Gala(GALA) Whitepaper
CRYPTO-ASSET WHITE PAPER - [GALA]
Version Number: 1.0
Document Type: White Paper
Document Author Offeror: OKX Europe Limited
Document Status: APPROVED
Language: English
TABLE OF CONTENTS
I. DATE OF NOTIFICATION II. STATEMENTS III. WARNING IV. INFORMATION ON RISKS
Offer-Related Risks
Issuer-Related Risks
Crypto-Assets-Related Risks
Project Implementation-Related Risks
Technology-Related Risks
Mitigation Measures V. GENERAL INFORMATION A. Information of the Offeror or the Person Seeking Admission to Trading B. Information of the Issuer C. Information about OKX Europe Limited ("OKX") VI. INFORMATION ABOUT THE CRYPTO-ASSET D. Information about the Crypto-Asset Project E. Information about the Offer to the Public of the Crypto-Asset or Its Admission to Trading F. Information about the Crypto-Assets G. Information about the Rights and Obligations Attached to the Crypto-Asset H. Information about the Underlying Technology I. Information on the Principal Adverse Impacts on the Climate and Other Environmental-Related Adverse Impacts of the Consensus Mechanism Used to Issue the Crypto-Asset. VII. GLOSSARY
I. DATE OF NOTIFICATION
The Date of Notification of this Crypto-Asset White Paper is 2025-11-20.
II. STATEMENTS
A. This Crypto-Asset White Paper has not been approved by any Competent Authority in any Member State of the European Union. OKX Europe Limited is solely responsible for the content of this Crypto-Asset White Paper.
B. This Crypto-Asset White Paper complies with Title II of the Regulation (EU) 2923/1114, to the best of the knowledge of the management body, the information presented in the Crypto-Asset White Paper is fair, clear, and not misleading and the Crypto-Asset White Paper makes no omission likely to affect its import.
C. The Crypto-Asset White Paper provides that GALA may not be transferable, or liquid, or lose its value, in part or in full.
D. The Utility Token referred to in this Crypto-Asset White Paper may not be exchangeable against the good or service promised in the Crypto-Asset White Paper, especially in the case of a failure or discontinuation of the Crypto-Asset Project. This statement is TRUE.
E. The Crypto-Asset referred to in this Crypto-Asset White Paper is not covered by the investor compensation schemes under the Directive 97/9/EC of the European Parliament and of the Council.
F. The Crypto-Asset referred to in this Crypto-Asset White Paper is not covered by the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.
III. WARNING
A. The summary should be read in conjunction with the content of the Crypto-Asset White Paper.
B. The Prospective Holder should base any decision to purchase this Crypto-Asset on the content of the Crypto-Asset White Paper as a whole and not on the summary alone.
C. The offer to the public of the Crypto-Asset does not constitute an offer or solicitation to purchase financial instruments and that any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable National Law.
D. This Crypto-Asset White Paper does not constitute a prospectus as referred to in the Regulation (EU) 2017/1129 of the European Parliament and the Council or any other offer document pursuant to the European Union or National Law.
E. The crypto-asset GALA is a utility token that operates as a native asset on the GalaChain blockchain, an ERC-20 token on Ethereum, and as an SPL token on the Solana blockchain. It is designed to function as the primary medium of exchange within the Gala ecosystem, which includes gaming, music, and film platforms. The token has a maximum supply of 50 billion units.
F. Holding the GALA token provides access to the Gala ecosystem. The token's primary functions are to serve as a payment method for digital assets (e.g., NFTs) within the ecosystem's applications, to cover transaction fees (gas) on the proprietary GalaChain, and to act as a reward mechanism for Founder's Node operators who provide computational resources to the network. Founder's Node operators may also use their position to participate in governance votes on ecosystem-related proposals. The GALA token does not grant holders any rights to financial returns, dividends, or ownership claims against the issuer or its assets. The GALA token is freely and instantly transferable, utilising the underlying blockchain network's standard processes.
G. This whitepaper is published solely in connection with the admission to trading of the GALA token on OKX Europe Limited's trading platform. There has been no offer of the crypto-asset to the public, and the crypto-asset has not been made available in exchange for fiat currency or other crypto-assets prior to its listing. The crypto-asset will be admitted to trading via OKX Europe Limited, an authorised crypto-asset service provider ("CASP") operating within the European Union. The trading admission does not involve any subscription, sale, or fundraising process. The purpose of this document is to provide key information regarding the characteristics of the crypto-asset, its governance, rights, and associated risks, to enable informed decision-making by users and market participants in the context of its admission to trading. Access to the crypto-asset on the trading platform may be subject to user verification, platform conditions, or applicable legal restrictions depending on the jurisdiction.
IV. INFORMATION ON RISKS
1. Offer-Related Risks
This whitepaper is submitted by OKX Europe Limited solely for the purpose of the assets admission to trading. No public offer of GALA tokens is being made by the issuer or OKX Europe Limited.
