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Thread: Announcement from the GRA concerning Hilo and ReelDeal games

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    Announcement from the GRA concerning Hilo and ReelDeal games

    I've just received the statement from the Gibraltar Gambling Commission concerning the Hilo and ReelDeal games.

    Please bear in mind that commenting is to be expected, but members who chose to turn this into a self-serving forum circus will be dealt with appropriately. I am out this week, but the moderators will be monitoring this for any questions or valid comments. Thanks!



    Gibraltar Gambling Commissioner’s response to allegations on Casinomeister in December 2012/January 2013 (repeated elsewhere) regarding Hilo and ReelDeal games.

    I must first make clear that, given our knowledge and experience of our licensees, their content suppliers and their testing/test house procedures, this case never had any of the dishonest elements referred to by the thread, which seemed to take over its focus, and were repeated in the thread and elsewhere as if established fact. Whilst we keep an open mind on such issues, and have seen in other jurisdictions that it is possible for dishonest operators or software producers to enter the remote gaming industry and thrive, in Gibraltar we proactively guard against this by a very restricted licensing policy (only 25 licensees, all leading European/US suppliers). As a consequence we are able to start from the position that all of the operators involved in this incident are well known to us, are well established and subject to respected corporate and personal licensing regimes here and/or elsewhere. That said, here and elsewhere, mistakes can happen, bugs do occur.

    Equally so, it was apparent to us from the moment the ‘katie91’ thread was initiated that the author was involved in some form of fraudulent activity. The posting simply did not ring true and should have set off the alarm bells of any experienced reader or regulator. Again, that does not preclude the author from making accurate or useful observations, but what it does do is render his credibility and the credibility of his evidence as close to useless, especially in the context of regulatory action. Anything such a witness says has to be taken with a huge degree of scepticism. If you doubt this, play the facts back against yourself: you are wrongly accused of dishonesty by a person who is dishonest; how should the regulator react? Dishonest complainants get little sympathy from us, they are not a platform on which you can build regulatory action. Indeed, they mean you have to cross check and double check absolutely everything, because you don’t know where the lies start and end.

    A third important element was the contributions to the thread by people with biased perspectives. This is why we asked Elliot to take it down (which he declined). The words ‘kangaroo court’, ‘hysterical witch-hunt’ and ‘stoking the flames’ come to mind when reading many contributions. This is aggravated by us knowing who some of the contributors are, the irregular practices some of them engage in themselves, and the agendas that some of them are pushing. These comments do not apply to all of the contributors, but many of them reading this will know that they too have ‘dirty hands’ in terms of their own account activities, or were pursuing private agendas rather than properly assessing the merits of the complaint.

    Fourthly we, as a public authority, must operate within the law. We must apply the rules of natural justice, and give any named parties accused of regulatory failings the opportunity to research and explain how and when the alleged failure occurred. We must then test and check that explanation, which is likely to lead to more questions, and the process may repeat itself a number of times as each party becomes satisfied that the explanation ‘makes sense’ and all other notions can be discounted. This process may also lead to us reviewing our own requirements in terms of how the game error got through the testing and reporting process and how we investigated it; indeed, due to a small but unacceptable number of incidents during in 2012 where game bugs were discovered or reported to us later than we expect, we have amended our own processes, as have a number of our operators. During the lifecycle of this complaint we have also had to deal with numerous other licensing cases and regulatory issues where those parties were at least equally able to claim our time and attention as were the drivers and issues in this matter.

    Turning to the game itself. We have had detailed and repeated conversations with all the suppliers involved and with advisers outside that circle. The origins of the discrepancy between Play for Real (PFR) and Play for Fun (PFF) and the paytable error on PFR rest in the creation of the games. The HiLo game was created in 2003/4 and is derived from a well established machine game. Reel Deal is a skin of the game and was created a few years later but uses the same underlying programme. The games have always been supplied as PFF and PFR.

