Prediction-market ISV legal review
An independent software vendor, or ISV, supplies software around a prediction market. Apparently Law examines the actual functions, compensation, relationships and restrictions; the ISV label alone does not establish a registration exemption.
What it covers
- Venue integration and account relationships
- Order routing, discretion, recommendations and custody boundaries
- Fees, referrals and other compensation
- Partner restrictions and the product facts a legal opinion describes
Questions operators bring
- Which functions does our interface perform for the user or venue?
- Who controls an order and who holds funds or assets?
- Do changes to compensation or recommendations require further review?
- Which federal, state and partner requirements need to be addressed?
Review the integration, not just the interface
Bring the venue relationship, integration design, order and account journeys, compensation terms and public disclosures. The review should identify what the vendor actually does and which assumptions or restrictions the opinion depends on. An ISV designation alone does not establish legality, registration status or partner approval.
What to bring to the first conversation
A product walkthrough, proposed jurisdictions, payment and value flows, partner agreements, public rules and any existing legal opinion. A draft opinion and an issued opinion are different: counsel must review the facts before signing.
For a payment processor, the engagement addresses the legal questions and opinion evidence within its scope. The processor retains its own merchant approval decision.
Building the product? Explore Apparently AI, a separate software company. Software output is not the firm’s legal advice.
Research on this subject
- Oct 17, 2026Prediction markets: building on the Phantom letter — passive software, introducing broker or commodity trading advisor
- Oct 17, 2026Prediction markets: building a company — the layers, how each is paid, and where a startup can compete
- Oct 17, 2026Prediction markets: passive software, introducing broker or advisor — the three paths compared
- Oct 17, 2026Prediction markets: a build checklist for staying inside the passive-software letter
- Oct 17, 2026Prediction markets: seven businesses inside the stack
- Oct 17, 2026Prediction markets: how each layer makes money
Apparently Law advises on gaming and prediction-market law in every U.S. state and territory, working with local counsel where a jurisdiction requires it.