Risks associated with the admission to trading include;
Service-related Interruption; Holders may be unable to access the utility due to technical, operation, or regulatory disruptions.
Jurisdictional limitations; GALA services or token utility may not be available in all jurisdictions, potentially restricting access.
Platform Reliance; Access depends on third-party infrastructure (wallets,platforms) and service interruptions or failures may affect token utility.
Limited Liability; OKX Europe Limited assumes no responsibility for the issuers project continuation, and token ownership does not confer contractual rights or guarantees.
Unexpected Risks: Beyond the risks outlined in this whitepaper, there may be additional risks that are currently unforeseen. It is imperative to note that certain risks may emerge from unforeseen events, changes, or interactions among factors that are difficult to predict. These unexpected risks may significantly and negatively impact the crypto-asset, the project, or the parties involved.
2. Issuer-Related Risks
Operational Risks; There is a risk that the issuer may face financial or operational difficulties, including insolvency, which could impact the continued development or availability of the services associated with the GALA token.
Counterparty Risks; Counterparty risks may arise where the issuer relies on third-party service providers or technology partners.
Reputational Risks; Adverse media and/or damage or loss of key personnel could negatively affect the ecosystem that the GALA token lives on.
Competition Risk; The issuer may face increased competition or changes in market conditions that affect its ability to carry out its objectives.
Regulatory Risks; The issuer may be subject to investigations, enforcement actions, or change in regulation that affect the tokens legal status in certain jurisdictions.
Disclosure Risks; The issuer may not be required to provide financial statements, limiting GALA token holders visibility into the financial health status of the issuer/project.
Key Person Risk; The project and/or token's success may rely on a small number of individuals or core team. If these individuals depart from the project, the direction and continuity of the project may be negatively affected in the future.
Issuer Risks; The information provided is based solely on publicly available sources and does not constitute any form of guarantee or warranty as to its accuracy or completeness.
3. Crypto-Assets-Related Risks
Market Volatility; The GALA token may be subject to significant volatility and could lose value rapidly, either due to market conditions or otherwise (issuer-related/technology/project implementation risks)
Utility Risk; The GALA tokens utility depends on access to certain services, and any modification or discontinuation of those services could reduce the associated utility of the token.
Smart Contract Risk; The GALA token may operate through smart contracts that may contain vulnerabilities, even if audited, and upgrades to the protocol or governance changes may affect functionality.
Liquidity Risk; Periods of low/limited liquidity may occur, particularly if the demand for the token or its use case decreases, which could have adverse effects on the GALA tokens price and future use cases.
4. Project Implementation-Related Risks
Scalability Issues; There is a risk that the project may not be implemented or scaled as intended. Technical limitations or infrastructure bottlenecks could hinder the expected scalability of the project, especially if user demand exceeds network or protocol capacity.
Governance Risk; The project may be subject to governance processes that involve on-chain voting or community proposals. Misaligned incentives, low participation, or malicious actors may affect the outcome of governance decisions and disrupt the project's roadmap.
Centralisation Risk; Similar to governance risks outlined above, centralisation within the governance process, or validator centralisation could lead to a lack of decentralization within the network, which carries future risks in terms of trust within the project, and also in regards to future roadmaps where plans may not reflect the interests of the broader user base.
5. Technology-Related Risks
Blockchain Performance Risk: The underlying blockchains on which the GALA token operates (including the native GalaChain, Ethereum, and Solana) may experience downtime, high network congestion, or increased transaction fees. Such events could delay, make prohibitively expensive, or prevent token transfers and utility usage on the affected network.
Consensus Failure Risk: A failure in the consensus mechanism of any of the blockchains supporting GALA (GalaChain's Proof-of-Authority, Ethereum's Proof-of-Stake, or Solana's Proof-of-History/Proof-of-Stake) could result in halted transactions, unexpected network behavior, or a loss of network integrity for the tokens on that specific chain.
Smart Contract & Protocol Vulnerabilities: Although the token uses standard smart contract makeups on public chains (e.g., ERC-20 on Ethereum, SPL on Solana), undetected bugs, exploits, or implementation errors could compromise functionality or security. Furthermore, the native GalaChain protocol itself, being proprietary software, is subject to internal code vulnerabilities that could have similar adverse effects.
Upgradeability Risk: If the token smart contracts (ERC-20, SPL) are upgradeable and have designated "owner" addresses, this introduces a central point of failure. This risk is also inherent in the native GalaChain, which is a permissioned network operated by the issuer. Misuse of these administrative privileges, whether by malicious actors or through internal error, could lead to modifications that compromise token functionality or security.
Third-party Infrastructure Dependency: Interaction with the GALA token across all its host networks may rely on external infrastructure (e.g., public RPC nodes, APIs, wallet services, off-chain governance voting portals). Outages or attacks on these third-party dependencies may interrupt access to token-related services.