    In the period 2004 - 2008 and beyond there was no overt requirement by regulators for PFF and PFR to have identical features and performance. Indeed, in some jurisdictions this is still the case, but since 2008 more and more regulators have made this a stipulation, generally, with the alternative that if the games are not identical, this should be made apparent in the game rules. The upshot of this situation is that apparently identical games on PFF and PFR can have different performances if the rules make this clear. So differences are not absolutely disallowed, but they should be identifiable and should not mislead the player of the game in a material way. That said, most European licensed operators have moved towards making PFF and PFR ‘identical’ or as close to as practical.

    It must also be recognised that PFF is a relatively little used feature of most operator’s facilities when compared to PFR, and most if not all players realise that PFR games are weighted for the house to win overall, with most customers losing, and only a small number of customers making wins of any scale. Let us not delude ourselves that PFR games are designed so that the house doesn’t win but the players do. The reality is that the house, overall, and a small number of players, will win, the rest will lose.

    The original HiLo game used an
    RTP
    /maths methodology known as ‘Fixed Price’ but with different
    RTP
    and RNG’s for PFF (100%) and PFR(96%); in very simple terms, the PFR game logic amounted to each customer choice producing an RNG number between 1 and 10,000, with numbers below 4800 winning and numbers above, losing, creating 96%
    RTP
    entirely randomly and a house win of 4%; the PFF gave a 50:50 chance. The RNG’s themselves were different for PFF (Flash) and PFR (Server integrated) as the games did not need to be identical.

    In 2006 a second version of the game mechanic was produced but using a different game logic known as ‘Fixed Odds’. In this case the game logic for both versions was 50:50 on the player’s choice, but the payout for winners was less than evens, again producing an overall house win of 4%. As the payout was less than evens both PFF and PFR versions had
    RTP
    ’s of 96% and the versions also used different RNG’s.

    Operators were able to offer either the Fixed Odds versions or the Fixed Price versions. Both games were in use with a very small number of operators.

    We have studied the use of these games and in both versions, to the overwhelming majority of customers, they are low priority, low interest games, but they can produce a positive income stream to operators. I will also make the point at this stage that any material variation of theoretical
    RTP
    created by the game mechanic is invariably reflected only in how long the customer’s deposit lasts, rather than his or her eventual losses or winnings. Some players may end their game session ‘up’, but games like these, with low turnovers and relatively low prize values, do not produce, and bugs do not prevent, ‘jackpot winners’, because there are none in the game structure. These are ‘churn games’ played by legitimate players for entertainment, with occasional prizes, but overall with players re-spending and ultimately losing their deposits. Shading up and down the
    RTP
    only extends or shortens the play time, with the possibility of more players stopping playing or moving games whilst in credit the nearer the
    RTP
    is to 100%. Even with an
    RTP
    of 100%, every player will not win or even break even, though their money may last a little longer.

    These games, in all versions, have been subject to independent testing and do behave entirely randomly, they are not ‘adaptive’ or illegal in any way. They do not ‘misrepresent’ the players’ chances. The error was in the production and presentation of a discrepancy in the paytables.

    The discrepancy occurred over an extended time frame and due to an initial error not being detected, and it allowing a second error to occur. As is the case with errors, the record of the errors occurring is not precise. That this was ‘an error on an error’ has also made it difficult to reverse engineer and isolate the mistakes. That said, neither error affected the performance of the PFR games but they did affect the apparent performance of the PFF games and ultimately the content of the paytable for Fixed Price PFR.

    In the first instance, a decision was made to put all the game versions on the same server based RNG rather than using the Flash version for PFF. The RNG change was done successfully. However, when it was done, the PFF on the Fixed Price version still operated at 100%
    RTP
    game logic, as it had been assumed at the time of this change that all the games used the same game logic (96%). Whilst this error made no difference to the random performance of the games, it meant the Fixed Price versions continued with different
    RTP
    ’s.

