Question
Provide a concise narrative that clearly states each of (a)–(e) below.
Response
Gala Games and Entertainment builds games, music, and film products in which players and audiences hold verifiable ownership of the items they earn and buy. General-purpose public chains impose transaction cost and latency that make high-frequency in-game item transfers impractical at consumer scale. Gala built GalaChain as a purpose-built layer one that settles ecosystem transactions and records item ownership for those three businesses without routing every action through a third-party network.
(Source: What is the Gala Games and Entertainment Ecosystem, GalaChain, GalaChain Decentralization White Paper)
Gala operates four priorities. It expands the Gala Games, Gala Film, and Gala Music businesses. It runs GalaChain as the settlement layer for those businesses. It sustains the Founder's Node network that supports the chain and receives daily GALA distribution. It executes the staged decentralization roadmap published in the GalaChain Decentralization White Paper in October 2024, which sets out four phases covering replacement of the Raft ordering service with a Byzantine fault tolerant consensus, global distribution of peers and orderers, integration of Founder's Nodes as validators with a collateral mechanism, and introduction of GalaChain Improvement Proposals with onchain voting.
(Source: GalaChain Decentralization White Paper, What is the Gala Games and Entertainment Ecosystem, Founder's Node)
Eric Schiermeyer founded Gala Games and Entertainment in 2019, and the business operates through Blockchain Game Partners, Inc., a Wyoming profit corporation. The ecosystem spans three entertainment businesses, Gala Games, Gala Film, and Gala Music, each of which issues in-game or in-app items as NFTs and pays users through Play-and-Earn, Listen-and-Earn, and Watch-and-Earn programs. GalaChain is a layer one built on Hyperledger Fabric with a Raft-based ordering service, a star topology with centralized orderers, and TypeScript chaincode. The GalaChain Decentralization White Paper records more than 40,000 nodes in the Founder's Node network, and Gala support material describes 50,000 Founder's Nodes powering the core of the ecosystem. Users reach GalaChain through a Gala account on ecosystem websites and bridge GALA to and from Ethereum through GalaConnect.
(Source: What is the Gala Games and Entertainment Ecosystem, GalaChain, GalaChain Decentralization White Paper, Founder's Node, GalaConnect is Here)
GALA is the utility token of the Gala ecosystem. Holders spend it on NFTs, node licenses, and in-ecosystem purchases. Gala pays it to qualifying Founder's Node operators as the daily distribution reward. GALA is the gas token on GalaChain, and gas paid in GALA is burned, which reduces total supply. GALA conveys no shareholding, participation, right, title, or interest in Gala Games or its affiliates and entitles holders to no fees, dividends, revenue, profits, or investment returns.
(Source: What is GALA, GALA Tokenomics, GalaChain, What is a Distribution)
The Ethereum GALA token at 0xd1d2Eb1B1e90B638588728b4130137D262C87cae is a UUPS proxy. DEFAULT_ADMIN_ROLE and UPGRADER_ROLE both sit with a Gnosis Safe v1.3.0 at 0x41285b414432a0Ba802a5dd09E872d3ec3C3571E that requires 4 signatures from 8 owners. MINTER_ROLE sits solely with the GalaBridge contract at 0x9F452B7cc24E6E6FA690fE77CF5DD2Ba3dbf1eD9. BLOCKLISTER_ROLE sits with a Safe v1.4.1 at 0x233Fc44C58712A2727410225E88d0C4AFDF482e9 that requires 3 signatures from 5 owners. No timelock governs any of these roles. GalaChain is a permissioned network, and authorization runs through Hyperledger Fabric certificate authorities and organization membership service providers that Gala operates, combined with secp256k1 signatures from registered end users. Founder's Node operators vote on ecosystem decisions through the Gala Node Dashboard, a Gala-operated web interface. Onchain proposal voting sits in Phase 4 of the decentralization roadmap and is not live.
(Source: GALA token contract, Admin and upgrader Safe, Blocklister Safe, GalaBridge minter, GalaChain authorization docs, Voting in the Gala Node Dashboard, GalaChain Decentralization White Paper)
Question
For each existing entity: Labs/DevCo (e.g., Founder, CEO, CTO, COO), Foundation (e.g., President, Executive Director, CFO, COO), and DAO / onchain governance leadership (if applicable) list the: (a) full names, (b) official titles, (c) and prior experience of key team members. For any non-existent entity, explicitly mention it does not exist. External links may be included but they will not factor into the score.
Response
Full Name | Entity | Official Title | Prior Experience |
|---|---|---|---|
Eric Schiermeyer | Labs / DevCo | President, Chief Executive Officer, and one of two directors of Blockchain Game Partners, Inc. | Co-founder of Zynga, where the company launched Poker, Mafia Wars, and FarmVille. Founded Gala Games and Entertainment in 2019. |
Mark Skaggs | Labs / DevCo | Senior Vice President of Games, appointed September 6, 2022 | Created FarmVille and CityVille at Zynga and launched Empires & Allies on mobile. Developed Command & Conquer Generals, Command & Conquer Red Alert 2, and Lord of the Rings Battle for Middle-Earth at Electronic Arts. Created Baahubali The Game and Alia Bhatt Star Life at Moonfrog Labs. 29 years in game development and three awards from the Academy of Interactive Arts & Sciences. |
Wright Thurston | Labs / DevCo | One of two directors of Blockchain Game Partners, Inc. | Controls True North United Investments, LLC, which holds roughly 45 percent of Blockchain Game Partners, Inc. and which counterclaimed against Eric Schiermeyer in the United States District Court for the District of Utah. |
Blockchain Game Partners, Inc., doing business as Gala Games, a Wyoming profit corporation incorporated on January 16, 2019 under filing number 2019-000837135, principal office at 680 S Cache Street, Suite 100, Jackson, Wyoming 83001. The corporation is also registered in Oregon as a foreign business corporation under registry number 195603593, and that filing lists Carl E Schiermeyer as President and Pia Brink as Secretary. | Labs / DevCo | ||
No foundation entity exists in the Gala structure. Gala Games and Entertainment operates entirely through Blockchain Game Partners, Inc., a Wyoming corporation whose board consists of two directors, Eric Schiermeyer and Wright Thurston. The GalaChain Decentralization White Paper, the Gala support corpus, and the pleadings and order in Schiermeyer v. Thurston describe the corporation and its Founder's Node network and identify no foundation. No foundation officers are listed because no foundation exists. | Foundation | ||
No DAO exists and no governance contract is deployed on Ethereum or on GalaChain. Governance decisions run as consensus votes that Gala presents to Founder's Node operators in the Gala Node Dashboard, and Gala posts the results on its blog. GalaChain Improvement Proposals with onchain voting sit in Phase 4 of the decentralization roadmap in the October 2024 white paper and are not live. No DAO officers or delegates are listed because no DAO exists. | DAO / Onchain Governance |
Question
Provide a structured description of the DAO's governance, powers, and economic rights. If a DAO does not exist, state so. Address the lettered items below. Even if there is no DAO, there must be an answer to (d).
