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Old 4th August 2006, 02:38 PM
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Post PR: eCOGRA COMPLIANCE COMMITTEE REPORT ON JACKPOT FACTORY SEARCH ENGINE ISSUE

eCOGRA COMPLIANCE COMMITTEE REPORT ON JACKPOT FACTORY SEARCH ENGINE ISSUE

On 28 July 2006 the Compliance Committee of eCommerce and Online Gaming Regulation and Assurance, made up of Mr. W. Galston OBE (Chairman) , Mr. F. Catania and Mr. M.Hirst OBE, all independent directors of the organization, considered all the facts regarding an incident in which complaints were received concerning search engine optimisation practices be conducted by the Jackpot Factory group.

The Committee received a report of an independent and on-site investigation which had been carried out by external auditors. This covered the circumstances surrounding the issue, its causes and effects and the remedial actions taken by the company.

The Committee findings are that:

1) The nature and tenor of the Jackpot Factory search engine optimisation project was totally unacceptable because of the fictitious and misleading scenarios it portrayed. This had resulted in widespread public disapproval of the campaign.

2) However, there was no evidence to show that any individual or group of individuals were harmed or persuaded to indulge in potentially harmful behaviour by the campaign, which represented an important mitigating factor.

3) Similarly, there is no evidence to suggest that Jackpot Factory management had any deliberate intention to encourage vulnerable persons to participate in gambling activities at group casinos

4) The investigating team report indicates that it is satisfied that the Jackpot Factory claim to have outsourced the project initially is correct. However, the report finds, and Jackpot Factory management conceded that the company's supervision of the project was inadequate.

5) The report confirms that internal disciplinary action taken by the company against those responsible was appropriate.

6) The Committee also considered the more positive aspects of the case and in particular the actions of Jackpot Factory in the immediate aftermath of the issue coming to public attention. On two occasions the company admitted fault in the matter and offered public apologies.

Management backed this up by re-directing company resources and mounting a committed and energetic exercise to track down every element of the campaign that could be found in order to remove it, at the same time urging the public to report any elements discovered so that these could be addressed.

7) Jackpot Factory management cooperated fully with the independent investigation team, presenting verbal and documentary evidence without reserve to assist in its investigations.

8) Jackpot Factory management has since deployed control improvements in its systems as suggested by the investigation team, which will guard against any repetition of this unfortunate incident. Processes are now in place to ensure that any further material that may surface as a result of this campaign is dealt with on a timely basis.

9) Evidence was produced showing that the damage to business and reputation suffered by Jackpot Factory was substantial, as a consequence of public disapproval and the suspension of the Play It Safe seal.

10) Before the incident, Jackpot Factory had a solid reputation for compliance with all eCOGRA standards and requirements.

Having considered all of the above, the Compliance Committee has made the following ruling:

The suspension of the "Play It Safe" seal is lifted, but Jackpot Factory will be subjected to increased eCOGRA monitoring to ensure compliance with the new content code of practice. This is to ensure that all remaining traces of the campaign are removed wherever this is possible. The Compliance Committee is aware of the existence of inactive search engine links, but is satisfied that these do not provide access to any offensive material. The removal of this type of link is solely under the control of the search engines.

The Committee wishes to thank all those representing players’ interests for their comments during the initial complaints and throughout the investigation. It also notes that the investigation team received the full cooperation of the Jackpot Factory management and is satisfied that they have shown their determination that this should not happen again.

The goal of eCOGRA in incidents such as this is to remove the immediate cause and potential for harm as quickly as possible, and then through fair and factual investigation isolate the reasons and ensure that systems are in place to guard against any repetition. These objectives have, in the opinion of this Committee, been met.
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Old 4th August 2006, 03:54 PM
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So the "3rd party" excuse worked again, I see.


Didn't they:

Take well over a month to pull the pages?

and most of all:

APPROVE THIS CAMPAIGN?

C'mon...they knew damn well what was going on, and could have stopped this from ever happening by simply NOT authorizing it to go any further.

..and damage resulting from this or not, they still should have faced a steep fine.
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Old 4th August 2006, 04:21 PM
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There have to be occasions when the "outsourcing" excuse is actually true imo.

In this case JF admitted fault upfront from the start. Fault for not having the right control systems in place to pick up this campaign and kill it, and it looks as if the investigating team has confirmed their explanation.

Note the following from the report Bryan has published above:

4) The investigating team report indicates that it is satisfied that the Jackpot Factory claim to have outsourced the project initially is correct. However, the report finds, and Jackpot Factory management conceded that the company's supervision of the project was inadequate.

5) The report confirms that internal disciplinary action taken by the company against those responsible was appropriate.