Interoperability Risk: The GALA token's multi-chain functionality relies on cross-chain bridges to move assets between GalaChain, Ethereum, and Solana. These bridges are complex systems that are known high-value targets for exploits. A failure, exploit, or security vulnerability in one of these bridges could result in a significant loss of assets, a de-pegging of the token's value on a specific chain, or a halt in cross-chain functionality.
Protocol-level Risk: Upgrades or hard forks of the underlying protocols (GalaChain, Ethereum, or Solana) may affect the GALA token. Such events could lead to compatibility issues, require token holders to migrate to new contracts, or result in unexpected token behavior if not properly managed by the issuer.
Emerging Technology Risk: Advances in computing (such as quantum computing) or undiscovered vulnerabilities in cryptographic algorithms may pose long-term security risks to the blockchains or associated smart contracts supporting the GALA token.
6. Mitigation Measures
Blockchain Performance Risk: The GALA token operates on networks with different performance architectures. The native GalaChain is a Proof-of-Authority network designed and operated by the issuer for high-throughput, low-latency gaming transactions, with performance managed by a permissioned validator set. Ethereum has adopted a Proof-of-Stake consensus mechanism, and its ongoing upgrades are designed to enhance throughput, while gas fees prioritise transactions under load. Solana utilises a Proof-of-History and Proof-of-Stake hybrid consensus mechanism, which is also designed for high scalability and low transaction costs.
Consensus Failure Risk: Each network's consensus failure risk is mitigated by its distinct security model. As a Proof-of-Authority network, GalaChain's consensus integrity is secured by a limited set of authorised nodes operated by the issuer; this concentrates trust in the issuer but mitigates against 51% attacks from unknown actors. Ethereum's Proof-of-Stake consensus includes validator incentives, slashing penalties, and finality checkpoints, with integrity reinforced by a large, globally distributed validator set. Solana's consensus mechanism similarly includes incentives and slashing, with network integrity secured by its own large, permissionless set of global validators.
Smart Contract & Protocol Vulnerabilities: On Ethereum (ERC-20) and Solana (SPL), smart contracts are immutable by design unless explicitly made upgradeable, and the GALA (v2) ERC-20 contract has been externally audited. These ecosystems use standardised libraries to reduce coding errors. The GalaChain L1, being a proprietary protocol, relies on the issuer's internal development, testing, and quality assurance processes to mitigate protocol-level risks.
Upgradeability Risk: On Ethereum and Solana, risks related to upgradeable contracts can be mitigated through standard practices like time-delay triggers or multi-signature wallet controls. The native GalaChain protocol, however, is directly upgradeable by its operator, Blockchain Game Partners, Inc. This centralisation allows for rapid patching but relies on the issuer's internal security and governance procedures.
Third-party Infrastructure Dependency: On Ethereum and Solana, this risk is mitigated by the availability of decentralised indexing protocols and a competitive market of RPC providers, reducing reliance on single data services. For GalaChain, the infrastructure is supported by a large, distributed network of Founder's Nodes running issuer-provided software, creating resilience through distribution, though the software itself remains a central dependency.
Interoperability Risk: This risk, which arises from connecting the networks, is primarily mitigated through the use of purpose-built, audited cross-chain bridges that employ token lock-and-mint or lock-and-burn mechanisms. The security of the token's cross-chain functionality relies heavily on the design and operational security of these specific bridges.
Protocol-level Risk: On Ethereum and Solana, this risk is managed through public roadmaps and structured governance processes with extensive public testing. In contrast, GalaChain's protocol roadmap and updates are managed directly by the issuer, with governance centralised, although some proposals may be voted on by Founder's Node operators.
Emerging Technology Risk: This risk is monitored by the respective core development teams for all three networks. The issuer, the Ethereum Foundation, and the Solana Foundation are responsible for researching and developing future-proof solutions, such as quantum-resistant cryptography, and each network's design may allow for cryptographic upgrades if required.
V. GENERAL INFORMATION
A. Information of the Offeror or the Person Seeking Admission to Trading
A.1 Name: N/A A.2 Legal Entity Identifier (LEI): N/A A.3 Legal Form, if applicable: N/A A.4 Registered Office, if applicable: N/A A.5 Head Office, if applicable: N/A A.6 Date of Registration [YYYY-MM-DD]: N/A A.7 Legal Entity Number: N/A A.8 Contact Telephone Number: N/A A.9 E-Mail Address: N/A A.10 Response Time (days): N/A A.11 Members of Management Body: N/A A.12 Business Activity: N/A A.13 Newly Established: N/A A.14 Financial Condition for the past Three Years: N/A A.15 Financial Condition since Registration: N/A A.16 Parent Company, if applicable: N/A A.17 Parent Company Business Activity, if applicable: N/A
B. Information of the Issuer
This section shall ONLY be completed if the information is different to that listed in section 1, above.