Response
No DAO owns or controls intellectual property. Blockchain Game Partners, Inc. develops GalaChain and the Gala Games, Gala Film, and Gala Music products, and operates the certificate authorities, peers, and orderers that run the chain. The GalaChain Decentralization White Paper describes the network as a permissioned network with centralized orderers and places distribution of peer and orderer operation to third parties in Phase 2 of a four-phase roadmap and community proposal rights in Phase 4. Section 5 of that white paper, covering the economic model and incentives, states that the section is still being worked on.
(Source: GalaChain Decentralization White Paper, GalaChain, GalaChain authorization docs)
Administrative power over the Ethereum GALA token sits in three roles on the proxy at 0xd1d2Eb1B1e90B638588728b4130137D262C87cae. A Gnosis Safe v1.3.0 at 0x41285b414432a0Ba802a5dd09E872d3ec3C3571E, requiring 4 signatures from 8 owners, holds DEFAULT_ADMIN_ROLE and UPGRADER_ROLE. DEFAULT_ADMIN_ROLE pauses and unpauses all transfers, grants and revokes every role, and transfers itself to a new holder. UPGRADER_ROLE authorizes replacement of the implementation contract. A Safe v1.4.1 at 0x233Fc44C58712A2727410225E88d0C4AFDF482e9, requiring 3 signatures from 5 owners, holds BLOCKLISTER_ROLE and freezes or unfreezes any address that does not itself hold a role. The GalaBridge contract at 0x9F452B7cc24E6E6FA690fE77CF5DD2Ba3dbf1eD9 is the sole holder of MINTER_ROLE and mints up to a hard cap of 50,000,000,000 GALA enforced in the implementation. No timelock applies to any role. On GalaChain, the CURATOR role governs privileged operations, the REGISTRAR role governs user registration under role-based access control, and organization membership service providers issued by Gala-operated certificate authorities gate all access. Founder's Node operators vote on ecosystem questions through the Gala Node Dashboard, and the May 2024 contract vote used a 24-hour window and a simple majority of 51 percent.
(Source: GALA token contract, GALA implementation contract, Admin and upgrader Safe, Blocklister Safe, GalaBridge minter, GalaChain authorization docs, Governance Proposal, Temporary GALA Token Contract Upgrade and Token Burn, Voting in the Gala Node Dashboard)
Holding and locking GALA confers reward qualification rather than governance rights. Gala stated on June 6, 2025 that from June 16, 2025 daily Founder Node rewards scale with GALA held against the node, with 1,000,000 GALA per node required for 100 percent of the reward and smaller balances earning a proportionally reduced reward, and that a GalaChain-native token called GSTAKE substitutes for GALA in that calculation and trades on Gala Connect, GalaSwap, and third-party venues. Gala stated on December 22, 2025 that GALA held in eligible GalaSwap liquidity pools also counts toward the daily node staking snapshot, that only the GALA side of the position counts, and that the 1,000,000 GALA threshold is unchanged. Founder's Node licenses became tokenizable on GalaChain on October 16, 2024, and moving a license into a transfer-ready state suspends daily distribution eligibility until the operator reactivates it. Voting rights attach to Founder's Node licenses rather than to locked GALA balances.
(Source: Founder Node Staking, What's changing, Node Owners, Keep Earning Node Rewards With Eligible GALA Liquidity Pools, Gala Founder's Nodes can now be Tokenized on GalaChain, Voting in the Gala Node Dashboard)
Gala states that GALA does not represent any shareholding, participation, right, title, or interest in Gala Games, their respective affiliates, or any other company, enterprise or undertaking, that GALA does not entitle holders to any promise of fees, dividends, revenue, profits, or investment returns, and that ownership of GALA carries no rights, express or implied. Gala states separately that a Founder's Node is strictly not an investment in Gala Games and Entertainment. The one mechanical value linkage in the published design is supply reduction, because GALA spent as gas on GalaChain is burned and daily emission is calculated as 0.25 percent of the difference between total supply and the 50,000,000,000 maximum supply, so a lower total supply produces a larger daily emission and a higher total supply produces a smaller one.
(Source: What is GALA, GALA Tokenomics, Founder's Node)
No DAO exists, so no DAO dissolution procedure exists. Authority to wind up the operating entity rests with Blockchain Game Partners, Inc. and its two-director board under Wyoming corporate law. The Ethereum GALA contract contains no dissolution, self-destruct, or shutdown function. The closest equivalent controls are the pause function, which the DEFAULT_ADMIN_ROLE Safe calls to halt every transfer, approval, and role change, and the upgrade path, which the UPGRADER_ROLE Safe uses to replace the implementation with arbitrary code. Both sit with the same 4-of-8 Safe at 0x41285b414432a0Ba802a5dd09E872d3ec3C3571E.
