I think your question is too complex and requires more analysis than is typical for the questions on this site. You really need to sit down with an internet attorney if you are starting this business. The consequences of doing it wrong are too severe AND you would be much better off having a paid attorney analysis. In other words, showing the authorities an answer from this website is not going to be a show of due diligence on your part to avoid legal ramifications. Rather it will be a recognition that liability may exist if you do it wrong.
If you'd like to discuss, please feel free to call. Jeff Gold Gold, Benes, LLP 1854 Bellmore Ave Bellmore, NY 11710 Telephone -516.512.6333 Email - Jgold@goldbenes.com
This might be workable but really needs a lot of work. It is not clear how you would profit but obviously the "house" would take a cut of the proceeds. You would also need to be very saavy jurisdiction wise. But to answer your question - maybe but no one is going to be able to tell you without a full consultation. Give me a call at 202-318-2406 if you want to schedule one.
This is not legal advice but a general comment on society based on a limited set of hypothetical circumstances. No one should act or refrain from acting based on these comments without seeking appropriately licensed legal or professional advice. The author disclaims all liability in respect to actions taken or not taken based on his comments.