B.1 Is the Issuer different from an offeror or person seeking admission to trading?: TRUE B.2 Name: Blockchain Game Partners, Inc B.3 Legal Entity Identifier (LEI): No information could be identified in regards to this field at the time of drafting this whitepaper. B.4 Legal Form, if applicable: Corporation B.5 Registered Office, if applicable: 1309 Coffeen Avenue STE 11110 Sheridan, WY 82801 USA B.5 Head Office, if applicable: 1309 Coffeen Avenue STE 11110 Sheridan, WY 82801 USA B.6 Date of Registration [YYYY-MM-DD]: 2019-01-19 B.7 Legal Entity Number: 2019-000837135 B.8 Members of the Management Body:
Line ID | Identity | Business Address | Function |
1 | Carl Eric Schiermeyer | 1309 Coffeen Ave STE 11110, Sheridan, WY 82801 | President & Director |
B.9 Business Activity: Blockchain Game Partners, Inc. provides curatorial and maintenance services to the Gala Games ecosystem. Its business activities include the development, operation, and maintenance of the proprietary GalaChain Layer 1 blockchain. B.10 Parent Company: No information could be identified in regards to this field at the time of drafting this whitepaper. B.11 Parent Company Business Activity: No information could be identified in regards to this field at the time of drafting this whitepaper.
C. Information about OKX Europe Limited ("OKX")
This section shall ONLY be completed if OKX draws up the Crypto-Asset White Paper.
C.1 Name: OKX Europe Limited C.2 Legal Entity Identifier: 54930069NLWEIGLHXU42 C.3 Legal Form, if applicable: Private Limited Company C.4 Registered Office, if applicable: Piazzetta Business Plaza, Office Number 4, Floor 2, Triq Ghar il-Lembi, Sliema SLM1562, Malta C.5 Head Office, if applicable: See C.4 C.6 Date of Registration: 2018-09-07 C.7 Legal Entity Registration Number: C 88193 C.8 Members of Management Body:
Line ID | Identity | Business Address | Function |
1 | Erald Henri J. Ghoos | See C.4 | Director |
2 | Fang Hong | See C.4 | Director |
3 | Joseph Portelli | See C.4 | Director |
4 | Wei Man Cheung | See C.4 | Director |
C.9 Business Activity: OKX Europe Limited is licensed as a Crypto-Asset Service Provider by the Malta Financial Services Authority, bearing licence number OEUR-24352, to provide crypto services under the Markets in Crypto-Assets Act, Chapter 647, Laws of Malta and is the operator of a Trading Platform for Crypto Assets, in accordance with Article 3(1)(18) of Regulation (EU) 2023/1114 (MiCA). C.10 Reason for Crypto-Asset White Paper Preparation: This crypto-asset whitepaper has been prepared in accordance with Regulation (EU) 2023/1114 (MiCA) for the purpose of: - The admission to trading of GALA on regulated platforms, starting with the OKX Exchange. OKX Europe Limited as a result of being a licenced CASP endeavours to fulfill the obligations established under MiCA and the respective MFSA guidelines to: - Notify this whitepaper to the MFSA; - Publish the whitepaper publicly; - And ensure its registration in the MiCA register maintained by the European Securities and Markets Authority (ESMA). This whitepaper has been prepared to provide transparent, accurate, and fair information to prospective token holders and regulatory authorities in line with the principles of MiCA. C.11 Parent Company: OKC International Holding Company Limited C.12 Parent Company Business Activity: The primary business activity of the parent company is holding of investments.
Other Information
This section shall ONLY be completed if someone, other those referenced in Section 1 to 3, compile and complete the Crypto-Asset White Paper.
C.13 Other Persons drawing up the Crypto-Asset White Paper: N/A C.14 Reason for Crypto-Asset White Paper Preparation: N/A
VI. INFORMATION ABOUT THE CRYPTO-ASSET
D. Information about the Crypto-Asset Project
D.1 Project Name: Gala Games D.2 Crypto-Assets Name: See F.14 D.3 Abbreviation: See F.14 D.4 Crypto-Asset Project Description: Gala Games is a blockchain-based gaming platform that utilises distributed ledger technology for game development and publishing. The project initially launched on the Ethereum blockchain, using ERC-20 and ERC-721 standards for its token and in-game assets. It has since developed its own Layer 1 blockchain, GalaChain, which is built on Hyperledger Fabric and operates using a Proof-of-Authority (PoA) consensus mechanism, as well as being recently deployed on the solana blockchain. The proprietary chain is designed to offer higher transaction throughput and lower costs for gaming applications. The ecosystem supports games, music, and film, with the GALA token serving as the central utility asset across both GalaChain and Ethereum. D.5 Details of all natural or legal persons involved in the implementation of the Crypto-Asset Project:
Name | Role | Business Address |
Eric Schiermeyer | CEO of Gala Games | San Francisco, California, United States |
Michael McCarthy | President of Gala Games | Salem, Oregon, United States |
Adam Price | CTO of Gala Games | Portland, Oregon, United States |
Mark Skaggs | COO of Gala Games | Allen, Texas, United States |
Wright W. Thurston | Co-Founder of Gala Games | Park City, Utah, United States |
D.6 Utility Token Classification: TRUE D.7 Key Features of Goods/Services for Utility Token Projects, if applicable: The Gala Games ecosystem provides a platform for the development and operation of blockchain-integrated games and entertainment applications. It enables users to own, manage, and trade in-game assets as non-fungible tokens (NFTs) and provides the underlying distributed ledger infrastructure (GalaChain) for these interactions. D.8 Plans for the Token: As of the date of this whitepaper, the project has not published a formal, forward-looking public roadmap detailing future milestones. Development and ecosystem updates are communicated through official project channels. D.9 Resource Allocation, if applicable: The GALA token was introduced via a "fair launch" model, meaning there was no initial coin offering (ICO), pre-sale, or pre-mined allocation of tokens to founders, advisors, or private investors. Tokens were initially generated and distributed as rewards to operators of Founder's Nodes who support the network's infrastructure. A portion of the GALA supply is held in a reserve address managed by the project team for ecosystem development purposes. D.10 Planned Use of Collected Funds or Crypto-Assets, if applicable: The project maintains a reserve of GALA tokens, which is managed by the project team. These assets are intended to support the ongoing development, maintenance, and growth of the Gala Games ecosystem. Decisions regarding the use of these reserve assets are executed by the team.