(Source: GALA implementation contract, Admin and upgrader Safe, Wyoming corporation record, Schiermeyer v. Thurston, D. Utah No. 2:23-cv-589-HCN-DAO)
Question
For the Primary Foundation do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist.
Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
No primary foundation exists. Gala Games and Entertainment has never established a foundation, association, or non-profit entity. The operating entity is Blockchain Game Partners, Inc., a Wyoming profit corporation incorporated on January 16, 2019 under filing number 2019-000837135, and the Wyoming and Oregon corporate registrations, the pleadings and order in Schiermeyer v. Thurston in the United States District Court for the District of Utah, the GalaChain Decentralization White Paper, and the Gala support corpus describe that corporation and its Founder's Node network without reference to any foundation.
(Source: Wyoming corporation record, Oregon business registry record, Schiermeyer v. Thurston, D. Utah No. 2:23-cv-589-HCN-DAO, GalaChain Decentralization White Paper)
No foundation holds intellectual property because no foundation exists. Blockchain Game Partners, Inc. develops and owns GalaChain and the Gala Games, Gala Film, and Gala Music products.
(Source: GalaChain Decentralization White Paper, What is the Gala Games and Entertainment Ecosystem)
No foundation holds any power over a DAO, a treasury, protocol-controlled resources, or token administration, because no foundation exists. Those powers sit with Blockchain Game Partners, Inc., which controls the Safes that hold DEFAULT_ADMIN_ROLE, UPGRADER_ROLE, and BLOCKLISTER_ROLE on the Ethereum GALA contract and which operates the GalaChain certificate authorities.
(Source: Admin and upgrader Safe, Blocklister Safe, GalaChain authorization docs)
No foundation holds any power over the development company because no foundation exists. Control of Blockchain Game Partners, Inc. rests with its shareholders and its two-director board.
(Source: Schiermeyer v. Thurston, D. Utah No. 2:23-cv-589-HCN-DAO, Wyoming corporation record)
No foundation holds any contract or administrative role on the GALA token. Every privileged role on the Ethereum contract belongs to a Gala-controlled Safe or to the Gala-deployed GalaBridge contract.
(Source: GALA token contract, Admin and upgrader Safe, GalaBridge minter)
No foundation receives, holds, or distributes GALA because no foundation exists. All emission flows from the GalaBridge minter to qualifying Founder's Node operators under the policy described in Section 6 of this filing.
(Source: GALA Tokenomics, What is a Distribution, GalaBridge minter)
Question
For the Primary DevCo do the following independently. If an entity does not exist, state that explicitly. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist.
Definitions: The primary Foundation and DevCo can be explained as those entities which are directly involved in the issuance of the native token at launch.
Response
Blockchain Game Partners, Inc., doing business as Gala Games, is the sole operating and development company. It is a Wyoming profit corporation incorporated on January 16, 2019 under filing number 2019-000837135, with its principal office at 680 S Cache Street, Suite 100, Jackson, Wyoming 83001 and Mountain Business Center, LLC as its Wyoming registered agent. It registered in Oregon as a foreign business corporation on April 13, 2022 under registry number 195603593, with Michael S Mccartchy at 6027 Sawgrass St SE, Salem, Oregon 97306 as its Oregon registered agent, and that filing lists Carl E Schiermeyer as President and Pia Brink as Secretary. The board consists of two directors, Eric Schiermeyer and Wright Thurston.
(Source: Wyoming corporation record, Oregon business registry record, Schiermeyer v. Thurston, D. Utah No. 2:23-cv-589-HCN-DAO)
Blockchain Game Partners, Inc. develops and owns GalaChain and the Gala Games, Gala Film, and Gala Music products, and it authored the GalaChain Decentralization White Paper. It operates the certificate authorities, peers, and orderers of the permissioned GalaChain network and controls the GalaChain SDK documentation and release process. No other entity holds rights in the protocol or the brand.
(Source: GalaChain Decentralization White Paper, GalaChain, GalaChain authorization docs)
No DAO exists, so the company holds no powers over one. The company controls the treasury directly. Gala reported approximately 2 billion GALA held in reserve by the team and burned approximately 20.9 billion GALA from total supply on May 15, 2023, covering all revenue previously received in GALA and nearly all reserve GALA issued as Founder's Node rewards, at a value of roughly 660 million dollars at the time. The company allocated treasury GALA to Animoca Brands on July 3, 2024 for liquidity provisioning services aimed at orderly trading. On token administration, the company controls the Safe at 0x41285b414432a0Ba802a5dd09E872d3ec3C3571E that holds DEFAULT_ADMIN_ROLE and UPGRADER_ROLE, the Safe at 0x233Fc44C58712A2727410225E88d0C4AFDF482e9 that holds BLOCKLISTER_ROLE, and the GalaBridge contract at 0x9F452B7cc24E6E6FA690fE77CF5DD2Ba3dbf1eD9 that holds MINTER_ROLE. It also sets the daily emission policy and the node reward qualification thresholds, and it decides which questions go to a Founder's Node vote.
(Source: GALA Tokenomics, Burning for Supply, Gala Games and Animoca Brands Announce Collaboration, Admin and upgrader Safe, Blocklister Safe, GalaBridge minter)
No foundation exists, so Blockchain Game Partners, Inc. holds no powers over a foundation and no foundation holds powers over it.
(Source: Wyoming corporation record, GalaChain Decentralization White Paper)
The company holds every privileged role on the Ethereum GALA contract through entities it controls. The 4-of-8 Safe at 0x41285b414432a0Ba802a5dd09E872d3ec3C3571E can pause and unpause all transfers, grant and revoke every role, transfer the admin role, and authorize an implementation upgrade. The 3-of-5 Safe at 0x233Fc44C58712A2727410225E88d0C4AFDF482e9 can freeze and unfreeze any address that holds no role. The GalaBridge contract at 0x9F452B7cc24E6E6FA690fE77CF5DD2Ba3dbf1eD9 is the only address that can mint, subject to the 50,000,000,000 GALA cap enforced in the implementation. No role carries a timelock. The company exercised the upgrade power on May 24, 2024, when the admin Safe upgraded the proxy to a temporary implementation, burned the illegitimately minted supply, and restored the original implementation inside a single transaction.
