Announcement from the GRA concerning Hilo and ReelDeal games

[Balthazar]

The customer loss/operator gain is not significant

You cannot look at a game 10 years after it has been introduced and after millions and millions of plays

Pick one, Mr. Brear.

 

[ThePOGG]

I guess as PB has made reference to it I can now state publicly that I did discuss the issue with him over email after his second statement (I was the petition starter) in an effort get this issue to reach some reasonable conclusion. As a gesture of good faith I volunteered not to make reference to any of that discussion in public. While PB never made any indication that he was looking to hold me to that, I did not wish to breach that assurance and as such have not discussed or published any of the contents of that conversation in public nor made reference to it.

I would make clear that my objective here was to reach a middle ground, so while I may not personally agree with the suggestions I was making, I was trying to find some action over and above those that have/have not been taken already on which we could all agree.

The first of the two suggestions I made was as follows; Even if we accept that these were in fact slots games, there's no way for the player to know that - add a fine print disclaimer to the game windows of any games that functions in this fashion to alert players to the fact that the cards do not behave like cards. Doing this in the game window - given that the vast majority of players do not read help files - gives all players a reasonable chance of knowing what the deal is.

The second suggestion was that whether the GRA/GGC agrees that players were mislead by the nature of the cards/the paytable/the advertised RTP, that players should be refunded if for no other reason than as a cheap way of minimising reputational damage to GRA licensees. Given that these are likely very low traffic games, I can't imagine they represent a huge proportion of overall revenue and as such it would seem small cost to pay to save name.

Unfortunately I believe I did more damage than good. While I started with the best of intention, towards the end of that conversation I allowed my own temper to colour the discourse, something that I'm justifiably ashamed of. Retrospectively I don't think it likely that we could have reached agreement on either of the above issues, however if I was trying to behave in a professional manner I failed completely. I should never have allowed that to happen and, far more worryingly, I believe that our conversation ultimately only served to reinforce PB's opinion of the motivations driving this discussion, an opinion that I don't feel is justified of many of the people reading. In at least one respect - that I've used this conversation as a vehicle to make a name for myself - I realistically can't offer defense. While I can honestly say I would rather than none of this happened - and every reader and group has the right to judge for themselves whether they feel I'm being honest in that respect - it has benefited my site in terms of both links and traffic and as such I can see the incentive that would cause my motivational integrity to be called into question (i.e. the right or wrong don't matter as long as this stays high profile).

As a barrier to conversation rather than an aide - rather than bringing parties together to a middle ground I've only served to polarise them further with thoughtless actions and comments both in public and private - I have since that point, and will continue from this point on, refrain from further commentary. What I would like to say before withdrawing entirely is a BIG thank you to CasinoMeister. I may have started the petition, Richas may have presented it in the best way, but the truth is that very few people noticed it buried in this thread until the big CM put his hand to it.

 

[Webzcas]

Unfortunately I believe I did more damage than good. While I started with the best of intention, towards the end of that conversation I allowed my own temper to colour the discourse, something that I'm justifiably ashamed of.

You have nothing to be ashamed of IMO. If anything the one who is acting unprofessional in this matter, is Phil Brear. I am still staggered that the Gambling Commissioner of Gibraltar has made the statements he has via Bryan in this thread. The latest installment posted yesterday is yet another prime example. Unbecoming of a professional body and the person who is the head of such an organisation.

If anything this has brought to light to the player community at least that Gibraltar is like pretty much every other offshore gambling jurisdiction.

 

[vinylweatherman]

A bot is not fraud or evil, it is merely breaching a term in a contract. A bot does not give the player an advantage as it cannot change the outcome of the game. As Katie 91 discovered, a bot just makes the casino win your money faster.

PB also justifies allowing the help file error pass because "nobody reads it". Well, the other thing that "nobody reads" is the small print in the pages and pages of terms and conditions that casinos often rely on to confiscate winnings. By the same argument, if something is only present buried in pages of smallprint, and not clearly shown to the player where they can't miss it, winnings should not be confiscated.

Worse still, PB agrees that casinos may confiscate winning even where no terms were broken by the player, but the casino feels that "the spirit of the bonus" was violated.

THIS is why players have lost confidence in the GRA and other small state regulators, they are far too ready to side with the casinos, which is the opposite of the view taken by most EU governments that the consumer is already at a disadvantage when dealing with "big business", and that where there is doubt, the consumer should always be given the benefit of such doubt. With this in mind, "spirit of the bonus" confiscations should not be allowed, and even violation of subtle or unclear terms in the smallprint, which "nobody reads" should not be held as binding as "no reasonable person" would expect players to have the legal training and determination of a lawyer when it comes to deciphering such legalese.