E. Information about the Offer to the Public of the Crypto-Asset or Its Admission to Trading
E.1 Public Offering or Admission to Trading: ATTR E.2 Reasons for Public Offer or Admission to Trade: Facilitating secondary trading for users on the OKX Trading platform in compliance with the MiCA regulatory framework. E.3 Fundraising Target, if applicable: N/A E.4 Minimum Subscription Goals, if applicable: N/A E.5 Maximum Subscription Goals, if applicable: N/A E.6 Oversubscription Acceptance: N/A E.7 Oversubscription Allocation, if applicable: N/A E.8 Issue Price: N/A E.9 Official Currency or Any Other Crypto-Assets determining the Issue Price: N/A E.10 Subscription Fee: N/A E.11 Offer Price Determination Method: N/A E.12 Total Number of Offered/Traded Crypto-Assets, if applicable: The maximum total supply of the GALA token is fixed at 50,000,000,000. E.13 Targeted Holders: N/A E.14 Holder Restrictions: N/A E.15 Reimbursement Notice: N/A E.16 Refund Mechanism: N/A E.17 Refund Timeline: N/A E.18 Offer Phases: N/A E.19 Early Purchase Discount: N/A E.20 Time-Limited Offer: N/A E.21 Subscription Period, beginning [YYYY-MM-DD]: N/A E.22 Subscription Period, end [YYYY-MM-DD]: N/A E.23 Safeguarding Arrangement for Offered Funds/Crypto-Assets: N/A E.24 Payment Methods for Crypto-Asset Purchase: In line with OKX current payment method offering. E.25 Value Transfer Methods for Reimbursement: N/A E.26 Right of Withdrawal, if applicable: N/A E.27 Transfer of Purchased Crypto-Assets: In line with OKX current Terms of Service. E.28 Transfer Time Schedule [YYYY-MM-DD]: N/A E.29 Purchaser's Technical Requirements: In line with OKX current Terms of Service. E.30 Crypto-Asset Service Provider (CASP) name, if applicable: OKX Europe Limited E.31 CASP identifier, if applicable: 54930069NLWEIGLHXU42 E.32 Placement Form: NTAV E.33 Trading Platforms Name, if applicable: OKX E.34 Trading Platforms Market Identifier Code (MIC): N/A E.35 Trading Platforms Access, if applicable: Users may access GALA through the OKX Trading Platform via the Application Program Interface ("API"), the Application Software ("OKX App"), as well as the official OKX website as follows; www.okx.com. E.36 Involved Costs, if applicable: In line with the OKX current Terms of Service. E.37 Offer Expenses: N/A E.38 Conflicts of Interest: A crypto-asset is listed following a decision rendered independently by the Listing Committee in line with the internal policies of OKX Europe Limited. Any potential disclosures that may arise of conflicts of interest are published on the OKX website. E.39 Applicable Law: Malta E.40 Competent Court: Malta
F. Information about the Crypto-Assets
F.1 Crypto-Asset Type: Other Crypto-Asset F.2 Crypto-Asset Functionality: The GALA token is the primary utility crypto-asset within the Gala ecosystem. Its core functionalities include: serving as the medium of exchange for purchasing digital assets (NFTs) across Gala's gaming, music, and film platforms; payment for transaction fees (gas) on the GalaChain blockchain; acting as a reward mechanism for Founder's Node operators who contribute computational resources to the network; and enabling governance participation for Founder's Node operators, allowing them to vote on ecosystem development proposals. F.3 Planned Application of Functionalities: All contemplated functionalities of the GALA token are fully available and operational at the time of this whitepaper's publication. F.4 Type of White Paper: OTHR F.5 Type of Submission: NEWT F.6 Crypto-Asset Characteristics: GALA is a fungible crypto-asset that exists as a native token on the GalaChain L1 blockchain, as an ERC-20 token on Ethereum, and as an SPL token on the Solana blockchain. It has a fixed maximum supply of 50,000,000,000 tokens. The tokenomics include a burn mechanism whereby GALA used for transaction fees on GalaChain is permanently removed from the circulating supply. F.7 Commercial Name or Trading Name, if applicable: See F.14 F.8 Website of the Issuer: https://gala.com/ F.9 Starting Date of Offer to the Public or Admission to Trading [YYYY-MM-DD]: 2025-03-05 F.10 Publication Date [YYYY-MM-DD]: 2025-12-18 F.11 Any Other Services Provided by the Issuer: N/A F.12 Identifier of Operator of the Trading Platform: N/A F.13 Language/s of the White Paper: English F.14 Digital Token Identifier Code used to uniquely identify the Crypto-Asset or each of the several Crypto-Assets to which the White Paper relates, where available: M7C8L07RX, J64P5J1LV F.15 Functionally Fungible Group Digital Token Identifier, where available: XS363HTZB F.16 Voluntary Data Flag: FALSE F.17 Personal Data Flag: TRUE F.18 LEI Eligibility: N/A F.19 Home Member State: Malta F.20 Host Member States: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Ireland, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden
