It's either:

1. A game with no real betting, but probably adverts to drive revenue.   or:

2. A proper Ponzi-game with real (and/or virtual) money invested/gambled/lost, but properly regulated and licenced as a gambling site.

I just reckon the Ponzicoin name could get some great global press on the back of 'Bitcoin is not a Ponzi, but PonziCoin actually is intended to be one'.....