What is Online Gambling?

You're the one who derailed it.

This game has gambling features that require you to first make a purchase before you use them. That's Consideration. There's no free method of entry. That means it's not a sweepstakes.

No, I stayed on topic, you deflected at an attempt to distract from the point.

First off, gachapon does not require a purchase, no nx item requires it. Surveys and events completely destroys that point, which is the last bit of land you stand on. I didn't think I'd have to bring this up either, but oh well. In order to be in violation of online gambling (UIGEA), they have to knowingly accept payments that are used as wagers. The cash shop has thousands of items which the card gives you access too, there's is no legitimate way to prove that NX is bought specifically for gambling activities.