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if you call all betting gambling, then sure. but gambling in legal terms has definitions like "a game of chance". For example, poker is gambling but it isn't necessarily a game of chance, you can win it by skill (some consider it a sport). Rolling dice isn't the same as sports betting. It is similar to sports betting, except even in sports betting there are enough variables for outcomes to be very unpredictable. This is more like insider trading, except it insider trading is a feature, except you can also roll dice and play a pure game of chance.

Maybe it can fall under gambling laws, but not under securities laws.

I don't agree with any gambling laws whatsoever, so I can't say I'm the right person to comment on the subject of how to classify this sort of betting. The entire concept of individual liberty is a farce if you can't gamble without restriction. People have been betting on who would kill the prey or gather the most fruits since their hunter & gatherer days. Gambling and freely sharing what you posses (copyright is illegitimate) are fundamental human rights.