His reply then descends into a rant against the UKGC, which is perhaps the REAL reason for his attitude, his job and "empire" is at risk of crumbling beneath him in a couple of years as if the UK are going to insist on secondary licenses, it could spell the end of cheap offshore licenses in "tax havens" as a means to avoid paying the usual level of taxes suffered by B&M businesses. This would be particularly so if other EU countries followed the UK lead (as some appear to be doing already) towards a point of consumption regulation and taxation regime.

We are not stupid, we all know that it is the prospect of raising taxes, rather than protecting the player, that is encouraging governments to do this, but by being too ready to side with the casinos, these offshore regulators have given the UK government a winning argument that allows them to spin this as a player protection move, not a taxation one.

Whilst they took 6 months in the FOBT case, when it came, the punishment was more painful. This case too was about a wrong figure that "most players don't read" when they walk up to a FOBT.

PB also argues that a "reasonable person" would not assume that just because cards are used the game plays like a deck of cards. This would be so if that "reasonable person" was an industry insider, and had a working knowledge of game design. However, a PLAYER only has what is in front of him to go on, and given that we are assured by casinos that all the games are fair, a "reasonable person" would see cards, and instinctively assume that the game would behave like a deck of cards, no matter what it looked like on the screen. For those who doubted this, there was the help file, and that CONFIRMED that the game played like a deck of cards by listing the RTP as 100%.

The only fraudulent thing Katie91 did was to use false details and open multiple accounts. The use of a bot on it's own is NOT fraudulent, merely a breach of contract, a civil matter. A "bot developer" is a legitimate occupation, it is up to the purchaser of such bots to check which sites allow it, and which sites do not. Bot use is hard to prove BECAUSE it does not affect the outcome in any way, so casinos can only have "reasonable suspicion" that one has been used. If casinos hate bots, it is largely down to paranoia and a mistaken belief by at least some that a bot can somehow "crash the RNG" by playing too fast and give the player an advantage.

I think PB has shot himself in the foot, because if the UK government get to see this statement, they will be concerned at the second part, the rant about the UKGC and that the "poor little big business casinos" need protecting from players that actually try to WIN when they gamble.

It is WE that need protecting from the casinos who can hold our money to ransom in the event of any dispute, putting them at an initial and very significant advantage in any dispute resolution process.

 

[Richas]

We have also had the self-righteous comments from the self-appointed ‘legal/compliance experts’ on the future of regulation, and what other regulators would have done etc etc. The first thread made clear that the game existed on Gibraltar, Alderney and Malta operators’ sites, I understand it also existed on others. So, it has been passed by all the primary European online jurisdictions, as not adaptive, not in breach of ‘simulation’ requirements and being fair. Is there a message there? As for the UKGC’s comments, the full correspondence has never been disclosed, but by any measure of regulators’ behaviour they appear to have acted partially and with undue, ill-considered haste in this matter, quickly and incorrectly treading in other jurisdictions’ affairs, effectively endorsing the findings of a non-authorised, non-approved ‘testing person’ instead of raising their own queries; so they too are now aligned with the cheating side of this argument.

I seem to have missed some important UKGC comment. Anyone have a link?

 

[Richas]

It appears we are never going to agree on this issue, but let me have one last attempt, on your terms and through your method, to explain why we are so far apart on our views.

Well not without the GRA actually doing its job, agreement would seem unlikely without this. The reason we are upset is your failure to act to protect consumers.

As occurred in the first thread, most of the comments made in the second thread remain unfounded, inaccurate and are at times malicious/self-serving. It is clear that many people comment on our conclusions without even reading the thread, let alone what I have written, and now make personal attacks and agree with assertions made by other people who have also not read what has been written nor examined the regulatory position. Perhaps Bryan can throw some light on this practice by producing the stats which show how many people who have made comments have visited and read every page of BOTH threads? This practice of ‘conclude before you even check’ now extends to a ludicrous ‘petition’ which further distorts the circumstances of this event, despite the initiator having a personal dialogue with me, and leads to what, a loss of confidence in the remote gambling industry amongst the people who have been misled into signing it?