G. Information about the Rights and Obligations Attached to the Crypto-Asset
G.1 Purchaser Rights and Obligations: There are no obligations attached for the purchaser. Purchasers of the GALA token acquire the right to use it within the Gala ecosystem. These rights include: (a) the ability to use GALA as a payment method for digital assets and services on the platform; (b) the ability to use GALA to pay for transaction fees on the GalaChain network; and (c) for operators of Founder's Nodes, the right to participate in governance votes concerning the ecosystem. G.2 Exercise of Rights and Obligations: As the token does not grant obligations, there is no conceivable way to exercise such obligations. Purchasers exercise their rights by interacting with smart contracts and applications within the Gala ecosystem via a compatible crypto-asset wallet. Payment and transaction fee rights are exercised through standard blockchain transactions. Governance rights are exclusive to Founder's Node operators and are exercised through a specific voting interface provided by the project. These rights do not confer any legal ownership, claim to treasury assets, or enforceable contractual rights against the issuer. G.3 Conditions for Modifications of Rights and Obligations: As the token does not grant obligations, there are no conditions under which obligations may be modified. The rights associated with the GALA token may be subject to modification through governance proposals submitted to and approved by Founder's Node operators. The ability to exercise governance rights is conditional upon the ownership and active operation of a Founder's Node license. G.4 Future Public Offers, if applicable: N/A G.5 Issuer Retained Crypto-Assets, if applicable: The GALA token was distributed via a 'fair launch' model, with no initial token allocation retained by the issuer at the time of the token generation event. However, the issuer, Blockchain Game Partners, Inc., manages a reserve of GALA tokens designated for ecosystem development, partnerships, and network growth. These assets are held in a publicly identifiable wallet, and their allocation is at the discretion of the project team. G.6 Utility Token Classification: TRUE G.7 Key Features of Goods/Services of Utility Tokens: The GALA token provides access to the Gala digital ecosystem. It functions as the primary medium of exchange for purchasing digital assets, such as non-fungible tokens (NFTs), within games and other applications on the platform. It is also used to pay for transaction fees (gas) required to interact with the GalaChain network. For participants who operate a Founder's Node, the GALA token serves as a reward mechanism for providing computational resources that support the network's infrastructure. There is no fixed quantity of goods or services per token; the cost of assets and transaction fees is dynamic. The GALA token is freely and instantly transferable, utilising the underlying blockchain network's standard processes. G.8 Utility Tokens Redemption, if applicable: The GALA token does not grant redemption rights for off-chain goods, services, or fiat currency from the issuer. Its utility is realised exclusively through its use within the Gala digital ecosystem for payments, transaction fees, and participation in the node network. G.9 Non-Trading Request: TRUE G.10 Crypto-Assets Purchase or Sale Modalities: N/A G.11 Crypto-Assets Transfer Restrictions: In line with OKX current Terms of Service. G.12 Supply Adjustment Protocols: N/A G.13 Supply Adjustments Mechanisms: N/A G.14 Token Value Protection Schemes: FALSE G.15 Token Value Protection Schemes Description: N/A G.16 Compensation Schemes: FALSE G.17 Compensation Schemes Description, if applicable: N/A G.18 Applicable Law: Malta G.19 Competent Court: Malta
H. Information about the Underlying Technology
H.1 Distributed Ledger Technology, if applicable: See F.14 H.2 Protocols and Technical Standards: The GALA token is implemented using the ERC‑20 token standard on the Ethereum blockchain. ERC‑20 is the widely adopted standard for fungible tokens on Ethereum, defining a common interface for token issuance, transfers, and third-party integrations. ERC‑20 tokens are deployed via smart contracts that control total supply, balances, and permissions, and are compatible with Ethereum wallets, DeFi applications, and decentralized exchanges. The standard supports functions such as transfer, approve, mint, and burn, enabling programmable token logic through Ethereum's account-based architecture. The GALA crypto-asset also exists as a native token on the proprietary GalaChain blockchain. GalaChain is a