6) The Committee also considered the more positive aspects of the case and in particular the actions of Jackpot Factory in the immediate aftermath of the issue coming to public attention. On two occasions the company admitted fault in the matter and offered public apologies.

Management backed this up by re-directing company resources and mounting a committed and energetic exercise to track down every element of the campaign that could be found in order to remove it, at the same time urging the public to report any elements discovered so that these could be addressed.

Judging by the closing comments of the compliance committee it looks as if new controls have been instituted under the direction of the investigating team. Hopefully that will ensure that this does not happen again.

This should send a warning signal to other operators too - point (9) of the findings is interesting in that it underlines that there were businees consequences for JF as a result of public repugnance at the campaign.

Regarding the question of a fine, the final paragraph of the committee's findings indicates what eCOGRA's remit is, I think. It's to investigate non-compliance incidents and then ensure the company gets back on the straight and narrow.

Presumably if a company refuses to do that, the only punitive measure that can be applied is the permanent removal of the Play It Safe seal, and that probably entails excommunication, too.
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Old 4th August 2006, 04:23 PM
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Well I guess here goes another 55+ page thread of more JF bashing!
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Old 4th August 2006, 05:01 PM
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Now - if we could get this type of investigation going for:

888.com!!!!!!!!!!

and

Casino Partners



For blatant spamming, affiliate scrapers, spamdexing, and any number of offenses that are JUST AS BAD - but completely overlooked.

I think this is a joke, running an investigation on JF when there is so much worse out there. My opinion, though...
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Old 4th August 2006, 07:35 PM
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Quote:
Originally Posted by Casinomeister
eCOGRA COMPLIANCE COMMITTEE REPORT ON JACKPOT FACTORY SEARCH ENGINE ISSUE


2) However, there was no evidence to show that any individual or group of individuals were harmed or persuaded to indulge in potentially harmful behaviour by the campaign, which represented an important mitigating factor.
I'm not expecting miracles, but the quoted point's logic does not satisfy me.

It's akin to saying that a person who steals the stop signs from an intersection isn't as guilty since no car accidents occurred there.

Also, it would be impossible to prove whether or not any harm was caused to any individual player, therefore claiming that there was 'no evidence to show...harmed' carries no weight imho.


Just my opinion.
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Old 4th August 2006, 08:40 PM
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eCOGRA COMPLIANCE COMMITTEE REPORT demonstrates that eCOGRA's investigation was in depth and covered all areas of possible concern with regards to the Jackpot Factory search engine issue.

My compliments to eCOGRA for doing a good job.

Let's not turn this into another 30 pages of trashing Jackpot Factory for their SEO mistakes - mistakes which they have stood up and taken full responsibility for. Complaints were made, resulting in Jackpot Factory's eCOGRA seal being suspended while an investigation proceeded.
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Old 4th August 2006, 08:46 PM
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Quote:
Originally Posted by rowmare
eCOGRA COMPLIANCE COMMITTEE REPORT demonstrates that eCOGRA's investigation was in depth and covered all areas of possible concern with regards to the Jackpot Factory search engine issue.

My compliments to eCOGRA for doing a good job.

Let's not turn this into another 30 pages of trashing Jackpot Factory for their SEO mistakes - mistakes which they have stood up and taken full responsibility for. Complaints were made, resulting in Jackpot Factory's eCOGRA seal being suspended while an investigation proceeded.

This I agree with.

Now - get eCogra to look into 888, CasinoPays, and Casino Partners SPAM. They are damaging the industry pretty bad IMO.
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Old 4th August 2006, 10:04 PM
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Quote:
1) The nature and tenor of the Jackpot Factory search engine optimisation project was totally unacceptable because of the fictitious and misleading scenarios it portrayed. This had resulted in widespread public disapproval of the campaign.
This is putting it very mildly. The campaign not only portrayed ficticious and misleading scenarios, it actively sought to prey on the vulnerabilities of weak or sick people. This alone merits heavy sanctions if not termination of membership.

Quote:
2) However, there was no evidence to show that any individual or group of individuals were harmed or persuaded to indulge in potentially harmful behaviour by the campaign, which represented an important mitigating factor.
I take this to mean that not a single person clicked on a link or signed up at a casino. I find this absolutely incredible considering the size and prominence of the campaign. In any event, this can hardly mitigate the intent of the campaign and, in a real-world situation, this would not be considered mitigation at all under any circumstances.

Quote:
3) Similarly, there is no evidence to suggest that Jackpot Factory management had any deliberate intention to encourage vulnerable persons to participate in gambling activities at group casinos
Again, totally incredulous. This was a huge campaign, and very controversial, to say the least. For anyone to believe that the staff or contractor would NOT tell management of this campaign, let alone launch it, is a total insult to the intelligence to all people in the industry.