(Source: GALA token contract, GALA implementation contract, Admin and upgrader Safe, Blocklister Safe, Temporary implementation contract, Upgrade and burn transaction)
The company earns revenue from game, film, and music product sales, NFT sales, and node license sales, and it states that the project was independently funded with no investment rounds of any kind. Emission policy changed in August 2024 from a halving schedule to a dynamic formula under which daily emission equals 0.25 percent of the difference between total supply and the 50,000,000,000 maximum supply, adopted after a Founder's Node vote. The daily distribution goes to Founder's Node operators who ran the node software for the minimum required time in the prior 24 hours, allocated by a points system, and settles around 02:00 Coordinated Universal Time. Rewards accrue as a GalaChain Allowance and reach the chain only when the operator mints them. GALA spent as gas on GalaChain is burned. Approximately 2 billion GALA remain in the team reserve. DWF Labs obtained 60 million GALA under a partnership announced in September 2023 to grow the GalaChain ecosystem and purchased a further 28 million GALA on the open market after the May 2024 incident.
(Source: GALA Tokenomics, What is a Distribution, Did the GALA Token have an ICO, Founder's Node, Burning for Supply)
Question
Disclose launch and initial supply details in a single initial allocation schedule covering the token's launch.
Response
No launch allocation event occurred. Gala states that GALA began emissions to Founder's Nodes on September 11, 2020 with no token sale and no pre-mint phase, so the launch supply was zero and every unit of supply since has entered circulation through the daily node distribution. The one bulk issuance in the record is the version 2 contract migration. On May 15, 2023 Gala dropped GALA v2 at a 1 to 1 ratio to holders of GALA v1 at a snapshot, and the published migration file lists 240,505 addresses receiving a combined 13,916,100,179.00185945 GALA. The Ethereum GALA v2 contract at 0xd1d2Eb1B1e90B638588728b4130137D262C87cae reports a total supply of 42,112,016,470.93 GALA across 220,066 holders, and CoinGecko reports an aggregate total supply of 49,040,605,312.09 GALA across Ethereum, Solana, and GalaChain.
(Source: GALA Tokenomics, Did the GALA Token have an ICO, Upgrading to GALA v2, GALA v2 migration totals, GALA token contract, CoinGecko GALA)
Two recipient categories exist. Founder's Node operators receive the daily distribution, which is the primary path by which new GALA enters circulation, and Gala holds a team reserve reported at approximately 2 billion GALA. No sale proceeds exist to allocate, because Gala states that GALA has never been available for purchase directly from the company, that no initial coin offering was held, and that the project was independently funded with no investment rounds of any kind. Gala burned approximately 20.9 billion GALA on May 15, 2023, comprising all revenue previously received in GALA and nearly all reserve GALA that had been issued as Founder's Node rewards, at a value of roughly 660 million dollars at the time.
(Source: GALA Tokenomics, Did the GALA Token have an ICO, What is a Distribution, Burning for Supply)
No initial price per token exists. Gala conducted no token sale, no initial coin offering, and no fundraising round, and GALA has never been available for purchase directly from Gala Games and Entertainment.
(Source: Did the GALA Token have an ICO, GALA Tokenomics)
The ticker is GALA. The Ethereum contract at 0xd1d2Eb1B1e90B638588728b4130137D262C87cae reports the name GALA, the symbol GALA, and 8 decimals. The token also exists on Solana at eEUiUs4JWYZrp72djAGF1A8PhpR6rHphGeGN7GbVLp6 and natively on GalaChain. The superseded version 1 contract sits at 0x15D4c048F83bd7e37d49eA4C83a07267Ec4203dA and is no longer supported.
(Source: What is GALA, GALA token contract, GALA v1 contract, CoinGecko GALA)
Maximum supply is capped at 50,000,000,000 GALA. The cap is enforced in the implementation contract as a constant of 50,000,000,000 multiplied by 10 to the eighth power, checked on every mint, and it cannot rise without an implementation upgrade. Since August 2024 daily emission has been dynamic and equals 0.25 percent of the difference between total supply and maximum supply, which replaced the earlier halving schedule after a Founder's Node vote. Supply falls when GALA is spent as gas on GalaChain, which burns it, and it fell by approximately 20.9 billion GALA in the May 15, 2023 treasury burn. As of July 27, 2026 CoinGecko reports circulating supply of 49,040,605,423.11 GALA, aggregate total supply of 49,040,605,312.09 GALA, and a maximum supply of 50,000,000,000 GALA.
(Source: GALA Tokenomics, GALA implementation contract, Burning for Supply, CoinGecko GALA)
No vesting or lockup schedule exists for any launch recipient, because no launch allocation, sale, or investor round occurred. The release schedule for GALA is the daily node distribution itself, which has run since September 11, 2020 and which since August 2024 releases 0.25 percent of the gap between total supply and the 50,000,000,000 cap each day to qualifying Founder's Node operators. The team reserve of approximately 2 billion GALA carries no published lock or release schedule and is held at the discretion of Blockchain Game Partners, Inc.
(Source: GALA Tokenomics, Did the GALA Token have an ICO, What is a Distribution)
Question
Address each of the following sub-items based on the project's airdrop status. If a sub-item does not apply to the project's situation, state that explicitly.
Response
Gala Games and Entertainment has never conducted an airdrop. Gala states plainly that there are no GALA airdrops and that no official airdrops have been conducted by the company. The reward path is the daily node distribution rather than an airdrop. Operators who run Gala node software under a valid workload license and meet the workload requirement for the prior 24 hours receive a share of the daily emission allocated by a points system, settled around 02:00 Coordinated Universal Time, and credited as a GalaChain Allowance that reaches the chain only when the operator mints it.