Layer 1 network built using Hyperledger Fabric. As a native asset, it operates according to the specific protocols and standards defined by this custom distributed ledger. The GALA token also exists as an SPL token on the Solana blockchain. The Solana Program Library (SPL) is the standard for creating and managing tokens on Solana, similar in function to Ethereum's ERC-20 standard. H.3 Technology Used, if relevant: The GALA token is deployed on the Ethereum blockchain using the ERC‑20 token standard. Ethereum is a general-purpose Layer 1 blockchain that supports smart contract execution via the Ethereum Virtual Machine (EVM). The token contract is written in Solidity and interacts with the Ethereum network using RPC-compatible clients. The Ethereum ecosystem enables composability with DeFi, NFT, and DAO infrastructure, and supports programmable token functionality within a Turing-complete environment. The Gala Games project employs a dual-chain architecture. GalaChain is a permissioned Layer 1 blockchain designed for high-performance gaming applications. This allows for fast and low-cost transactions controlled by a set of authorised validator nodes. A bridging mechanism exists to facilitate transfers of the GALA token between GalaChain and Ethereum. The token's presence on the Solana blockchain provides access to its high-throughput, low-cost ecosystem. A cross-chain bridge facilitates the transfer of the GALA token between GalaChain and Solana, expanding its utility. H.4 Consensus Mechanism, if applicable: Ethereum uses a Proof-of-Stake (PoS) consensus mechanism. Validators are selected to propose and attest to new blocks based on the amount of ETH they have staked. Blocks are finalized through a checkpoint-based finality system, with strong economic incentives to penalize dishonest behavior. This mechanism supports decentralization, finality, and high security. This consensus model ensures the integrity of the blockchain, including the execution and recording of all associated transactions for the GALA token. In regards to GALA tokens deployed on the GalaChain, this blockchain operates on a Proof-of-Authority (PoA) consensus mechanism. In this model, a limited number of pre-authorised nodes are responsible for validating transactions and creating new blocks. This mechanism prioritises transaction speed and scalability over decentralisation. The SPL version of the GALA token relies on the security and consensus of the Solana network, which uses a hybrid mechanism combining Proof-of-History (PoH) with Proof-of-Stake (PoS). H.5 Incentive Mechanisms and Applicable Fees: Ethereum validators earn rewards in the native token (ETH) for producing and attesting to blocks. Gas fees are paid in ETH and are required to execute transactions or smart contract calls, including GALA token transfers. Under EIP-1559, a portion of the base fee is burned while the remainder is distributed to validators. Fees vary depending on network congestion and computational complexity of the transaction. On GalaChain, network operations are secured by the authorised PoA nodes. Users are required to pay transaction fees in GALA, and a portion of these fees is burned. The primary incentive mechanism is the distribution of GALA rewards to Founder's Node operators, who contribute decentralised computing power and storage to the network. On the Solana network, transaction fees for GALA transfers are paid in its native token, SOL. These fees are paid to Solana validators who secure the network through staking. H.6 Use of Distributed Ledger Technology: TRUE H.7 DLT Functionality Description: GalaChain is a custom-built Layer 1 blockchain developed by the issuer using Hyperledger Fabric. It is structured as a permissioned network with a Proof-of-Authority consensus model, operated by a limited set of authorised validator nodes. This design is intended to provide a scalable, low-cost, and high-performance environment specifically tailored for the high transaction volumes characteristic of gaming and entertainment applications. H.8 Audit of the Technology Used: TRUE H.9 Audit Outcome, if applicable: The ERC-20 smart contract for the GALA (v2) token was audited by CertiK. The final report, updated on May 15, 2023, identified 1 critical, 1 major, 4 medium, and 2 minor findings. According to the audit report, all identified issues have been resolved or acknowledged by the project team. No public audit of the underlying GalaChain Layer 1 technology has been disclosed. Further details can be found at: https://skynet.certik.com/projects/gala-games
I. Information on the Principal Adverse Impacts on the Climate and Other Environmental-Related Adverse Impacts of the Consensus Mechanism Used to Issue the Crypto-Asset.
