The definitive answer is NO!
According to the US Unlawful Internet Gambling Enforcement Act (UIGEA) a Bet or Wager is defined as follows:
(1 ) BET OR WAGER.
The term 'bet or wager'—
(A) means the staking or risking by any person of something of value upon the outcome of a contest of others, a sporting event, or a game subject to chance, upon an agreement or understanding that the person or another person will receive something of value in the event of a certain outcome;
(B) includes the purchase of a chance or opportunity to win a lottery or other prize (which opportunity to win is predominantly subject to chance);
(C) includes any scheme of a type described in section 3702 of title 28;
(D) includes any instructions or information pertaining to the establishment or movement of funds by the bettor or customer in, to, or from an account with the business of betting or wagering;
Section (A) above clearly states, in layman's terms, that a bet or wager is when you are betting something of value and receiving something of value.... Once might say that a Jack has value because you 'can' pay for them, however you can also get them for free by simply playing the game... And, most importantly the person receiving the Jacks is not receiving anything of value because they can not sell them or cash them out...
(B), (C) do not apply because you are not purchasing a chance to win anything, but I included them for consistency.
(D) pertains to the bettor (the player in our case), moving funds to or from a betting establishment, which by definition (A), we are not.
To take this one step further even The following section is where it is describes what is excluded:
(E) does not include-
(i) any activity governed by the securities laws (as that term is defined in section 3(a)(47) of the Securities Exchange Act of 1934 for the purchase or sale of securities (as that term is defined in section 3(a)(10) of that Act);
(ii) any transaction conducted on or subject to the rules of a registered entity or exempt board of trade under the Commodity Exchange Act;
(iii) any over-the-counter derivative instrument;
(iv) any other transaction that
(I) is excluded or exempt from regulation under the Commodity Exchange Act; or
(II) is exempt from State gaming or bucket shop laws under section 12(e) of the Commodity Exchange Act or section 28(a) of the Securities Exchange Act of 1934;
(v) any contract of indemnity or guarantee;
(vi) any contract for insurance;
(vii) any deposit or other transaction with an insured depository institution;
(viii) participation in any game or contest in which participants do not stake or risk anything of value other than
(I) personal efforts of the participants in playing the game or contest or obtaining access to the Internet; or
(II) points or credits that the sponsor of the game or contest provides to participants free of charge and that can be used or redeemed only for participation in games or contests offered by the sponsor; or
(ix) participation in any fantasy or simulation sports game or educational game or contest in which (if the game or contest involves a team or teams) no fantasy or simulation sports team is based on the current membership of an actual team that is a member of an amateur or professional sports organization (as those terms are defined in section 3701 of title 28) and that meets the following conditions:
(I) All prizes and awards offered to winning participants are established and made known to the participants in advance of the game or contest and their value is not determined by the number of participants or the amount of any fees paid by those participants.
(II) All winning outcomes reflect the relative knowledge and skill of the participants and are determined predominantly by accumulated statistical results of the performance of individuals (athletes in the case of sports events) in multiple real-world sporting or other events.
(III) No winning outcome is based
(aa) on the score, pointspread, or any performance or performances of any single real world team or any combination of such teams; or
(bb) solely on any single performance of an individual athlete in any single real-world sporting or other event.
Notice that section (viii) says it is OK to "stake" or "risk" "personal efforts" which constitutes the time you take to play and that it is OK to "stake" points or credits that the sponsor of the game (Triplejack) provides to participants free of charge and that can be used or redeemed only for participation in games or contests offered by the sponsor..
Since Jacks are available free of charge (in other words, we are not requiring that you buy them in order to play) and you can not use them or redeem them for anything besides virtual things in the game, then again... It is not Gambling...
Of course this is the US regulation that governs the act of Internet gambling and does not necessarily address other countries, we are a US based company and as stated in our Terms and Conditions, Section 8 Player Eligibility, Access to Triplejack may not be legal in your jurisdiction and we do not warrant that it is.
I hope this information is helpful to those who have had concerns.