Great write up. There does indeed seem to be a lot of similarities there.
Some random thoughts to add on (I'm also not well versed in gift card law):
  • expiration dates can indeed apply to ecash if you build it as such. Makes it seem even more like a gift card.
  • I think there's open loop and closed loop gift cards. Ie visa gift cards vs Walmart, which have different laws for
  • the redemption back to cash is something I'm unsure of. In ecash, if you made the argument it's a gift card, but allow for the issuer to allow conversion back to BTC, does it still apply? You don't really see conversion allowed by Walmart gift cards (though you make an interesting point for when it dips below a certain point)
  • what can you spend the ecash gift card on? Is it allowing you to buy something in that network? I'm not sure if gift card laws can apply if it's only purpose is to eventually redeem the gift card and not actually "use it to make a purchase"
In either case, "For now, I'm going to say that I am purchasing ecash tokens when I send my sats to a mint." is very much how im looking at it too whether that may be 100% accurate or not.
I think most (probably all) the open loop gift cards are issued by banks and credit card companies who have money transmitter licenses and are so regulated that there isn't much additional burden for them.
I like the analogy when it is with closed loop cards. One way to put it is that you buy the ecash from the mint and then you spend the ecash at the mint to buy different btc. Kind of like using an azteco voucher with fiat.
Another way would be you buy the ecash from the mint and then you spend it at a shop in your community that also accepts ecash, but under the hood, isn't the first ecash token being returned to the mint and changed into a new token? I thought this is how they avoided double spending. If so, you can never actually spend your ecash anywhere but at the mint. Just like you can't spend a closed loop gift card anywhere but at the store that issued it.
The hard part is defining what service you are prepaying for when you enter the mint with your btc.
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