'free gifts, etc.' in Article 28(3) of the Game Industry Act means 'goods or similar that are provided to the user of the game product as a result of using the game product, which is a property benefit. Regardless of the legal nature of NFTs and other virtual assets, their property value (property interest) is recognized, so NFTs and other virtual assets are equivalent to ‘free gifts, etc.’. The question is, if you're offering a free gifts, is there a case for not promoting speculation? However, our precedent suggests that the provision of prizes or other incentives in and of itself encourages gambling and constitutes a violation of the Gaming Industry Act. However, our precedent suggests that merely offering a free gifts promotes speculation. In the current era of online gaming (including mobile gaming), few game operators operate with a business model that lures users with free gifts. Rather, free gifts have become an integral part of the game content, and some game operators use them as a way to share or give back to their users. While such a need may have been recognized at the time of the legislation, the notion that the offer of a free gifts is sufficient to satisfy the requirements of Article 28(3) should be reconsidered. In short, a legislative decision is needed that would prohibit the offer of a free gifts if it is "likely to promote speculation” but allow the offer of a free gifts that is "not likely to promote speculation”.