    Subsequently, the content of the games’ paytables were upgraded from static to dynamic. This was when a second error occurred. Both Fixed Price Help Files were linked to the PFF outcomes (100%) and so the Fixed Price Help File indicated that both versions had an
    RTP
    of 100%, when PFF was still 100% and PFR was 96%. This meant that, as was alleged by Katie91, a player could form the belief that the PFR game had an
    RTP
    of 100%. As I have already said, whilst this is a technical possibility, it is a commercial ‘impossibility’, it would be an error, as a PFR game returning 100% would be doomed to commercial failure. Katie91 sought to exploit this error and complained when his bot produced large losses.

    Now my analysis and explanation is not going to please those who felt they had a fox (or a fix) in their sights, but in our view katie91, who we have spoken to and has admitted his actions, used false details to ‘multi-account’, and was using a bot, indeed, he writes and sells bots, so he was knowingly and deliberately in breach of the operator’s
    T&C
    ’s on at least two significant matters, in an effort to obtain money in a way he knew he was not entitled to. If katie91 had used his real identity he would have run the risk of being declined or discovered; if he had asked ‘can I use a bot’ he would have been declined; so the katie91 account should never have existed, the game play should never have taken place. katie91 is the ‘villain of the piece’ whereas the thread held ‘her’ up as some kind of puritan victim of a corporate conspiracy. These were not minor breaches of
    T&C
    ’s, they are fundamentals. If you want to support other players making fundamental breaches of
    T&C
    ’s in order to win, or make them yourself, then you are asking for the end of the legitimate industry.

    In dealing with the operators, we have expressed our disappointment to them that the game carried the defect. We have reiterated our policy of ‘bugs may happen, but they must not happen very often, or else’. The ‘or else’ being a ramping up of expensive testing processes to higher levels, delays or down time for games, lost revenues, weaker offers, nothing gained by anyone, as bugs will still occur. We have also reminded intermediary suppliers of games who perform upgrades that when things go wrong, liability isn’t split, it is multiplied – everyone in the supply chain has to take responsibility, not just the writer, not just the intermediary and not just the front end operator. They have all taken a hit from this.

    Finally, whilst there are 60+ pages of thread to respond to, I am not going to do that. It is unfortunate that we have taken 4 months to publish our conclusions, but the game was taken down as soon as the error was discovered and we have had to work through the unlikely explanations and discount them, as well as the likely explanations and confirm them. The customer loss/operator gain is not significant and we see no case for reimbursements; the supply parties have been disturbed by the case and have felt the discomfort of regulatory interventions. You might want to dissect my points and continue to debate the issue, but the case is now closed, everyone needs to learn from it and move on.

    Phill Brear
    Gambling Commissioner
    May 2013.




    Last edited by Casinomeister; 28th May 2013 at 06:14 PM. Reason: uploaded corrected copy
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    Quote Originally Posted by Casinomeister View Post
    I've just received the statement from the Gibraltar Gambling Commission concerning the Hilo and ReelDeal games.

    Please bear in mind that commenting is to be expected, but members who chose to turn this into a self-serving forum circus will be dealt with appropriately. I am out this week, but the moderators will be monitoring this for any questions or valid comments. Thanks!
    I will try to be constructive here despite being disappointed that the awaited statement tells us what we knew already
    1) the original poster was a bad un
    2) a mistake was made in the software help file
    3) The play game differed from the real money game

    and seems to add one new bit of information - that the regulator is disappointed with the error but is taking no action. Indeed it is offering a defence of its licencees against malicious allegations rather than taking any action.

    It is a bit of a none statement really.

    As a constructive approach I suggest a list of the questions outstanding from the thread and this case. Some are direct to this one instance, others are about the regulatory weaknesses it has highlighted.

