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Tombola Edits WhitePaper Mid-ICO

We previously covered the Tombola ICO, calling it an outright scam, rather than the poorly planned and executed projected that it was appearing to be in July. The project having a bounty and airdrop campaign made it almost impossible to have any real conversation about the actual project in the bitcointalk forums.

Online Gambling Regulation for Lotteries

One of the largest arguments we had with the “Tombola team,” was getting any information on what countries their EOS lottery project would be promoted in and what steps had been taken to deal with regulators in each country.

Lotteries are generally owned and controlled by governments that use lotteries for tax revenue and Tombola could not answer anything regarding how their team plans to tackle that issue with all of the governments that have a military and police to stop illegal gambling operations.

Even when we pointed out the US considers a raffle an illegal lottery, Malta has arrested people, the Philippines pursue unregulated lotteries as well as China and Malaysia, the Tombola team would only comment that “Every country does not support same law and its variant and also has own Provision.”

Whitepaper Edited Mid-ICO

We had already posted many reasons their project, based on their previous whitepaper, would be unsuccessful for Tombola investors but the team changed and their entire whitepaper and project with the only notice to investors being ” Tombola now ERC20 based. Not more EOS  Grin

The Tombola Project for ICO was listed as the “first Cryptocurrency Lottery and Gambling platform based on EOS.”

This was listed on ICO websites promoting the active ICO:

About Tombola

The first Cryptocurrency Lottery and Gambling platform based on EOS. Fair and fun, but no gas spending. Tombola will be the standard of the world Game and Lottery platform

What is Tombola?

Tombola is EOS blockchain based lottery and gambling service that make it impossible to manipulate and provides clear information about all purchased tickets, lottery numbers, and winners
Technical Info

Tombola creates a hash value with seeds that are randomly generated in the EOS chain and with seeds in the player. The generated hash value uses the Tombola algorithm to calculate the results of the game. And All results are recorded in the block chain.

People already held the Tombola TBL Token at the time the project was suddenly changed to an ERC20 Token during the ICO. Tombola didn’t refund investors. They didn’t stop the ICO funding round or warn investors that the whitepaper would be edited. They just made one post in bitcointalk forum that it is now and ERC20 project.

The Previous Whitepaper Difference to the Edited Whitepaper

The old whitepaper (which we saved a copy of) before they edited had many advantages promoted by Tombola as better than Ethereum blockchain technology using their planned EOS lottery at the time. 

B-3. Problems of the existing blockchain lottery services
As for the conventional blockchain lottery services, they use bit coin and ethereum for their services. First of all, as for companies that use Bitcoin for their services, they manage the collected amount centrally through their own server that controls the amount of money due to the disadvantage of Bitcoin without smart contract function and distribute the prize money. This implies that they can manipulate the results at any time, or they can flee at night with the huge prize money.
As for Ethereum lottery services, you must pay an Ethereum gas fee. Ethereum has an Ethereum Gas (Gwei) that you have to pay to run smart contract codes in your structure. In the order of the higher amount to be paid for this gas, the miners have a system where they establish deals and must pay accordingly a kind of fee in addition to the Ethereum they must actually use. Although the lottery ticket amount includes fees, the user has to pay fees again. Currently Ethereum has a processing speed that can handle 100 transactions every 15 seconds. While Visa, a global credit card company, handles up to 25,000 transactions per second and China’s Alipay handles up to 50,000 transactions per second, Ethereum has a far slower speed. If a user receives a large amount of money as a jackpot, no one knows how long it will take to receive the prize money.

This was true when Tombola wrote their original whitepaper and is still true now that they have changed the project to an ERC20 Token. The Ethereum Network almost crashing due to crypto kitties last year was the first proof of such issues using ETH for games.

The main selling proposition Tombola had with their ICO was throughout the whitepaper as being an EOS project, as shown in the now redacted point:

D. Tombola with EOS DAWN. 3.0
Tombola plans to build coins and serve platforms based on EOS to solve the problems of existing block chain lottery and game services. Based on EOS blockchain Smart Contractor system, when the terms of the contract are met, it is designed to automatically send the amount of money at the correct time to the appropriate location. EOS has the advantage of being able to handle millions of projects per second and not having to pay for the Gas Fee the user has to use most often. Thus, users can eliminate the burden of double payment of fees and receive rewards quickly.

So the project now has less transactions per second and gas fee’s for the users now that it will be on Ethereum. This is similar to Tesla adding gas engines to their cars and brushing off investors concerns without any comment at all. It would tank the stock and that’s why no company does that and why ICO founders need no experience when marketing is the only solution they have for problems that arrive.


Anyone who currently bought the Tombola (TBL) Token previous to August 18th had bought a token based on a whitepaper that was to build an EOS Gambling platform. This was by a team that had no regard for regulation of gambling or lotteries and now they have conveniently changed the project to an ERC20 token project. The project would not need as much funding to run another lottery on Ethereum, as others exist already and the team will not be profitable with any actual product because they has almost no plan to begin with before changing the entire project.

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