What is the cash limit of legal game awards in China?

At present, there is no direct and clear definition of "gambling" in online games in China's laws or other legal documents, but we can still find the following relevant provisions in Notice II and Administrative Measures:

Article 20 of Notice 2: "Online game operators shall not distribute game props or virtual currency by lottery, betting, random drawing and other accidental means on the premise that users directly invest in cash or virtual currency."

Paragraph 3 of Article 18 of the Administrative Measures: "Online game users shall not be induced by random sampling to obtain online game products and services by investing in legal tender or online game virtual currency."

Based on the above provisions, it is not difficult to see that the key elements of the so-called "gambling" in the game are "investing in cash or virtual currency" and "accidentally obtaining game products and services". Notice 1 also contains restrictive provisions on "convenient conditions" that may lead to gambling:

Notice 1 Article 3: "... if the game is won or lost by gambling with game points, guessing games, etc. There are settings, and the number of game points won or lost by users in each game and every day should be set. It is not allowed to provide services such as trading game points in the form of "virtual currency" or exchanging cash or property in disguise, and strictly manage game points transfer services such as gifts and transfers between users to prevent convenient conditions for online gambling activities. "

For the differences and connections between the above-mentioned "virtual currency" and the "game currency" that we usually know and understand, please refer to the article "Why should we distinguish virtual currency from game currency in game design".

Second, the common gambling risk tips in online games at present

At present, the gambling behavior in online games includes the following common game design or operation methods that may involve gambling, in addition to the accidental methods such as "drawing lots, betting and random drawing" mentioned in Notice 2. Among them, except the game of opening boxes is explicitly prohibited, others belong to the so-called "edge ball" practice:

1, legal risks of "opening a treasure box" or "unpacking".

In this "mode", players can get a certain number of treasure boxes after completing some game tasks. Treasure boxes may contain game rewards, or they may just be empty boxes. The result will not be known until the player opens the treasure chest, but the player can only open the treasure chest with the key after spending cash or "virtual currency" to buy a special key. This is obviously contrary to the provisions of the above-mentioned Notice II, which has been clarified again in the Administrative Measures.