    1) Why did the certification not catch this problem? How will this change in future?
    2) Was the
    RTP
    of the fixed price real money version altered (varied) without notification to players?
    3) Can the
    RTP
    be changed by a supplier without recertification or notification to players?
    4) Can the optimal play of a game be altered without recertification or notification to players?
    5) Which parties testing failed? Was it the licencee or the supplier? Indeed did the licencee do their own test as required by the licence?
    6) Why do the mandatory quarterly checks of returns from games not include reference to the advertised
    RTP
    ? Is it clear that these checks happen at all?
    7) What measures have been put in place to prevent a re-occurrence?
    8) What refunds to players will be made?
    9) What happened to the extra money won compared to the advertised
    RTP
    ? The UKGC precedent for a
    FOBT
    machine was that it went to problem gambling research/help but here the players are identifiable.
    10) Is it possible for the fixed price available for the same brand of game to differ between licenced suppliers? (Under the same certification)
    11) Is it possible to have different optimal play for the same brand of game using the same certification at different sites?

    Feel free to improve the above questions or add to them.

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    Holy sh*t, the BIGGEST issue was that it's a card game that doesn't behave like a real deck of cards, and they didn't address it?

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    GRA: "If katie91 had used his real identity he would have run the risk of being declined or discovered; if he had asked ‘can I use a bot’ he would have been declined; so the katie91 account should never have existed, the game play should never have taken place."

    So what? Does that mean it was ok for Betfred/Finsoft/Spielo/Gtech et al and many others to scam their punters for 4 or 5 years?

    Thank goodness that Katie did break their terms and bring this cheating to the public's attention, otherwise we would not have concrete proof that BF, GRA etc are crooks - we would have only suspected it. By releasing this statement the GRA have admitted they are crooked.

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    Quote Originally Posted by Richas View Post
    1) the original poster was a bad un
    No one gave a crap about the
    OP
    , he's irrelevant. He could be the most dishonest man on Earth and it wouldn't change a damn thing. I can't believe that they spent that much time talking about him and what he did. Very unprofessional.

    This statement was as disappointing as I was expecting it to be.

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    Is Betfred going to stay on the accredited list even though they have been shown to have cheated players by offering an unfair game for several years and have refused to reimburse the affected players.

    If I were an affected player I would now be suing them.

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    First of all thanks
    CM
    for posting this statement as soon as you got it.

    Now what we see here is not a cover up but simply lack of understanding of what constitutes as an 'adaptive game'. We have misinterpretation of real life symbols here - namely cards. This has been brought up before, it's all written down in GCAs rules.

    Just one quote
    :
    Quote Originally Posted by Gibraltar Gambling Commissioner View Post

    The original HiLo game used an
    RTP
    /maths methodology known as ‘Fixed Price’ but with different
    RTP
    and RNG’s for PFF (100%) and PFR(96%); in very simple terms, the PFR game logic amounted to each customer choice producing an RNG number between 1 and 10,000, with numbers below 4800 winning and numbers above, losing, creating 96%
    RTP
    entirely randomly and a house win of 4%; the PFF gave a 50:50 chance. The RNG’s themselves were different for PFF (Flash) and PFR (Server integrated) as the games did not need to be identical.

    So instead of having different cards in a high low game, we have an arbitrary number. For a 52 deck shoe each card should have approx. 192 numbers assigned of out 10.000 (or simply 100 out of 5200). Instead the system first determines if we lose or win and then if we lose it will give as a loosing card even if we have an ace and decided to go for a lower card. How is that not 'adaptive'? This is essentially the definition of a perfect adaptive game. This is very sad and

    It seems that anyone can create a rigged 90% RPT roulette and GCA will happily accept that as long as casino can prove that you had a 45% chance of win. I feel speechless, powerless etc.

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    That is the most unprofessional thing I have ever read.

    It does not read as an objective, unbiased analysis, to put it mildly.

    In fact, that statement is the most disturbing part of this whole seedy affair,
    imo
    .

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    the words carpet, brush,and under spring to mind

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    As others have mentioned, the most important problem wasn't even addressed: We're dealing with a card game that does not behave like a card game. This is even in contravention of the GRA's standards.

    I guess we already knew it, but this again shows that gaming regulators don't really care about "fair play".

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