I'm not clear from the article that this is "random amounts" or even "of random cryptocurrencies." They just said "random wallets", which could mean a lot of different things.

Even if it is random cryptocurrencies, though, if they're smart, the amounts of each of said currencies should add up—at moment of sale, when converted to USD—to a constant amount. In that case, it'd be random ratios of each currency, to fill in a crypto "instrument." (Actually, I would expect this to be true if they have any business sense at all, since the only way to be able to do their books is if they can track their costs, which is only feasible if they have a fixed per-unit cost.)

Or, to put that another way, rather than a lottery per se, this might be more of a crypto-backed Collateralized Debt Obligation issuance where people don't get to know which tranch they're buying. (Which is legal, AFAIK; if it wasn't, the 2007 mortgage bubble couldn't have happened.)

Digging deeper, the TNW article provided more info and you’re right: they are buying $25 less than the price they charge for the package (between $75 and $475) worth of a random mix of a top 300 list of cryptocurrencies from an exchange, so it's probably not a lottery (unless some or all of the underlying cryptocurrencies are lottery tickets, which is probably not legally the case however much it might practically be.)

Is it that different from if I sell you a Euro, a Yen, a Dollar, and a Pound? They are fungible items whose value fluctuates.

How about if I sell you scrap gold jewelry on eBay? It's value will change before you get it and neither of us really knows how much gold is in it when the transaction takes place.

Have you ever seen a MSB offer Euros, Yen, or Dollars in random amounts as a product? Does not seem like the actions you list are similar at all to this situation.

I think this list of ETN/ETFs behave pretty similarly: https://money.usnews.com/funds/etfs/rankings/multicurrency

Based off that list are you saying companies like T. Rowe Price and Citigroup are offering ETNs and ETFs that have fund compositions that are random for each customer?

Obviously the value proposition is a little bit different but it seems close enough to rhyme. T. Rowe Price and Citigroup aren't saying "the best part about these funds is that you have no idea whats in them!" but in practice these funds behave similarly to the crypto flash drives.

I don't think that the etfs disclose which assets are held on any given day. From the consumers perspective they are buying some mix of currencies, although they don't know exactly which ones. It seems pretty random to me, just not different from the other note holders.

How about a fruit basket? I buy that without knowledge of what I am getting. But I think the sellers have badly communicated what they are selling. I don't think random applies to the amount. I think they might mean to say a collection of a bunch of currencies, funded with whatever amount it takes to get you in to that currency. There isn't really a way to know until they get a product page up.

So now you are comparing global mediums of exchange to fruit? Before you go too far maybe consider why we have FinCEN, FDIC, FTC, SEC, etc.

Good news! Florida is a FOR profit prison system. So, I am sure all of this will be looked at with thorough detail before plea deals are rolled out /sarcasm

http://www.orlandosentinel.com/opinion/os-ed-kiss-off-privat...

I am surprised they are not in Boca Raton, hq of most American based scammers

Is there something specific about their local laws that make it so appealing?

I don't really think there is much of a jurisdictional reason but it just tends to be a popular location for scammers. It could just be due to the location in regards to retired people.