Well I have read the lot so your criticism is off the mark for me. Online discussion boards seem to be new to you. Some posters are informed, others not, that is the nature of the beast. Sadly the impression you give is that you are in the uninformed category.

‘Conclude before you even check’ also extends to quoting the GRA’s rules to the GRA. Well, not quite. If you take the trouble to visit our website and read our rules, you will see that the GRA is not the Gibraltar gambling regulator. The GRA has had nothing to do with us for nearly three years. So all those who tell us what our rules say appear to have not even looked at them, as they make explicit that the Gibraltar Gambling Commissioner is the Gibraltar regulator, and publishes the rules, known as RTOS (Remote Technical and Operating Standards), and how they are to be applied in such circumstances.

As someone who did quote the remote technical operating standards in these threads I wonder just how this (esp the bold bits) is unclear?

Old / Expired Link

7.1 Game fairness
(1) Licence holders should make information available to customers on their website(s)
about their testing and quality assurance arrangements in place to assure fairness
and randomness in their gaming products, including information about
testing/certification by an ATF where applicable and where this can be accessed.
(2) Licence holders should ensure appropriate systems and resources are deployed to
prevent or detect attempts to cheat by customers or other parties. Such measures
should be applied on a risk sensitive basis, with analytic programs (e.g. algorithms,
exception reports, cluster analysis) deployed to identify long term or systemic
cheating as well as short/medium term sporadic efforts.
(3) Games should be implemented and operate fairly and strictly in accordance with the
published rules and prevailing RTP where applicable.
(4) Games designed to give the customer only the perception that speed or skill
influences the outcome of a game (e.g. „steering‟ or „aiming‟) should make this
apparent in the game description.
(5) A licence holder should not implement game designs or features that may
reasonably be expected to mislead the customer about the likelihood of particular
results occurring. This includes, but is not limited to the following:
(a) Where a game simulates a physical device the theoretical probabilities and visual
representation of the device should correspond to the features and actions of the
physical device (e.g. roulette wheel).
(b) Where multiple physical devices are simulated the probabilities of each outcome
should be independent of the other simulated devices (e.g. dice games).
(c) Where the game simulates physical devices that have no memory of previous
events, the behaviour of the simulations should reflect the behaviour of the
physical devices (e.g. roulette wheel, cards, dice games).
(d) Games should not falsely display near-miss results, that is, the event may not
substitute one random losing outcome with a different losing outcome......
.....
‘Play for Free’ Games
(1) Play for free games for no prize are not gambling but should accurately reflect any
„real-money‟ version of the game, and should not be used to encourage those under
18 to use licensed gambling facilities.
(2) In particular, such games should not be designed to mislead the player about the
chances for success by, for example, using mappings that produce different
outcomes than the cash game. Licence holders should be able to demonstrate this
equivalence to the Gambling Commissioner upon request.

Hmm fairly clear. Are you now saying these are not your rules or is it just that you will not enforce them by imposing sanctions on sites or ordering compensation?

Can I take you seriously if you don’t read your own threads, don’t read what I have written, don’t know who we are, or read what our rules are, but you agree with the supercilious, aggrandised egomaniacs who splash their opinions on the thread as if they had access to the relevant data, coupled with infallible judgement and had done their own homework?

If you parked the hostile attitude to consumers you might have a chance of convincing us that you do protect us.

So what do our rules say? They do say games should not be ‘adaptive’ ie , “the probability of any particular outcome occurring should be the same every time the game is played, except as provided for in the (fair) rules of the game.” So the games were not adaptive as we or any other regulator defines that term. As the outcome of every call was entirely random, albeit weighted against the player, the game is not adaptive. Note that the game was approved for use in all the European jurisdictions which licence online slot play.

Ok it was not adaptive. I can believe that. You don't demonstrate it in a way that is reassuring but it was not adaptive....just deceptive.

Then we have the assertions about the game representing a device. Well, where is that rule? Indeed, where is that card game that uses 12 of 13 cards in this way and with these bets? The claim that it breaks an imaginary US or European rule is a complete nonsense. Read RTOS, you will not find the so-called rule you are told the game breaches; not in our rules or any other remote gambling rules (I am familiar with most of them). You might think such a rule exists, and it does for certain specified circumstances, but not for these circumstances. Read our RTOS section 7.1(5). What you will see is: “A licence holder should not implement game designs or features that may reasonably be expected to mislead the customer about the likelihood of particular results occurring. This includes, but is not limited to the following:………”

Please see your own RTOS rules quoted above. Are you now telling us these rules do not apply to Gibraltar regulated sites? If not why the ... are they published? Oh what the hell, here is a repeat of the relevant bit, you know with the bit you forgot to quote...

