You could always have the end user drop in their legally obtained copy of CARDS....

ChickeNES 31 days ago | parent | context | favorite | on: Remake of the Windows 95 Solitaire game

You could always have the end user drop in their legally obtained copy of CARDS.DLL from older versions of Windows, and then parse the NE to extract all of the card images...at least, that's what I did when I made a clone of Windows Solitaire :)