(Source: Are there any GALA airdrops available, What is a Distribution, GALA Tokenomics)
The only bulk distribution in the record is the version 2 contract migration, which was a 1 to 1 replacement for existing holders rather than a new-recipient airdrop. The recipient segment was every holder of GALA v1 at the snapshot Gala took ahead of May 15, 2023, including balances held at supported exchanges that Gala contacted in advance. The method was a direct drop of GALA v2 to each snapshot address at a 1 to 1 ratio, with no claim step. Gala warned holders to withdraw from liquidity pools before the snapshot and stated that recovery of GALA dropped to liquidity pool contracts was not guaranteed. Gala published the complete per-address allocation as a machine-readable file with the columns address, value, and gala, listing 240,505 addresses and a combined 1,391,610,017,900,185,945 base units, equal to 13,916,100,179.00185945 GALA at 8 decimals.
Question
Projects must disclose all material terms of market-making arrangements that affect token liquidity. If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. For each market maker, include in a table:
If the project has no agreements or deals with market makers, state that explicitly; doing so earns full credit. If no native tokens were loaned or allocated to market makers, state that explicitly; cash/fiat retainers or fees are not required for this item.
Response
Gala has published no market maker agreement, token loan arrangement, or term sheet. Two liquidity-related arrangements appear in the public record. Gala announced on July 3, 2024 that Animoca Brands would receive GALA tokens from the Gala treasury to provide liquidity provisioning services with the goal of facilitating orderly trading of GALA, without stating the size of the allocation or the term. DWF Labs, which describes itself as a market maker and multi-stage web3 investment firm trading on more than 60 exchanges, entered a partnership announced in September 2023 to support GalaChain ecosystem growth and obtained 60 million GALA under that arrangement, and it purchased a further 28 million GALA on the open market after the May 2024 incident. Gala has published no allocation percentage, contract term, loan or option structure, or fee arrangement for either counterparty. This record sits alongside the company statement that the project was independently funded with no investment rounds of any kind.
(Source: Gala Games and Animoca Brands Announce Collaboration, Did the GALA Token have an ICO, GALA Tokenomics)
Question
Projects must disclose all material terms of centralized or decentralized exchange listings that affect token liquidity. For each listing, include in a table:
If the project has no agreements or deals with CEX or DEX, state that explicitly; doing so earns full credit; cash/fiat fee amounts are not required for this item.
Response
Gala has published no exchange listing agreement, listing allocation, term duration, or native token listing fee for any venue. The disclosed venue relationships are integration announcements rather than commercial agreements. Gala announced on November 12, 2024 that GalaSwap had been rebranded to GalaConnect, which lets users swap GalaChain tokens including GALA through a peer-to-peer interface and bridge tokens to and from Ethereum. Gala announced on November 13, 2024 that Bitrue became the first centralized exchange to integrate GalaChain, allowing GalaChain-based GALA to trade without bridging to Ethereum. KoinBX integrated GalaChain and listed both ETH on GalaChain and GALA on GalaChain for trading on March 27, 2025. Tapbit enabled direct GalaChain GALA deposits and withdrawals on May 16, 2025. Alchemy Pay and Banxa provide fiat on-ramps, with Banxa joining the existing Alchemy Pay route in April 2025. Gala operates its own decentralized exchange, GalaSwap, and a launchpad, GalaPump. Ahead of the version 2 migration Gala contacted supported exchanges so that balances held in exchange wallets qualified at the snapshot.
(Source: GalaConnect is Here, Bitrue Integrates GalaChain, KoinBX Integrates GalaChain, GalaChain Now on Tapbit, , , )
Question
Disclose all prior token sales by the Project — including fundraising rounds, any material OTC sales to investors, and any discounted market-maker sales. For each sale, provide:
If no prior sales occurred, state that explicitly (e.g., "No prior fundraising, OTC, or discounted MM sales have occurred.").
Response
Investment Vehicle: No investment instrument exists. Gala issued no SAFT, no simple agreement for future tokens, no token warrant, and no equity round tied to token rights.
Date Of Sale: No sale date exists. The first issuance of any kind was the Founder's Node emission that began on September 11, 2020.
Number of tokens sold: Zero tokens were sold.
Vesting Schedule: No vesting schedule exists because no tokens were sold to investors.
(Source: Did the GALA Token have an ICO, GALA Tokenomics)
No prior token sale or fundraising round occurred. Gala states that GALA has never been available for purchase directly from Gala Games and Entertainment, that no initial coin offering was ever held, that there was no token sale or pre-mint phase, and that the project was independently funded with no investment rounds of any kind. Emissions to Founder's Nodes began on September 11, 2020 and remain the only issuance path. The single disclosed transfer of GALA to an investment firm is the 60 million GALA that DWF Labs obtained under the GalaChain ecosystem partnership announced in September 2023, which Gala announced as a partnership rather than as a token sale and for which no price, instrument, or vesting terms were published.
(Source: Did the GALA Token have an ICO, GALA Tokenomics, What is a Distribution)
Question
If any, list prior exploits or incidents that directly affected the token, token supply, tokenholder balances, token contract, minting controls, burn mechanics, or custody of token supply. This question is not asking about general protocol, application, or smart contract exploits unless the incident directly affected the native token itself.
If no prior incidents, state this explicitly (e.g., "No exploits affecting tokenholders or protocol funds as of YYYY-MM-DD").
Response
Two incidents have affected GALA. The first compromised an Ethereum minter key in May 2024. The second compromised the pNetwork bridge that issued a wrapped representation of GALA on BNB Smart Chain in November 2022.
Incident 1, unauthorized minting on Ethereum
May 20, 2024 at 19:32:11 Coordinated Universal Time. The affected component was an externally owned address holding MINTER_ROLE on the Ethereum GALA v2 token contract at 0xd1d2Eb1B1e90B638588728b4130137D262C87cae. The token contract code and GalaChain were not affected.