(5) A licence holder should not implement game designs or features that may
reasonably be expected to mislead the customer about the likelihood of particular
results occurring. This includes, but is not limited to the following:
(a) Where a game simulates a physical device the theoretical probabilities and visual
representation of the device should correspond to the features and actions of the
physical device (e.g. roulette wheel).
(b) Where multiple physical devices are simulated the probabilities of each outcome
should be independent of the other simulated devices (e.g. dice games).
(c) Where the game simulates physical devices that have no memory of previous
events, the behaviour of the simulations should reflect the behaviour of the
physical devices (e.g. roulette wheel, cards, dice games).

Is that a clear indication of your rules being broken? If not what on earth would be? You choose to give us a quote with .....rather than the meat of the rule that was clearly broken!

It is my office which has to decide if what occurred amounted to an operator breaching that rule. The answer is no, because the evidence, precedent, and a common sense interpretation say no. The examples which we go on to use refer to ‘simulates physical devices’. HiLo/Reel Deal does not simulate a physical device, it is a bespoke slot game. Even if this rule did apply, which it does not, we still have to apply a ‘reasonableness test’ in terms of how or why the rule was breached. You cannot look at a game 10 years after it has been introduced and after millions and millions of plays without any challenge, which has been accepted in numerous jurisdictions, and then say – that game is misleading everyone, because it obviously isn’t. What happened was the introduction of a paytable error, not the creation of an unfair game. We have taken sufficient and proportionate action with regard to that error, consistent with the likely actions of any other regulator presented with a similar error.

Of course it was misleading everyone. In part this was the use of cards but in the main it was saying it was a 100% RTP game, having a 100% RTP free money version and really paying 96% once you play for cash- it is hard to see how more deceptive it could be!!!!!

This conclusion also impacts on the calls for reimbursement. Reimburse who, back to when, what for? Are you seriously saying the operator should reimburse people who happily played the game, winning and losing, but who eventually lost, who got exactly what they came looking for, because there was an (unseen) error in the Help File? Are you saying the operator should discard his T&C’s that make provision for such unintended minor errors? Maybe there are other T&C’s that should be discarded when it suits the customer, like using your true identities and not using bots, leaving the operator with no protection whatsoever from the scammers out there and the occasional bugs which may work for or against the house, or, as in this case, make no difference whatsoever to the official and tested/approved RTP. If there are any genuine cases out there, let them come forward, I am sure they will get a sympathetic hearing. We have not published the numbers or the dates involved because we know that would be, pretty stupid, but your logic runs something like – “Your game had a minor and irrelevant error I didn’t know about, ignore that and what it says in the T&C’s I have agreed to, give me my money back.” It is a hard but undeniable truth, that the only evidence of anyone being misled by the paytable error is katie91.

Yes - every player who played on a game advertised as 100% RTP in the help file but really paying 96% should be recompensed. if they can't be contacted because the deception has lasted nearly a decade the gross yield unrefunded should go to problem gambling research/help. The site(s) should not profit from a game that deceived.

I have been heavily criticised in the second thread for addressing katie91’s behaviour. Esteemed commentators suggest ‘her’ behaviour is not relevant (and that the error was deliberate). Read katie91’s opening statement. ‘She’ is the one who treats you with contempt, sets out to mislead you, who abuses your trust and lies to you, about who she is, what she has done, why she has done it, who with, what she expects, how you can help her, and more besides. For page after page, until we intervene, her lies that the game was ‘rigged’ are the basis of what we now say was a disproportionate and unfounded attack on the integrity of the games and the games provider, amplified by people who should have known better.

You have mistaken our total indifference to Katie91 with a criticism. "She" was a bad un. Yep. Got that. Even so, if a burglar finds a fallen pensioner with a broken hip and calls an ambulance I am disinclined to worry that the burglar should not have been there in the first place. If a burglar finds a terrorist bomb factory and reports it my concern is the people with the explosives not the person trying to nick their TV. The evidence of the crime is still real even if it was reported by a bad un.

