LEGAL OPINION

Tallinn, 27 January 2026

To: HuHu.game OÜ
Registry code: 17421993

We, Eesti Firma OÜ (registry code 14164797), acting as a professional service provider in the field of corporate and commercial law in the Republic of Estonia, holding a government licence for the provision of trust and company services No. FIU000144, issued by the Financial Intelligence Unit (FIU) of the Republic of Estonia, hereby issue this Legal Opinion at the request of HuHu.game OÜ.

1. PURPOSE OF THE LEGAL OPINION

The purpose of this Legal Opinion is to assess the legal nature of the business model operated by HuHu.game OÜ under the project name “HuHu – Hundred’s Hunters” and to determine whether the said business model qualifies as a game of skill under the laws of the Republic of Estonia. This Legal Opinion is limited to the legal qualification of the game mechanics and does not address licensing, regulatory approvals or supervisory procedures.

2. SOURCES OF INFORMATION

• information published on the official website huhu.game;
• descriptions of the game mechanics, compliance statements and terms of use provided by the operator;
• the Gambling Act of the Republic of Estonia (entry into force 01.01.2026).

No independent technical audit, software code review or operational testing was conducted.

3. DESCRIPTION OF THE GAME MODEL

• all participants interact within a single shared game environment;
• the game operates through a sequential counter progressing from 1 to 100;
• each player action advances the counter by one unit;
• the round is completed when the counter reaches a predetermined target value;
• the outcome depends on reaction speed, timing and active participation;
• mechanics are transparent and identical for all players;
• no randomness, chance or hidden algorithms are used.

4. APPLICABLE LEGAL FRAMEWORK

Pursuant to §3 (4) of the Gambling Act of the Republic of Estonia, games of skill are games “the outcome of which depends predominantly on the physical skills or abilities or knowledge of the player.”

5. LEGAL ASSESSMENT

The decisive factor influencing the outcome of each round is the player’s skill.

6. CONCLUSION

Based on the analysis above, we are of the opinion that the business model operated by HuHu.game OÜ constitutes a game of skill under the laws of the Republic of Estonia.

7. DISCLAIMER

This Legal Opinion does not constitute a regulatory approval, licensing decision or binding interpretation by any supervisory authority.

_______________________
Ilja Nikiforov
Lawyer / Management Board Member
Eesti Firma OÜ