(Source: Incident Report, Unauthorized Token Minting, GALA token contract)
Incident 2, pGALA bridge compromise on BNB Smart Chain
November 3, 2022. The affected component was pGALA, the wrapped representation of GALA that pNetwork issued on BNB Smart Chain, together with the PancakeSwap pGALA liquidity pool. The Ethereum GALA contract and GalaChain were not affected and their supply did not change.
Question
Describe material risk factors across the three categories below. Each category includes prompts to address at a minimum.
(a) Regulatory, Legal & Tax Risks — Describe how evolving laws and regulations could affect the project by answering, at a minimum, questions like:
Impact of Regulatory Change on TGE and Listings: (If applicable) How could evolving or conflicting laws and regulations affect your ability to complete the TGE, deliver tokens to purchasers, and list or maintain the token on trading venues in key jurisdictions?
Entity-Level Regulatory Impact: (If applicable) How could regulatory or legal changes impact your core entities (Foundation, DevCo, DAO, affiliated service providers), including enforcement actions, licensing requirements, or forced changes to structure or operations?
Tokenholder Tax Treatment: (If applicable) What uncertainties exist around how tokenholders may be taxed, and make clear that tokenholders are responsible for understanding their own tax obligations?
Jurisdictional & User Access Restrictions: (If applicable) If the project restricts access for certain jurisdictions or user types (e.g., U.S. persons, sanctioned countries, retail vs. professional), what are those restrictions and what risks do they create for users and for the project?
(b) Protocol, Technology & Security Risks — Describe risks to network and contract reliability, correctness, and safety by answering, at a minimum, questions like:
Bugs and Design Flaws: (If applicable) What bugs, design flaws, or implementation errors could exist in your core protocol code, smart contracts, and any bridges, rollups, or oracles that you depend on, and how could these lead to loss of funds or disruption of the protocol?
Security Measures & Their Limitations: (If applicable) What security measures have you taken (audits, formal verification, bug bounties), and what types of failures might these measures still fail to detect or prevent?
(c) Token Economics, Unlocks & Incentive Risks — Describe how the token's economic design and supply schedule could affect holders by answering, at a minimum, questions like:
Critical Economic Assumptions: (If applicable) Which economic assumptions (e.g., staking yields, fee revenue, liquidity incentives, MEV capture, demand for blockspace) are critical for protocol security, utility, and governance, and what happens if those assumptions fail?
Question
Identify to the best of your ability the token's current deployments across chains, including project-issued deployments, project-endorsed representations, and, if possible, documented third-party wrapped or bridged representations.
For each entry, provide:
Multiple entries on the same chain are permitted.
Definition: A protocol-level asset is an asset whose balances and transfers are handled directly by the blockchain's core rules, rather than by a token smart contract. For protocol-level assets without a token contract address, enter "No contract address" and identify the asset and chain.
Response
This Token Transparency Filing is provided for general informational purposes only and does not verify or warrant the accuracy of individual answers.
(Source: Upgrading to GALA v2, Check If You Qualify And Will Receive GALA V2, GALA v2 per-address migration totals)
Secondary market concentration is visible on Ethereum. The largest holder of the GALA v2 contract is 0xF977814e90dA44bFA03b6295A0616a897441aceC, a Binance treasury address, holding 5,879,295,562.04 GALA, and 0x28C6c06298d514Db089934071355E5743bf21d60, a second Binance address, holds 509,181,769.34 GALA. CoinGecko reports 24-hour trading volume of 18,982,285 dollars against a market capitalization of 93,491,768 dollars as of July 27, 2026. Gala has disclosed no allocation of GALA to any exchange in connection with a listing and no payment of listing fees in GALA or in any other asset.
(Source: GALA token contract, CoinGecko GALA, Where To Get GALA)
Incident 1, unauthorized minting on Ethereum
A malicious actor compromised the private key of an address that held the minter role. Gala attributes the compromise to a breach involving a third-party contractor and to access controls that the company has since replaced. The actor called the mint function directly. No defect in the token contract was involved, and the actor never held the admin, upgrader, or blocklister roles.
Incident 2, pGALA bridge compromise on BNB Smart Chain
A pNetwork engineer embedded the plaintext private key for the owner address of the pGALA proxyAdmin contract in code that had sat openly exposed on GitHub for 67 days. Anyone holding that key had the power to upgrade the pGALA contract and mint arbitrary supply.
Incident 1, unauthorized minting on Ethereum
The actor minted 5,000,000,001 GALA to 0xe2Ca471124b124831e231fB835778840AD100F97 in a single transaction. Over roughly the following 40 minutes the actor liquidated part of that balance across dozens of transfers into four addresses beginning 0x465e56cd, 0x38f5e5b4, 0x72b1410d, and 0xbcc66fc7, and then returned 5,912 ETH to the Gala Finance Cold Wallet. 598,763,538.24 GALA had left the exploiter address by the time the burn executed.
Incident 2, pGALA bridge compromise on BNB Smart Chain
Approximately 55 billion pGALA were minted and swapped, draining more than 12,976 BNB, worth roughly 4.3 million dollars at the time, from the PancakeSwap pool.
Incident 1, unauthorized minting on Ethereum
Gala granted BLOCKLISTER_ROLE to an operational address at 21:46:47 Coordinated Universal Time on the same day and blocklisted the exploiter address. Gala then put a governance proposal to Founder's Node operators to deploy a hotfix version of the GALA contract that removes the illegitimate supply and to schedule the upgrade and burn within 72 hours, with voting open for 24 hours and a simple majority of 51 percent required to pass. On May 24, 2024 at 16:49:11 Coordinated Universal Time, in transaction 0x59d87edc805a83f1c6397f053dc3ffe159e3a752192bf709aac21d9d6bf71fb5, the admin Safe upgraded the proxy to a temporary implementation at 0xe22970745B9ED0c74f2F7731FA198060fD1a9808, called its burnExploitedGala function, which unblocklisted the exploiter address, burned its entire balance of 4,401,236,462.76439 GALA to the zero address, and reinstated the blocklist entry, and then restored the original implementation at 0x8D92A6812b3dA2346883F0631910c96Cb9c5a5f9 inside the same transaction. Gala also migrated internal access to Okta SAML with Identity Center and restrictive permission sets, redesigned its AWS role-based access control models, enabled AWS Macie, and engaged law enforcement.
