Legal / Position Statement
Skill-Based Gaming Position Statement
Last updated: May 2026
1. Summary
Carpe Five (operated by IWTBNB Group) operates a suite of timing-based competitive games. The outcome of every competitive event on the platform is determined by the player's precision in stopping a running timer at a specific target moment. Random elements — where present — are bounded, equalised across all competitors in a round, and disclosed in advance. The platform does not operate any product whose outcome is randomly drawn during play.
2. Game Modes & Skill Mechanics
Each mode below names (a) the player input that determines outcomes, (b) any random element, and (c) how that random element is bounded.
Main Game
- Input ·
- The player presses START to begin a five-second timer, then presses STOP. The server measures the elapsed wall-clock time. The closer to 5.000 s, the higher the reward; clearing all 10 levels qualifies the player for the seasonal Grand Prize.
- Random element ·
- None.
- Bounds ·
- N/A — outcome is a deterministic function of the player's reaction precision.
Time Attack
- Input ·
- Five consecutive 5-second rounds. The sum of absolute errors across all rounds determines the tier reward.
- Random element ·
- None.
- Bounds ·
- N/A.
Daily Gauntlet
- Input ·
- Five randomised target tolerances per day. Players compete on win count first, cumulative error as tiebreaker.
- Random element ·
- The five tolerance values for the day are seeded from the calendar date (same five values for every player worldwide on a given day).
- Bounds ·
- Same seed for every player, so the random element does not differentiate competitors — it merely sets the day's difficulty profile. The day's seed is publicly derivable and can be audited.
Tournaments
- Input ·
- Time-windowed competitions using one of the modes above (currently Time Attack or Daily Gauntlet). Ranking is by sum of errors / win count, as appropriate for the underlying mode.
- Random element ·
- Inherits from the underlying mode (none for Time Attack; Daily Gauntlet inherits the same per-day shared seed used in the free flow).
- Bounds ·
- N/A — equalised across competitors per the duplicate model.
BINGO
- Input ·
- The player buys 1–10 cards. Each card carries a 5×5 grid of target second-values (1.0 s to 5.0 s, step 0.1 s). The player presses STOP; the server snaps the elapsed time to the nearest 0.1 s and fills every cell across the player's hand carrying that target value. Pattern completion (line / X / outer frame / full BINGO) determines the per-round payout tier.
- Random element ·
- Card-layout generation: which target value occupies which of the 24 non-centre positions on each card.
- Bounds ·
- Duplicate-card model. The same ten layouts are committed at round start and served to every player in that round (card #N is identical for every participant). Position-distinct constraint. If the same target value appears on more than one card, it occupies a different grid position on each card. Per-value spread cap. No target value appears on more than 8 of the 10 cards. Pre-commit disclosure. All ten layouts are visible to the player before the player decides whether to buy additional cards. Seed audit. Each round's layout seed is stored in
bingo_games.layout_seedand published on the Fairness page.
3. Why "Equalised Randomness" Is Not Chance
A random element that affects every competitor in the same way does not introduce chance into the determination of the winner. This is the legal basis under which duplicate bridge tournaments, daily fantasy sports, and tournament poker are treated as skill-based by the predominant-purpose test in the United States and the "skill-element-sufficient" test in much of the Commonwealth.
In BINGO specifically, every player in a given round sees identical card layouts. A given player's rank against other players in that round is therefore determined purely by (i) timing precision and (ii) strategic decisions about which cards to buy and at what value to aim — both of which are exercises of skill.
4. Free-to-Enter Architecture
The platform is operated as a free-to-enter skill competition:
- The Main Game, Time Attack, and Daily Gauntlet are entered with in-game «hearts», which are awarded via daily check-ins, free task completion, and refilled on a timer.
- BINGO and Tournaments use Billionaire Coins (BC), which can be earned without payment through gameplay. While BC may also be purchased, no purchase is required to participate in any aspect of the platform, including qualification for the Grand Prize.
- The Grand Prize pool is funded by advertising revenue accumulated platform-wide and is not derived from player consideration.
5. Jurisdictional Carve-Outs
The platform is geo-blocked at the edge (IP-country detection) for the jurisdictions listed below. The list reflects the current state of our legal review and may be expanded as regulatory clarity emerges in additional markets. Currently restricted:
- Mainland China (CN) — gaming licensing framework + capital controls
- South Korea (KR) — Game Industry Promotion Act restrictions on real-money skill gaming
- Saudi Arabia (SA), United Arab Emirates (AE), Qatar (QA), Kuwait (KW), Bahrain (BH), Oman (OM) — local statutes that treat any prize-bearing competition involving consideration as restricted regardless of skill content
- Iran (IR), Iraq (IQ) — sanctions / sectoral restrictions and unfavourable regulatory environment
Players with an IP address that resolves to any of the above are redirected to a static /blocked page and cannot access the platform. Circumventing the block via VPN or other means is a violation of the Terms of Service (§16) and grounds for account termination plus forfeiture of all in-platform balances. In every other jurisdiction, the platform is offered subject to the user's own confirmation that local participation is lawful.
6. Comparison Cases
The platform's position aligns with the following lines of authority and industry practice:
- Duplicate bridge — recognised as a skill game in essentially all common-law jurisdictions; the random deal is identical across tables, so chance does not differentiate competitors.
- Daily fantasy sports (DFS) — recognised as skill-based by majority of US states (Humphrey v. Viacom and successor cases) on the predominant-purpose test; the random element (athlete performance variance) is equalised across the player pool.
- Tournament poker — recognised as skill-based for federal purposes (United States v. DiCristina, 2012, E.D.N.Y., reversed on appeal but illustrative of the predominance analysis); duplicate-deal poker formats are accepted skill games in most jurisdictions.
- eSports tournaments — universally accepted as skill-based competitions.
- Reaction-time skill platforms — Skillz Inc. and analogous operators have built large skill-based gaming businesses on a structurally similar "skill-determines-rank" foundation.
7. Skill Predominance — Empirical Verification
The platform commits to publishing periodic statistics demonstrating skill predominance, including: per-mode win-rate distribution by player skill decile, correlation of cumulative play time with win rate, and top-1% vs bottom-1% comparative win rates. Initial statistics will be published once a statistically meaningful population of players has competed across multiple seasons.
(Pending — to be backfilled at season 2 boundary.)
8. Responsible Play
The platform implements several responsible-play measures:
- Age gating to 18+ at registration.
- Hearts (free-entry currency) regenerate on a fixed cadence regardless of play activity.
- BC purchases are capped per transaction and per period.
- No in-game mechanics push the player to recover losses via increased spending.
- Account self-exclusion is available upon user request.
9. Contact
Counsel reviewing this position or partner KYC packets requiring further detail may contact us through the contact page.
⚠️ Legal-review notice
This statement is the platform's public position. It is not legal advice. Final classification in any target jurisdiction must be confirmed in writing by qualified counsel admitted in that jurisdiction. Partners (advertising, banking, settlement) considering an engagement may request the latest counsel-reviewed version.