> > (2) Any digital game that is advertised or offered to a person for no monetary consideration.

I'd argue buying any form of MTX creates a monetary consideration. Though, I guess it is kind of a gray area that's gonna have to be ruled on.

> This solely refers to the game being available for free, not for any additional powerups or cosmetics being available for free.

I didn't intend to mean additional stuff being free. I meant additional stuff you can buy, resulting in the no monetary considerations carveout not applying.

This is absolutely not a gray area. MTX are monetary consideration. Free games in this case are more likely advergames.