Are all probability-based mechanics requiring you to choose how you spend limited resources gambling?
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Who knows, but the act of paying for the chance of a prize is definitionally gambling. See slot machines.
There are slot machine mechanics in tons of videogames that dont have 18+ ratings because they don't cost real money to play
Hell, the very first Pokemon games on the Gameboy 30 years ago had slot machines.
Should those have had 18+ ratings?
Surely not. That would be absurd.
You spent time writing this post with the hope of earning the "prize" of karma. That's a higher price and a bigger prize than anything in Balatro