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So just make every game free to play and then require a paying to unlock the actual game.

As ever it will come down to judicial discretion whether trivial word games are allowed to nullify the law or not.

That'd IMO count as a monetary consideration, and thus not be excempt.

I wonder if making the game free to play before shut down would allow them to skirt the law?

I doubt it, as that'd not nullify the contract established by people who bought the game before it went FTP.