I was in touch with Bet365 again, and I believe the matter is settled. Their response was that the frequency of the cards dealt is weighted (as observed). For example, according to the math I was given, winning with three 9's occurs about 5 times as often as winning with 3 aces.
They indicated to me that the game has been moved to their arcade game section. I think it was unreasonable that the game was ever listed as a card game, but I have no complaint about it being located in the arcade section.
While I see that the game now has a disclaimer
"The cards drawn are either 9, 10, J, Q, K & A. No deck is used, instead each card value has a different weighting so lower value cards are drawn more regularly than higher cards (i.e. The probability of drawing an ‘ace’ is not equal to drawing a ‘nine’). The higher the card value the higher the payout should you get ‘Three of a Kind’."
I do not find this response satisfactory.
They are not cards at all, this is just a slot, you cannot 'weight' cards unless you are a Mafia card cheat, maybe. It is impossible.
The game should be redesigned in order to make it immediately apparent that it is a slot.
The other games in the 'arcade' section do not behave in this way; 'Shut the Box', for example is a dice game where the RTP can be calculated by analysis of dice probabilities (1 in 6 for any given number is the basis), in 'Digit', each number of 1 to 9 has an equal probability and again you can calculate the RTP, for the various 'Top Trumps' games you can fairly trivially make a note of the cards in the deck and again derive an RTP (probably around 95%).
While Bet365 is regulated in Gibraltar, the Alderney regulations state for example:
'Games should not give the customer a false expectation of better odds by falsely representing any occurrence or event.'
and
'Where a game is represented or implied to be a simulation of a physical device, the behaviour of the simulation should be identical to the expected behaviour of the physical device.
a) The visual representation of the device should correspond to the features of the physical device.
b)
The probability of any event occurring should be as for the actual physical device E.g. the probability of obtaining a “six” on a simulated dice throw should be 1/6.
c) Where the game simulates multiple physical devices that would be expected to be independent of one another, each simulated device should be independent of the other simulated devices.
d) Where the game simulates physical devices that have no memory of previous events, the behaviour of the simulations should be independent of and not correlated with their previous behaviour so as to be non-adaptive and unpredictable in practice.'
The game is just another slot and should be sent back to the manufacturers until it is designed properly so that it doesn't mislead. The game violates fair gaming principles codified in the regulations of at least one jurisdiction and perhaps more.
In the mean time Bet365 need to REFUND all money lost on this game. It's clearly not fair, and a disclaimer in the help file doesn't make up for it.
Their response to the 'Killer Ace' complaint is equally slapdash and unsatisfactory.
There is no rollover game description in the game board, to explain that the 'Black', 'Red', and Suits bets don't pay out for an Ace.
The update they have effected to their help file is lazy and shows every sign of not being proofread or properly thought through.
Here it is (new text highlighted):
Killer Ace offers a large selection of betting options including:
Making multiple bets within one game.
Mixed chips on the same bet i.e. 1 + 10 = 11 units staked.
Placing chips in between two or four different numbers (on the single numbers section). This will split the bet over the numbers highlighted.
Select 'Odd/Even' to stake the turn of any even or odd card. Aces do not count in an Odd/Even bet.
To select the turn of any numbered card of a particular suit, place chips on the applicable symbol within the gaming area.
Choose Red/Black to anticipate the dealing of any red or black card. Aces do not count in a Red/Black bet.
Any single card number, irrespective of suit or colour.
Groups of numbers 2 through 7 or 8 through K.
As you can see the language is confusing, the help text is poorly structured and they've not even updated the right sections within the help.
The odd/even bet was never in dispute - the mouseover on the betting felt shows that Aces are not included, this is made obvious from the fact that there are 13 denominations, and that the Ace is the only one not paired with another denomination. The problem was with the Red/Black and Suit bets. However they have not updated the text of the suit bet, so it still appears that you should win if you bet on a suit and get an Ace.
'Aces do not count' is far from clear, either.
The help text is, and was, crap.
' Making multiple bets within one game. ' found directly under the heading 'Bet Types'
is not a bet type and it just confuses the simple task of explaining how the bets work.
I strongly believe, based on this evidence, that Bet365 do not have anyone working for them that understands the games they are offering.
How hard would it have been to post something like this:
Game Rules:
In the game Killer Ace, you place bets on the next card to be drawn from a deck of cards.
In Killer Ace, Aces are 'killer', which means that only bets placed on the 'Ace' denomination win - all other bets lose.
(The above tells you all you really need to know, but here follows more text)
Specific bets:
Suit: Pays 4* your bet, if the next card is of the suit you bet on. If the next card is an Ace, this bet loses, regardless of its suit.
Even: Pays 2* your bet, if the next card is a 2, 4, 6, 8, 10 or Q.
Odd: Pays 2* your bet, if the next card is a 3, 5, 7, 9, J or K.
2-7: Pays 2* your bet if the next card is a 2, 3, 4, 5, 6 or 7.
8-K: Pays 2* your bet if the next card is a 8, 9, 10, J, Q or K.
Red: Pays 2 * your bet if the next card is Red. If the next card is an Ace, regardless of colour, the bet loses.
Black: Pays 2 * your bet if the next card is Red. If the next card is a Ace, regardless of colour, the bet loses.
Denomation: Pays 12.6 * your bet if the next card is of the chosen denomination.
A/2/8: Pays 4.2 * your bet if the next card is an Ace, 2 or 8.
Two denomination bet: Pays 6.3 * your bet if the next card is of either of the two neighbouring denomations you bet on.
Four denomination bet: Pays 3.15 * your bet if the next card is one of the four neighbouring denomations you bet on.
It defies belief that they are accused of cheating, they take the games offline and they respond with such a half-assed and inadequate updating of a couple of helpfiles. The Killer Ace game is still not clear enough either on the game board or in the help file. Does their vendor not supply them with proper helpfiles? Or do they just like to 'roll their own'? (if so, they need to employ someone who is capable of writing lucid explanations
Why have I not been refunded for the bet I placed on 'Black', which lost when I drew a black Ace?
I have no doubt at all that all bets on Suits, Red or Black, should be refunded where the player lost because of an Ace. Why have they not acted to identify the players affected and to issue them with refunds? I can see no excuse for not having done so.
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. Just like a private eye working for a divorce lawyer `And here`s photos of your partner on holiday accidentally sleeping with every Spanish waiter on the island (no mean feat as she was actually in Greece at the time)`, great job OP 
