 2026.

Prime Skill LOGIC makes the individual paid-Play result available to identify before commitment. The result is fixed, the player can inspect it without paying for the inspected result, and the player can reject or avoid it before choosing whether to Play.

REVIEW THE TENNESSEE LEGAL FRAMEWORK SEE WHY PRIME IS DIFFERENT

Separate 1,000-result lists by game and stakeFree future-result inspectionX = A/B − CInspect, switch, reject, avoid, or Payout/resetFixed result unchanged after commitmentAUTO_START OFF

THE QUESTION

Why this legal distinction matters in Tennessee

Tennessee defines gambling as risking something of value for a profit whose return is “to any degree contingent on chance” PDF (opens in new tab). The controlling definition appears in Tenn. Code Ann. § 39-17-501 (opens in new tab), available through the Tennessee General Assembly's official code portal (opens in new tab).

That wording makes the relationship between chance and the return the central disputed element. It does not ask only whether skill is present or whether skill predominates. Prime's position therefore focuses on the exact moment of an individual paid Play: when the player commits, the selected result is already fixed, available to identify without paying for it, rejectable or avoidable, and unchanged by the commitment.

This is a fact-specific legal position. It is not a claim that Tennessee has approved Prime Skill LOGIC.

OFFICIAL SOURCES

What Tennessee law says

Statute

1. The statutory definition focuses on chance and the return

Tenn. Code Ann. § 39-17-501 (opens in new tab) defines the relevant gambling terms, including the phrase “to any degree contingent on chance.” That phrase matters because the legal issue is not resolved merely by showing that a player uses skill. The issue is whether chance determines or conditions the return in the transaction being evaluated.

Authority type: binding statutory text.
Why it matters here: Prime's argument must address causation at the individual paid-Play commitment, not rely on a general “skill game” label.

Statute

2. Tennessee separately regulates gambling devices

Tenn. Code Ann. § 39-17-505 (opens in new tab) addresses possession of a gambling device. Device presentation and economic operation therefore matter alongside the play sequence.

Authority type: binding statutory text.
Why it matters here: reels, credits, paid stakes, redeemable value, and the payout path are relevant to characterization even when the decision mechanic is materially different from an ordinary slot.

Appellate decision

3. Tennessee appellate authority examines actual machine economics

In State v. Vance (opens in new tab), the Tennessee Court of Criminal Appeals affirmed convictions involving “Free Spin” machines whose credits could be exchanged for cash. The decision treated actual operation and economic substance as material, rather than allowing a patent, label, or claimed design purpose to control the legal result.

Authority type: published Tennessee appellate authority.
Why it matters here: Prime cannot win the analysis with branding. It must prove the exact pre-Play information, player choices, result invariance, configuration, money flow, and payout operation.

Attorney General guidance

4. The Attorney General reads “to any degree” literally

Tennessee Attorney General Opinion 16-13 PDF (opens in new tab) concluded that the presence of skill did not end the inquiry where a fantasy-sports return still depended to some degree on fortuitous future athletic events. Attorney General opinions are persuasive guidance, not court judgments.

Authority type: official persuasive guidance.
Why it matters here: Prime does not rely on skill merely predominating. Its narrower position is that the exact paid result is fixed, identifiable, avoidable, and invariant before the player commits.

Trial order

5. Torch is the nearest verified adverse machine record

The three-judge trial court's final order in Torch Electronics, LLC v. Mulroy PDF (opens in new tab), entered July 14, 2025, held the machines in that record to be gambling devices. The order rejected a limited pre-reveal structure where previewing the immediately upcoming prize depended on available credit and revealing the complete prize script was economically impractical. Tennessee Courts currently lists the matter as “Appeal” (opens in new tab).

Authority type: adverse current trial-level order with appeal status subject to change.
Why it matters here: Torch cannot be ignored, but its limited and credit-dependent preview record is not the same factual record as free inspection across Prime's separate persistent game-and-stake lists.

Enforcement / tax guidance

6. Enforcement and tax treatment remain separate from the merits argument

The Shelby County District Attorney reports continuing enforcement against no-chance gaming machines and similar devices, including machine seizures and criminal investigations, in its official Torch enforcement release (opens in new tab). The Tennessee Department of Revenue also states in GEN-36 (opens in new tab) that payment of amusement-machine tax or fees does not legalize a machine that is otherwise unlawful or authorize gambling.

Authority type: official enforcement statement and official tax guidance.
Why it matters here: registration, fees, or a product label do not replace the exact legal and factual analysis. Enforcement statistics show posture and exposure, not that Prime's exact system has been adjudicated unlawful.