Quote:
4) The investigating team report indicates that it is satisfied that the Jackpot Factory claim to have outsourced the project initially is correct. However, the report finds, and Jackpot Factory management conceded that the company's supervision of the project was inadequate.

5) The report confirms that internal disciplinary action taken by the company against those responsible was appropriate.
And exactly what action was taken? Staff had already left the firm well before this issue came to light - so exactly WHAT action was taken against whom?

Quote:
6) The Committee also considered the more positive aspects of the case and in particular the actions of Jackpot Factory in the immediate aftermath of the issue coming to public attention. On two occasions the company admitted fault in the matter and offered public apologies.

Management backed this up by re-directing company resources and mounting a committed and energetic exercise to track down every element of the campaign that could be found in order to remove it, at the same time urging the public to report any elements discovered so that these could be addressed.
It took them nearly a month, and on a couple of occasions they claimed that everything had been fixed when in fact the opposite was true. I do not consider this a positive aspect at all. Jackpot Factory should have taken down their entire site and replaced it with a simple one page site indicating that maintenance was going on. They did not acknowledge their complicity in the issue except in the forums, when they should have been required to either publicly apologize on the front pages of their sites or send emails to all players.

Quote:
7) Jackpot Factory management cooperated fully with the independent investigation team, presenting verbal and documentary evidence without reserve to assist in its investigations.
Challenge. Based on the above information I cannot believe this to be true.

Quote:
8) Jackpot Factory management has since deployed control improvements in its systems as suggested by the investigation team, which will guard against any repetition of this unfortunate incident. Processes are now in place to ensure that any further material that may surface as a result of this campaign is dealt with on a timely basis.
Irrelevant. If a criminal were caught committing a crime, would he be let off if he promised not to do it again? Obviously not saying that JF is criminal but this point cannot be considered mitigation either.

Quote:
9) Evidence was produced showing that the damage to business and reputation suffered by Jackpot Factory was substantial, as a consequence of public disapproval and the suspension of the Play It Safe seal.
Irrelevant. Damage to business and reputation was their own doing, and should have no bearing on any subsequent decisions taken with regards to their status. Had the evidence shown otherwise, would this have caused eCOGRA to take a negative view of this point?

Quote:
10) Before the incident, Jackpot Factory had a solid reputation for compliance with all eCOGRA standards and requirements.
Irrelevant. Might be allowed if JF had committed a relatively minor mistake accidentally - but this is way beyond accidental or minor.

Quote:
Having considered all of the above, the Compliance Committee has made the following ruling:

The suspension of the "Play It Safe" seal is lifted, but Jackpot Factory will be subjected to increased eCOGRA monitoring to ensure compliance with the new content code of practice. This is to ensure that all remaining traces of the campaign are removed wherever this is possible. The Compliance Committee is aware of the existence of inactive search engine links, but is satisfied that these do not provide access to any offensive material. The removal of this type of link is solely under the control of the search engines.

The Committee wishes to thank all those representing players’ interests for their comments during the initial complaints and throughout the investigation. It also notes that the investigation team received the full cooperation of the Jackpot Factory management and is satisfied that they have shown their determination that this should not happen again.

The goal of eCOGRA in incidents such as this is to remove the immediate cause and potential for harm as quickly as possible, and then through fair and factual investigation isolate the reasons and ensure that systems are in place to guard against any repetition. These objectives have, in the opinion of this Committee, been met.
Messrs. Catania, Galston, and Hirst, I respect your positions and past work in the industry and I believe that you feel that you have done the right thing here. I believe all of you are no-nonsense, honest businessmen/contributors and have all played key roles in the development of the online gambling industry.

However, I believe my opinion will represent a majority of observers (though I am only speaking for myself). I believe that you have been mislead and misinformed in order to reach this atrocious decision and I urge you to reconsider, re-investigate, and interview parties outside of Jackpot Factory who may have additional knowledge and evidence which you have not yet seen.

At this point, I have nothing else to say except to register my extreme disappointment at this development.
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Old 5th August 2006, 04:19 AM
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Quote:
Originally Posted by kwblue
Now - if we could get this type of investigation going for:

888.com!!!!!!!!!!

and

Casino Partners



For blatant spamming, affiliate scrapers, spamdexing, and any number of offenses that are JUST AS BAD - but completely overlooked.

I think this is a joke, running an investigation on JF when there is so much worse out there. My opinion, though...
I agree


eCogra had to go after someone though!

It took the heat off 888.com and John Anderson's obvious conflict of interest issues. 888.com flew under the radar once again followed closely by CP.
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