According to her CM log she has made 14 postings, so who is treating who with disdain here, after two weeks and over 200 entries on ‘she’ was still posting and leading you all on as to what had occurred, as well as lying in emails to the operator. You say this is not relevant?
The game was not ‘rigged’, ‘gaffed’ or any other acronym for ‘fixed’, nor was it even ‘advertised’ as having 100% RTP as she and many of you have claimed. It was not ‘advertised’ at all beyond the link in the contents page. By who’s stretch of who’s imagination is a paytable in the Help File an advertisement? No advertising authority or gambling regulatory authority defines advertising to include the esoteric contents of a Help File, which we all know virtually no-one ever reads. Advertising is ‘in your face’, like the very small number of 100% RTP PFR games which are ‘advertised’ and promoted as such by very few operators, and which require perfect strategy to stay even and do not include slot games so far as I recall. An error in a Help File is an error in a Help File, it is not ‘an advertisement’.

You don't like advertised as a term? Mis-described? Misrepresented? Falsely represented, told a great big porky pie about? Your own rules make it clear that games should be properly described - the sites failed this obligation.

3.4 Game rules and information
(3) For each game, the licence holder‟s game rules and information should be readily
accessible and identifiable in a clear and intelligible manner by way of a conspicuous
link to the game rules on the home pages for gaming products, game selection
screens/menus, and within individual games.
(4) The game rules should not be unfair or misleading.
(5) The availability of game rules and information should be checked regularly; if the
information is not available the game should not be made available for gambling.
(6) The published game rules and information should be sufficient to explain to
customers all of the applicable rules and how to participate. As applicable, game
information should include the following:
a) the name of the game;
b) the applicable rules, including clear descriptions of what constitutes a winning
outcome;
c) any restrictions on play or betting, such as any play duration limits, maximum win
values, bet limits, etc;
d) the number of decks or frequency of shuffles in a virtual card game;
e) whether there are contributions to jackpots (“progressives”) and the way in which
the jackpot operates, for example, whether the jackpot is won by achieving a
particular outcome;
f) instructions on how to interact with the game; and
g) any rules pertaining to metamorphosis of games, for example, the number and
type of tokens that need to be collected in order to qualify for a feature or bonus
round and the rules and behaviour of the bonus round where they differ from the
main game.
h) Information about the likelihood of winning:
i) a description of the way the game works and the way in which winners are
determined and prizes allocated;

Just how can you ignore the vital importance of misinforming players about their likelihood of winning?

A number of CM users put katie91 and her so called evidence on a pedestal, built their arguments around her claims without checking them out properly, wanting to believe what she had written, and now they find it impossible to admit they were had over by a con-man and got this whole episode wrong. Even Bryan seems to be in that category. This closed mind-set by people who should know better is very disappointing. It looks as if the ‘top rated’ casino commentary site cannot accept what well established rules say, and how they are applied by all regulators. Nor can it bring itself to say that what actually lit the fire was outrageous. If katie91 had started the thread with,

Forget about Katie, we have. I don't care if Katie ever got a refund or instead got done for fraud KATIE IS NOT THE ISSUE!

‘Hey I am a bot designer using false online identities and for the last 6 weeks I have been trying to cheat a game, but I have goofed and I now realise there is an error on the paytable, but by the time I worked this out my bot had turned over nearly £400k and lost me over £12k, will you help me get my money back by saying the company are cheats?’

Well I don't want you to care much for Katie, I don't - I do want you to care that a pay table was wrong for nearly a decade (and that in another linked case the RTP and/or optimal seems to have been changed without notification or recertification). Do you not get yet that katie is not the issue?

Would she have got the same reaction? Is this accurate description of events not a bit more relevant that the 14 entries ‘she’ made to con you all? We are where we are because ‘she’ lied to you, end to end, and because I have taken the trouble to correct that situation, whereas other weighed in behind her without asking obvious questions.

You have "corrected" nothing. That is the problem.

We have also had the self-righteous comments from the self-appointed ‘legal/compliance experts’ on the future of regulation, and what other regulators would have done etc etc. The first thread made clear that the game existed on Gibraltar, Alderney and Malta operators’ sites, I understand it also existed on others. So, it has been passed by all the primary European online jurisdictions, as not adaptive, not in breach of ‘simulation’ requirements and being fair. Is there a message there? As for the UKGC’s comments, the full correspondence has never been disclosed, but by any measure of regulators’ behaviour they appear to have acted partially and with undue, ill-considered haste in this matter, quickly and incorrectly treading in other jurisdictions’ affairs, effectively endorsing the findings of a non-authorised, non-approved ‘testing person’ instead of raising their own queries; so they too are now aligned with the cheating side of this argument.

