Can't Kobos be registered to an AdobeID? If so, I fail to see why DRM-free is a requirement (assuming DRM-free is a functionality concern and not an idealistic one, of course). Google Play books use Adobe encryption, Kobo devices can read ADE fulfilled epubs (if you register your device to a free Adobe ID), and Google Play gift cards are sold in all kinds of B&M stores. Bing, bam, boom.
Unless there's a "don't want no stinking Adobe ID" requirement I missed somewhere in the list lof demands.
