As a gacha game, yes, it can be viewed as a pay-to-win game where free players don't have enough chances or opportunities to get the best and the rarest cards in the game. This means that usually, the free-to-play users will have to spend a significantly higher amount of time in-game, grinding and hoping for good drops from their gacha pulls versus the P2P players who just simply buy crystals and spend them on summons until they get the DBL fighter that they desire.