Oh I am tired of this rot now. Katie was a little cheat, the site and software supplier made money from misrepresenting a game, they were the bigger cheats. Yes cheats - an error for so long that goes through certification and quarterly audits may start as an error but the affect is to cheat consumers.

Did no-one else find it a little strange that an organisation that took 6 months to deal with the FOBT case (and provided virtually no information about it) and has zero profile in matters such as these, takes only 3 days to weigh in on this one, providing some considerable but irrelevant detail, promoting its own cause, despite the game meeting published UK standards (except for the error). It was approved by one of their own approved testing houses, albeit not on behalf of a UK remote gaming licence holder. This was a pretty lamentable episode, and if anyone wants to explore the benefits of the proposed UK legislation, I suggest you research that issue properly before you make any further comments on how it will improve consumer protection.

It was fixed for players in half that time and an agreed deal whereby the licencee did not profit from the error was achieved. You took nearly a decade and only then when a cheater made a fuss was it revealed. it certainly looks like the UKGC did a better job. On what criteria do you think your performance on this issue beats their's? I don't really need much more research - I have two cases of a misrepresented RTP and the regulatory action (and speed) is markedly better with the UKGC. I am sure that a UK or EU judge would have no other option but to draw the same conclusion.

Finally, I understand we have been down-graded by CM as a jurisdiction. I am not sure who else is in the same category as we now are, but I suggest you take a reality check on this. If the criteria for grading include ‘do we always agree?’, then fine, because we won’t, but if it is ‘who provides the best and most secure products, and who deals with consumer complaints properly and thoroughly’, then no-one comes near to us, and you should know that.

Well in a few months time we all get dual protection via UKGC licences anyway, that is a threat o jobs in Gib including yours. I'm sad for the licencees in Gib but have less sympathy for you.

So, just as the dust is settling on the thread, here I am stirring it up again, because you were wrong in how you reacted to the OP, you were wrong in your analysis and you are wrong in your attitude to this matter. You should not support cheats, they are cheating honest operators and honest players; but bugs and errors do occur, and we deal with them. Stop splitting hairs and looking for ghosts in cupboards, and next time, look at little closer at what is being claimed, check the facts, and do your own homework, before doing mine.

Nobody supports cheats.Just get beyond Katie, it is not about Katie.

As for doing your homework, someone should. Looks like in future that person will be Jenny Williams (UKGC).

 

[mimi26]

well put Richas :notworthy, but I fear you may be better of talking to your back garden wall.

 

[vinylweatherman]

well put Richas :notworthy, but I fear you may be better of talking to your back garden wall.

I have a fence, but here goes.


Forget about playing cards, let's call it a number wheel showing 1,2,3,4,5,6,7,8,9,10,11,12

Let us also call the game "random".

What would a "reasonable person" assume?

Well, I for one would assume that in a random game each number, however mapped to the RNG, would have an equal probability of coming up as the next result, that being 1 in 12. There is no reason why the house edge could not be accommodated by the paytable. This would not be deceptive, as the paytable and the concept of each number having a 1 in 12 chance of coming up would allow the mathematical calculation of the RTP. If the helpfile was wrong, it would be mathematically obvious.

However, in this game, the mathematical model showed the RTP to be 100%, and that's what the helpfile said. There is no way to "bust" this if a deception other than to record and analyse a long sequence of results and run a statistical analysis on them. In the end, it took one "con artist" to bust another (which is how players are viewing this game, whatever the official view).

We expect Katie91 to get busted for fraud, but we ALSO expect the software designers of this game to also get busted.

 

[Jufo]

This may have been a niche game, but it shows that the GRA feel that it is acceptable to run "keno logic" behind every game, including those that could NEVER operate that way if they lived in the real world as physical devices. It doesn't seem to have been "adaptive", but it was certainly a weighted card deck, which in the real world would be achieved by removing cards or substituting duplicates, both of which would be highly illegal in a land based casino.

No, the game was adaptive. The result was based on what the player bet on. If he bet on red then a black card would be more likely to appear. If he bet on black then a red card would be more likely to appear. This is the very definiton of an adaptive game. It wasn't simply a weighted card deck but a rather card deck whose contents changed dynamically depending on where the player had bet on. Mr.Brear's statement that the game was not adaptive is false.