THE DECISION PATH

Why Prime Skill LOGIC is materially different

Prime's distinction is not a slogan about skill. It is a sequence of verifiable facts that changes what the player knows and can do before an individual paid Play.

Separate lists preserve the relevant choice

Every game-and-stake combination has its own 1,000-result list, and each list keeps its position when the player changes games or stakes. The player is not limited to learning one next outcome on one shared path. Future-result information remains available across the separate choices.

Inspection occurs without buying the inspected result

The player can review future-result information without paying for the result being inspected. The system presents the values used in X = A/B − C, which identifies the relevant next board or result. The player may use a calculator and continue inspecting before deciding whether to commit.

An unfavorable result can be rejected or avoided

After inspection, the player can decline the paid Play, change the game or stake, inspect further, or use Payout/reset. These are decision routes before the inspected result is purchased, not remedies after an unknown result has already been bought.

Commitment does not alter the selected result

If the player accepts the inspected route and presses Play, the individual result remains the result identified before commitment. The paid action does not redraw, reroll, or change that selected result.

AUTO_START OFF preserves an individual manual decision

AUTO_START is OFF in the configuration described on this page. Each paid Play requires a manual action, preserving the point at which the player can inspect, reject, switch, continue reviewing, or leave.

These facts matter under Tennessee's statutory wording because they support a direct causal argument: at the individual paid-Play commitment, the return is not being determined by an unknown event after the player takes the risk. The result is already fixed and available to identify, and the player can avoid buying it. Tennessee has not issued a binding Prime-specific decision accepting or rejecting that argument.

ADVERSE COMPARISON

The closest adverse comparison

The table below compares mechanics, not legal labels. The ordinary-slot column describes the common paid-spin structure and is not a claim about every device. The Torch column reflects the facts described in the official 2025 final order PDF (opens in new tab). The Prime column describes frozen Prime Skill LOGIC 1.9.8 with AUTO_START OFF.

Question	Common ordinary-slot structure	Limited pre-reveal record in Torch	Prime Skill LOGIC 1.9.8
Can the player identify the exact paid result before committing?	The player commits before the specific result is disclosed for rejection.	The immediately upcoming prize could be previewed only with sufficient credit.	The relevant next result can be identified before paid Play using the displayed information and `X = A/B − C`.
Can the player inspect farther without paying for inspected results?	No equivalent free inspection route defines the common structure.	Revealing the complete script was described as economically impractical.	Future-result information can be inspected without paying for the inspected result across every separate game-and-stake list.
Can the player move among independent choices?	A paid spin normally initiates the result process offered by that game.	The court evaluated a limited preview mechanic in the machines before it.	Each game-and-stake combination has a separate 1,000-result list whose position persists when the player switches.
Can the identified result be rejected or avoided?	The specific result is not presented as a free pre-purchase choice.	The court found that moving information about prizes forward did not remove chance from the record before it.	The player can decline, switch game or stake, inspect further, or use Payout/reset before buying the identified result.
Does the selected result change after commitment?	The result is revealed through the paid play sequence.	The order evaluated the Torch sequence as a whole and held those machines unlawful.	The identified individual result is fixed before Play and remains unchanged after commitment.
What is the legal status?	Ordinary gambling devices may fall within Tennessee's gambling laws.	Adverse trial-level order; appeal currently listed.	No binding Tennessee Prime-specific determination. Prime advances a fact-specific `DEFENSIBLE INTERPRETATION`.

The comparison does not claim that Torch is defeated, irrelevant, or formally inapplicable. It shows why the statutory analysis should be conducted on Prime's complete mechanics rather than on the word “preview” alone.

THE POSITION

The strongest Prime position

Prime's documented product position is that chance does not determine whether the award is granted in the exact system. The legal argument focuses on the individual paid-Play commitment: the result has already been fixed, the information needed to identify it is available without paying for it, the player can reject or avoid it, and the accepted result does not change after commitment.

That argument directly addresses the phrase “to any degree contingent on chance” in Tenn. Code Ann. § 39-17-501 (opens in new tab). It also accepts the lesson of Vance (opens in new tab): legal characterization turns on actual operation and economics, not a name or patent. Prime therefore puts the inspection sequence, separate lists, formula, rejection routes, manual commitment, result invariance, logs, and payout operation at the center of the record.

This is Prime's strongest accurate position under current Tennessee authority. It is a DEFENSIBLE INTERPRETATION, not a claim of confirmed Tennessee law.