(Source: Governance Proposal, Temporary GALA Token Contract Upgrade and Token Burn, Incident Report, Unauthorized Token Minting, Upgrade and burn transaction, Temporary implementation contract)
Incident 2, pGALA bridge compromise on BNB Smart Chain
pNetwork characterized the mint as a white-hat action taken to pre-empt a malicious actor and announced a recovery plan. Gala stated that it was not part of that process. On November 11, 2022 pNetwork stated that it could not proceed with the recovery plan. Gala then sued pNetwork on behalf of pGALA holders and stated that any damages recovered would be converted to GALA and burned.
Incident 1, unauthorized minting on Ethereum
Resolved. The proxy has recorded exactly three upgrade events across its life, the deployment upgrade in April 2023 and the two that installed and removed the temporary implementation inside the May 24, 2024 transaction. The live implementation at 0x8D92A6812b3dA2346883F0631910c96Cb9c5a5f9 contains no function that burns another account's balance, so the remediation capability existed for the duration of a single transaction and no longer exists. The exploiter address 0xe2Ca471124b124831e231fB835778840AD100F97 remains blocklisted and cannot send or receive GALA.
Incident 2, pGALA bridge compromise on BNB Smart Chain
The litigation against pNetwork is the disclosed remediation path and Gala has published no recovery distribution to affected holders. GALA now bridges to and from Ethereum through GalaConnect, which Gala operates, rather than through a third-party bridge.
Incident 1, unauthorized minting on Ethereum
The incident report, the governance proposal, and the onchain record of the upgrade, burn, and role changes are linked above.
(Source: Incident Report, Unauthorized Token Minting, Governance Proposal, Temporary GALA Token Contract Upgrade and Token Burn, Upgrade and burn transaction)
Governance Control over Monetary Policy & Rewards: (If applicable) To what extent can governance change monetary policy, fee parameters, or reward allocations (e.g., inflation rate, treasury flows, incentive programs), and how could such changes adversely affect tokenholders?
Response
Impact of Regulatory Change on TGE and Listings
GALA launched without a token generation event, an initial coin offering, or a fundraising round, and emissions to Founder's Nodes began on September 11, 2020. The absence of a sale removes the offering-side regulatory exposure that a token generation event creates, and it shifts the exposure to the ongoing distribution. A regulator that treats GALA as a security, or that treats the daily node distribution as an investment return paid on a purchased node license, would force changes to how the distribution operates and would restrict GALA on integrated venues in that jurisdiction. Gala markets Founder's Node licenses to retail buyers and states that a node is strictly not an investment, and a contrary determination would reach both the license and the reward. Divergent rules across jurisdictions fragment access and raise the cost of maintaining exchange and on-ramp integrations.
(Source: GALA Tokenomics, Did the GALA Token have an ICO, Founder's Node, Bitrue Integrates GalaChain)
Entity-Level Regulatory Impact
Legal and operational responsibility concentrates in one company, Blockchain Game Partners, Inc., a Wyoming corporation with a two-director board and no foundation, no DAO, and no other entity to continue its functions. That company develops GalaChain, operates its certificate authorities and orderers, and controls every privileged role on the Ethereum token. Enforcement action, a licensing demand, or an adverse legal outcome against the company would halt protocol development, chain operation, and token administration at the same time. The company has already been through control litigation. In Schiermeyer v. Thurston in the United States District Court for the District of Utah, True North United Investments, LLC sought a preliminary injunction appointing a custodian to act as president, chief executive officer, and sole director of the company, and the court denied that motion on August 21, 2024, holding that True North had failed to meet its burden and that simple economic loss usually does not in itself constitute irreparable harm. A different outcome in a future dispute would place control of the admin Safe and the chain operations in other hands.
(Source: Schiermeyer v. Thurston, D. Utah No. 2:23-cv-589-HCN-DAO, Wyoming corporation record, Admin and upgrader Safe, GalaChain Decentralization White Paper)
Tokenholder Tax Treatment
Node operators receive GALA daily, and most jurisdictions treat receipt of a reward token as an income event measured at the value on the day of receipt, with a separate gain or loss event on later disposal. The GalaChain Allowance design adds a timing question, because the reward accrues as an off-ledger allowance and reaches the chain only when the operator mints it, and jurisdictions differ on whether the accrual or the mint is the taxable moment. The May 2023 migration from GALA v1 to GALA v2 and any conversion between GALA and GSTAKE for node qualification each raise a separate disposal question. Gala publishes no tax guidance and holders carry sole responsibility for their own tax positions. This filing provides no tax advice.
(Source: What is a Distribution, Founder Node Staking, What's changing, Upgrading to GALA v2)
Jurisdictional & User Access Restrictions
Gala publishes no list of restricted jurisdictions and no public terms of service that set out geographic or user-type eligibility for GALA, GalaConnect, or Founder's Node licenses. Two structural restrictions do exist and are documented. GalaChain is a permissioned network, and access requires a registered account whose credentials Gala issues through the certificate authorities it operates, so Gala can decline or revoke access to any user at the network layer. The Ethereum token carries a blocklist that a 3-of-5 Safe controls and that can freeze any address, and Gala used it in May 2024. Users in jurisdictions that restrict token trading depend on the third-party exchanges and fiat on-ramps that Gala has integrated, and each of those venues applies its own eligibility rules.