I.1 Name: OKX Europe Limited I.2 Relevant legal entity identifier: 54930069NLWEIGLHXU42 I.3 Name of the crypto-asset: Gala I.4 Consensus Mechanism: The crypto-asset's Proof-of-Stake (PoS) consensus mechanism, introduced with The Merge in 2022, replaces mining with validator staking. Validators must stake at least 32 ETH every block a validator is randomly chosen to propose the next block. Once proposed the other validators verify the blocks integrity. The network operates on a slot and epoch system, where a new block is proposed every 12 seconds, and finalization occurs after two epochs (~12.8 minutes) using Casper-FFG. The Beacon Chain coordinates validators, while the fork-choice rule (LMD-GHOST) ensures the chain follows the heaviest accumulated validator votes. Validators earn rewards for proposing and verifying blocks, but face slashing for malicious behavior or inactivity. PoS aims to improve energy efficiency, security, and scalability, with future upgrades like Proto-Danksharding enhancing transaction efficiency. I.5 Incentive Mechanisms and Applicable Fees: The crypto-asset's PoS system secures transactions through validator incentives and economic penalties. Validators stake at least 32 ETH and earn rewards for proposing blocks, attesting to valid ones, and participating in sync committees. Rewards are paid in newly issued ETH and transaction fees. Under EIP-1559, transaction fees consist of a base fee, which is burned to reduce supply, and an optional priority fee (tip) paid to validators. Validators face slashing if they act maliciously and incur penalties for inactivity. This system aims to increase security by aligning incentives while making the crypto-asset's fee structure more predictable and deflationary during high network activity. I.6 Beginning of the period to which the disclosure relates: 2024-10-06 I.7 End of the period to which the disclosure relates: 2025-10-06 I.8 Energy consumption: 737.30878 (kWh/a) I.9 Energy consumption sources and methodologies: The energy consumption of this asset is aggregated across multiple components: To determine the energy consumption of a token, the energy consumption of the network(s) ethereum is calculated first. For the energy consumption of the token, a fraction of the energy consumption of the network is attributed to the token, which is determined based on the activity of the crypto-asset within the network. When calculating the energy consumption, the Functionally Fungible Group Digital Token Identifier (FFG DTI) is used - if available - to determine all implementations of the asset in scope. The mappings are updated regularly, based on data of the Digital Token Identifier Foundation. The information regarding the hardware used and the number of participants in the network is based on assumptions that are verified with best effort using empirical data. In general, participants are assumed to be largely economically rational. As a precautionary principle, we make assumptions on the conservative side when in doubt, i.e. making higher estimates for the adverse impacts.
VII. GLOSSARY
Consensus Mechanism: Shall mean the rules and procedures by which an agreement is reached, among the DLT network nodes, that a transaction is validated.
Crypto-Asset: Shall mean a digital representation of a value or of a right that is able to be transferred and stored electronically using distributed ledger technology or similar technology.
Distributed Ledger Technology or DLT: shall mean the technology that enables the operation and use of distributed ledgers.
Home Member State: Shall mean either (a) where the offeror or person seeking admission to trading of crypto-assets other than asset-referenced tokens or e-money tokens has its registered office in the Union, the Member State where that offeror or person has its registered office; or (b) where the offeror or person seeking admission to trading of crypto-assets other than asset-referenced tokens or e-money tokens has no registered office in the Union but does have one or more branches in the Union, the Member State chosen by that offeror or person from among the Member States where it has branches; or (c) where the offeror or person seeking admission to trading of crypto-assets other than asset-referenced tokens or e-money tokens is established in a third country and has no branch in the Union, either the Member State where the crypto-assets are intended to be offered to the public for the first time or, at the choice of the offeror or person seeking admission to trading, the Member State where the first application for admission to trading of those crypto-assets is made; or (d) in the case of an Issuer of asset-referenced tokens, the Member State where the Issuer of asset-referenced tokens has its registered office; or (e) in the case of an Issuer of e-money tokens, the Member State where the Issuer of e-money tokens is authorised as a credit institution under Directive 2013/36/EU or as an electronic money institution under Directive 2009/110/EC; or (f) in the case of crypto-asset service providers, the Member State where the crypto-asset service provider has its registered office.
Host Member State: Shall mean the Member State where an Offeror or Person Seeking Admission to Trading has made an offer to the Public of Crypto-Assets or is seeking admission to trading, or where a Crypto-Asset Service Provider provides crypto-asset services, where different from the Home Member State.
Issuer: Shall mean a natural or legal person, or other undertaking, who issues crypto-assets.
Management Body: Shall mean the body or bodies of an Issuer, Offeror, Person Seeking Admission to Trading, or of a Crypto-Asset Service Provider, which are appointed in accordance with National Law, which are empowered to set the entity's strategy, objectives and overall direction, and which oversee and monitor management decision-making in the entity and include the persons who effectively direct the business of the entity.
Offer to the Public: Shall mean a communication to persons in any form, and by any means, presenting sufficient information on the terms of the offer and the crypto-assets to be offered so as to enable prospective holders to decide whether to purchase those crypto-assets.
Offeror: Shall mean a natural or legal person, or other undertaking, or the Issuer, who offers crypto-assets to the public.
Operator: Shall mean the entity that runs a trading platform for crypto-assets.
Qualified Investors: Shall mean persons or entities that are listed in Section I, points (1) to (4), of Annex II to Directive 2014/65/EU.
Retail Investor/Holder: Shall means any natural person who is acting for purposes which are outside that person's trade, business, craft or profession.
Utility Token: Shall mean a type of crypto-asset that is only intended to provide access to a good or a service supplied by its Issuer.
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