As for the losses being "insignificant", they are actually 0.04 x the total wagered over all those years of operation. Their argument that the only inconvenience was a reduction in the time it took to lose the deposit is the same as claiming that a cinema that advertised 100% of a film but only showed 96% of it should not compensate customers because they only lost an insignificant amount of the total entertainment time.

Mr.Brear's argument that the only effect to the player is a reduction in play time is false as well. The house edge affects play time but much more importantly it affects the odds for the player to win. As an example, suppose that a player deposits 100€ and makes 5€ bets on this game until he either loses his deposit or doubles his initial balance to 200€. With a fair game (100% return) the odds of the player to double his deposit are exactly 50/50. But how much will the odds of doubling his balance be reduced if he plays a 96% version of this game instead? The answer might be surprising: The player will double his balance only 16.7% of time or about once every 6 attempts. The difference is huge - you risk 100€ to win 100€ and only have a 1 in 6 shot to win rather than the 1 in 2 shot you believed to have.

With the above example I wanted to say that whether the RTP is 96% or 100% makes an absolutely huge difference for the player's chances to win. It also makes a huge difference to the casino's profits. Therefore Mr.Brear's statement that the error was minor or irrelevant cannot be further from the truth.

 

[Nifty29]

Jufo makes sense.

Sounds adaptive to me.

Anyone have an alternative explanation?

 

[ChopleyIOM]

I've kind of given up on this entire episode since the responses from PB have gone from the ludicrous to the farcical to the borderline insane.

We established OVER SIX MONTHS AGO that what we were dealing with here was an ADAPTIVE, CHEATING CARD GAME that fell foul of every single rule in the book, including the GRA's own rule book. (I mean, come on, Betfred actually told us that much right from the start!)

A card game that offers x2 pays on red or black, and yet actually weights 56/44 behind the scenes depending on what colour the player picks is the textbook definition of adaptive behaviour.

This entire saga now has descended into the realms of comedy status, the only thing I'm still slightly surprised by is that Bryan hasn't busted Gibraltar down to 'five miles down past junk' status as a jurisdiction.

 

[dunover]

Jufo makes sense.

Sounds adaptive to me.

Anyone have an alternative explanation?

No, on this particular software being a 'pick' game from a limited amount of possibilities the TRTP will be achieved over a very short period. This means by it's very nature it will in effect be compensated via being reactive to the stakes and choices the poor sod who plays it makes. So, yes, it pretty well can only be described as adaptive. Which would be fair enough if was ever described as such.

 

[questa]

This all beggars belief.

In particular, Player losses were insignificant.

Ok, how much were they?

What a scandal. Online gaming is a scam. If you trust these jokers with your cash, you are an idiot, plain and simple.

And Mr Brear, you should be ashamed. What an amateur.

 

[ChopleyIOM]

This all beggars belief.

In particular, Player losses were insignificant.

Ok, how much were they?

What a scandal. Online gaming is a scam. If you trust these jokers with your cash, you are an idiot, plain and simple.

And Mr Brear, you should be ashamed. What an amateur.

I don't think its fair to pick on an episode like this and conclude that online gaming is a scam. Admittedly the disaster-zone that the GRA have turned out to be doesn't taint the whole barrel, but it does, as already noted, give huge amounts of ammunition to governments who are determined to tax and regulate online gaming at the point of consumption.

PB appears to have aimed a gun at his own jurisdiction's head and pulled the trigger with extreme prejudice.

 

[Richas]

As PB has decided that he has made his "final" statement is there any prospect of a comment from BetFred, any other affected site and/or Finsoft?

I hope they can do a bit better.

 

[daywalker]

......

 

[GOCC]

As PB has decided that he has made his "final" statement is there any prospect of a comment from BetFred, any other affected site and/or Finsoft?

I hope they can do a bit better.

I doubt it. I asked the Betfred rep some pages ago if he would be honouring his comment that once the GRA had concluded, then Betfred would reimburse. Seems that now the GRA have said they dont have to, they are taking the financial high ground and not bothering. I hope i am wrong, but doubt it.

 

[mrmark21]

I doubt it. I asked the Betfred rep some pages ago if he would be honouring his comment that once the GRA had concluded, then Betfred would reimburse. Seems that now the GRA have said they dont have to, they are taking the financial high ground and not bothering. I hope i am wrong, but doubt it.

So they werent being honest when they made that comment?

 

[binshakindown]

Maybe I missed it,

but has anyone seen an update, posting, had verbal communication or otherwise heard from any of the casinos and/or associated software providers involved in this debacle?