(Source: GalaChain authorization docs, Blocklister Safe, Incident Report, Unauthorized Token Minting, Where To Get GALA)
Bugs and Design Flaws
GALA depends on four code surfaces. The Ethereum token is an upgradeable UUPS proxy at 0xd1d2Eb1B1e90B638588728b4130137D262C87cae whose implementation combines ERC20, burnable, permit, pausable, access control, and a custom blocklist, compiled with solc 0.8.9. GalaChain runs TypeScript chaincode on Hyperledger Fabric with a Raft ordering service in a star topology with centralized orderers, so a fault in the orderer set halts the chain. The GalaBridge contract at 0x9F452B7cc24E6E6FA690fE77CF5DD2Ba3dbf1eD9 is the sole minter on Ethereum and is the single point at which GalaChain balances become Ethereum balances, so a defect in its accounting mints Ethereum supply that no GalaChain balance backs. GalaConnect and the Gala wallet handle key custody for users who never touch an Ethereum wallet. The realized failure in this stack was operational rather than a code defect. On May 20, 2024 a compromised minter key produced 5,000,000,001 GALA of unauthorized supply, and Gala confirmed the contract itself was not breached. The design concentrates recovery capability in the same place as the risk, because the 4-of-8 Safe that holds UPGRADER_ROLE can replace the implementation with arbitrary code at any time and without a timelock, which is how the May 2024 burn executed. Compromise of four of those eight signing keys would allow an attacker to install an implementation that reassigns or destroys balances.
(Source: GALA implementation contract, GALA token contract, GalaBridge minter, GalaChain Decentralization White Paper, Incident Report, Unauthorized Token Minting, Upgrade and burn transaction)
Security Measures & Their Limitations
Five measures are in place. The Ethereum implementation source is verified and readable at 0x8D92A6812b3dA2346883F0631910c96Cb9c5a5f9. Privileged roles are split across separate multisignature wallets, with a 4-of-8 Safe holding admin and upgrader and a 3-of-5 Safe holding blocklister, and minting restricted to the GalaBridge contract rather than to any human-held key. The implementation enforces a hard 50,000,000,000 GALA cap on every mint and blocks the blocklisting of any address that holds a role. A pause function halts every transfer, approval, and role change. On GalaChain, two authorization layers apply, an organization layer using Fabric certificate authority membership service providers and a user layer using secp256k1 signatures, with replay protection through an optional expiry field, a mandatory unique key on submit transactions, and an operation field that binds each request to a specific channel, chaincode, and method. The limitations are material. Gala has published no independent smart contract audit report and no bug bounty program scope for the GALA token contract or GalaChain, and the Certik reference in the decentralization white paper covers a throughput measurement rather than a security review. No role carries a timelock, so an upgrade, a pause, or a blocklist takes effect the moment a Safe reaches its threshold and holders receive no notice period. Section 5 of the decentralization white paper, covering the economic model and incentives, states that the section is still being worked on, so the incentive design that would secure a future validator set is unpublished. The May 2024 breach originated in third-party contractor access rather than in contract code, and the remediation Gala describes is identity and cloud access hardening through Okta SAML, Identity Center, redesigned AWS role-based access control, and AWS Macie, none of which is verifiable from published artifacts.
(Source: GALA implementation contract, Admin and upgrader Safe, Blocklister Safe, GalaChain authorization docs, GalaChain Decentralization White Paper, Incident Report, Unauthorized Token Minting)
Critical Economic Assumptions
Three assumptions carry the design. The first is that enough Founder's Node operators keep running node software for the daily distribution to remain meaningful and for the node network to support the chain. Since June 16, 2025 a full reward requires 1,000,000 GALA held or staked per node, so an operator with a smaller balance earns proportionally less, and at a GALA price of 0.0019058 dollars that threshold represents roughly 1,906 dollars of capital per node held against a reward stream. Falling price or falling reward makes node operation uneconomic and shrinks the operator set. The second is that Gala's game, film, and music businesses generate demand for GALA as a payment and gas asset, because the token has no fee claim, no dividend, and no revenue share, and Gala states that ownership of GALA carries no rights, express or implied. The third is that the emission formula stays in balance with burn. Daily emission equals 0.25 percent of the gap between total supply and the 50,000,000,000 cap, which means emission falls as supply approaches the cap but never reaches zero, and the offsetting burn depends entirely on GalaChain transaction volume. With circulating supply at 49.04 billion against the 50 billion cap, the remaining gap is under 1 billion GALA, so the daily emission that funds node rewards is now a small fraction of what it was and continues to shrink. The reward stream that motivates node operation therefore declines structurally over time regardless of ecosystem growth.
(Source: Founder Node Staking, What's changing, GALA Tokenomics, What is GALA, CoinGecko GALA, What is a Distribution)
Governance Control over Monetary Policy & Rewards
Control over monetary policy sits with Blockchain Game Partners, Inc., exercised through a Founder's Node vote and executed by a 4-of-8 Safe. Tokenholders who do not own a node license have no vote. Gala changed the emission model in August 2024 from a halving schedule to the dynamic 0.25 percent formula and changed reward qualification in June 2025 to require 1,000,000 GALA per node, and it can change either again. The May 2024 response demonstrates the ceiling of that authority. A 24-hour vote requiring a simple majority of 51 percent of Founder's Node operators, followed by a Safe transaction, upgraded the token implementation, burned 4,401,236,462.76439 GALA from a specific address, and restored the prior implementation inside a single transaction with no timelock and no notice period. The same mechanism can raise or lower emission, redirect the distribution, freeze addresses through the blocklister Safe, pause all transfers, or install an implementation that changes balances. Voting power concentrates in node license holders rather than in the broad holder base, so a limited group directs decisions that affect every holder. GALA also gives its holders no way to exit that control, because the token carries no redemption right and no claim on the company.
(Source: Governance Proposal, Temporary GALA Token Contract Upgrade and Token Burn, Upgrade and burn transaction, GALA Tokenomics, Founder Node Staking, What's changing, Admin and upgrader Safe, Voting in the Gala Node Dashboard, What is GALA)