CANDID FACTS

Hard facts we do not hide

Prime Skill LOGIC uses reels, themes, jackpots, multipliers, a bill acceptor, credits, paid stakes, redeemable value, and venue-supported payout. Those facts are relevant to Tennessee's device and economic-reality analysis.

Info is mandatory when the player enters a game or changes the game or stake. On repeated paid Plays at the same game and stake, the system does not technically force Info to reopen or prove that the player completed a correct calculation before every Play.

These facts do not change Prime's established product position that chance does not determine whether the award is granted in the exact system. They do mean the legal analysis must test the complete operation, not isolate only the most favorable screen.

AUTHORITY BOUNDARY

The Tennessee record remains fact specific

Tennessee has not issued a Prime-specific approval, license, clearance, immunity, safe harbor, or binding determination for Prime Skill LOGIC 1.9.8. The Torch order PDF (opens in new tab) is a serious adverse machine precedent at the trial level, and the Tennessee Courts status page (opens in new tab) currently lists an appeal.

The absence of a Prime-specific determination does not change the documented mechanics or prevent Prime from publishing its fact-specific position. Product facts, Prime's interpretation of Tennessee law, and a binding state decision are three different things, and this page keeps them separate.

VENUE REVIEW

Why this model matters to a serious venue

A serious operator should be able to examine the decision mechanic instead of relying on a label. Prime's operating model supports that examination with a controlled 1.9.8 configuration, AUTO_START OFF, full event logs, build-identity records, formula and Info evidence, stake-and-result invariance testing, and payout records.

Those controls create an inspectable operating record. They do not promise revenue, indemnity, defense, state approval, or zero enforcement risk. They give a venue a concrete factual package to evaluate and preserve.

QUESTIONS

Frequently asked questions

Is Prime Skill LOGIC an ordinary slot machine?

It uses slot-like presentation and offers paid stakes and redeemable value, so those facts cannot be ignored. Its defining decision mechanic is different from the common slot sequence: before an individual paid Play, the result is fixed, available to identify without paying for the inspected result, and open to rejection or avoidance. Tennessee will look at actual operation and economics, as State v. Vance (opens in new tab) illustrates. This page does not claim a binding state classification.

What does the player know before Play?

The player can inspect future-result information for the separate game-and-stake lists and use X = A/B − C to identify the relevant next board or result. The player can then decline, switch the game or stake, inspect farther, or use Payout/reset. If the player proceeds, the identified result remains unchanged after commitment.

What role does skill play?

The player must inspect information, apply or verify a defined calculation, compare routes, and decide whether to accept or avoid the identified result. Prime does not argue that the presence or predominance of skill alone resolves Tennessee law. Attorney General Opinion 16-13 PDF (opens in new tab) explains why skill alone is insufficient when a return still depends on fortuitous events. Prime's narrower argument is that the exact paid result is already fixed, knowable, avoidable, and invariant before commitment.

What law is Prime relying on in Tennessee?

The central text is Tenn. Code Ann. § 39-17-501 (opens in new tab), which defines gambling by asking whether a return is “to any degree contingent on chance.” The analysis also considers the device provision in § 39-17-505 (opens in new tab), the economic-reality reasoning in State v. Vance (opens in new tab), the Attorney General's Opinion 16-13 PDF (opens in new tab), and the adverse Torch final order PDF (opens in new tab).

Has Tennessee approved Prime Skill?

No. Tennessee has not issued a Prime-specific approval or binding determination for the system described here. This page presents the product mechanics and Prime's documented legal position, with direct links to the authorities that frame the dispute.

Does paying amusement-machine tax settle the classification?

No. The Tennessee Department of Revenue states in GEN-36 (opens in new tab) that tax and fees do not legalize an otherwise unlawful machine or authorize gambling. Tax compliance and gambling classification are separate questions.

Review the mechanic, the law, and the record

Prime Skill LOGIC gives a serious venue something concrete to evaluate: separate persistent lists, free future-result inspection, a defined calculation, meaningful rejection routes, a fixed result that remains unchanged after commitment, and a manual paid decision with AUTO_START OFF.

REVIEW THE TENNESSEE LEGAL FRAMEWORK SEE WHY PRIME IS DIFFERENT

This page describes frozen Prime Skill LOGIC 1.9.8 with AUTO_START OFF and Prime's documented position based on the cited public authorities. It does not represent Tennessee approval, licensing, clearance, immunity, safe harbor, or a binding Prime-specific determination. Actual legal characterization can depend on exact build identity, configuration, operation, venue, money flow, payout practice, and current law.