Or should we expect them to use the same tactics that rogue casino operators and other unscrupulous types commonly employ? Keep a low profile, don't communicate anything, ignore the issue(s) and eventually everything will just blow over nicely. Is it possible that all affected parties (excluding players and affiliates) are prohibited from discussing this case further? Maybe they would get in trouble with the Gibraltar licensing folks and be asked to sit in the corner or made to go to their room for a few minutes or worse, be verbally scolded. You would think if the financial gains/losses were truly “insignificant” then the offending parties should have no problem with compensation, since the funds are insignificant.

Question: Could a casino lose its license if they decided to refund players even though PB’s three informal statements indicate they are not going to be required to do so? It would seem that if one casino did decide to compensate the players it scammed, then they would essentially be admitting they were guilty and therefore implicate the whole lot of them. I don’t see how they are not guilty, but realize that is much different from them admitting they are.

 

[manfreid88]

It's just me or...

It's just me or they keep not giving a s**t about players and their....errr... feelings and money?

 

[mrmark21]

I'd never place a bet at any of the casinos involved in this issue as their silence dosent really instill a sense of confidence. Betfred used the possibility of reimbursing players as damage control. Then renegged. I'm happy to be proven wrong.

Not even the GRA took responsibility. Can't say I'm surprised what does surprise me though is PB's obvious negative attitude towards players. He should learn not to bite the hand that feeds him.

 

[KasinoKing]

No, the game was adaptive. The result was based on what the player bet on. If he bet on red then a black card would be more likely to appear. If he bet on black then a red card would be more likely to appear. This is the very definition of an adaptive game. It wasn't simply a weighted card deck but a rather card deck whose contents changed dynamically depending on where the player had bet on. Mr.Brear's statement that the game was not adaptive is false.

Sorry, but I disagree with this; it's not "adaptive", just different (fixed) odds on each outcome of a single game round.

An Adaptive game is one which monitors how good (or bad) a player is doing and them makes an adjustment to the odds of further rounds to ensure the RTP meets the operator's wishes.

I will probably get even more stick for this, but I actually can't see very much wrong with My Brear's latest statement and I urge everyone to go back and read it again very slowly and carefully.
The only issue I have with this whole fiasco is how exactly the game was presented in the casinos. Having never even seen it for myself, let alone played it, I have no idea how it was categorised; If it was listed among other true card games, then the GRA is definitely in the wrong. But if it was clearly categorised as a "slot" or "arcade game", then they do have a point. In this case the rules and paytable are VERY important, but again I have not seen those for myself, so it's impossible for me to make a conclusive judgement.

KK

 

[Richas]

Sorry, but I disagree with this; it's not "adaptive", just different (fixed) odds on each outcome of a single game round.

An Adaptive game is one which monitors how good (or bad) a player is doing and them makes an adjustment to the odds of further rounds to ensure the RTP meets the operator's wishes.

I will probably get even more stick for this, but I actually can't see very much wrong with My Brear's latest statement and I urge everyone to go back and read it again very slowly and carefully.
The only issue I have with this whole fiasco is how exactly the game was presented in the casinos. Having never even seen it for myself, let alone played it, I have no idea how it was categorised; If it was listed among other true card games, then the GRA is definitely in the wrong. But if it was clearly categorised as a "slot" or "arcade game", then they do have a point. In this case the rules and paytable are VERY important, but again I have not seen those for myself, so it's impossible for me to make a conclusive judgement.

KK

I agree it is not adaptive as I understand it but it was deceptive. For NINE years the pay table was wrong and the play game paid at a different rate. It is a huge problem.

As for the last statement being OK, oh dear me no. I did it paragraph by paragraph but the totally unprofessional attack on the UKGC was new and not really highlighted by me. It was a terrible statement.

Phil Brears has taken unprofessional to a new level in regulatory terms not just with his partisan statements but his complete failure to deal with the way that players were deceived (cheated).

 

[maphesto]

@ Richas and KasinoKing:

If the outcome of the game (red or black) was based on which color the player chose, surely the game must be adaptive.

 

[Richas]

@ Richas and KasinoKing:

If the outcome of the game (red or black) was based on which color the player chose, surely the game must be adaptive.

Not as I term adaptive. Basically there is one table of odds, whatever you pick you get 96% RTP. adaptive is where the players outcomes are checked and the odds adjusted on their next bet. If you have a good run you get worse odds than 96%. Adaptive is a lot worse for game play than just having a fixed house edge.