QUOTE: Your association with Ecogra-PWC evidently goes some way beyond "I certainly believe in the need for real regulation"; you're their front-man, their spokesman, their reporter, their tireless apologist. You're clearly DEEPLY involved with these folk. UNQUOTE
"Apologist"? I think not, for eCOGRA has nothing but positive, concrete and genuine developments to offer the industry. Which is considerably more than you are presenting at present, I have to say. Support and engagement with eCOGRA certainly does not preclude the expression of my personal belief in the need for genuine regulation and the right to challenge your repetitive and extreme views and suggestions of corporate impropriety. Nor does it make my personal beliefs and opinions any less valid or detract from their credibility.
QUOTE For the last time, these are my expressed opinions (here) on regulation: "I'm personally happy as things are" and "I have no problem with player-friendly regulation as a necessary move forward in this industry, as you asked. It doesn't much concern ME, but players come in all shapes and sizes and there have to be benefits." A blind man in a fog can ascertain from this that I am happy as things are for myself, but I appreciate that the need is there for others. Those sitting in the Ecogra-PWC pocket I do not qualify as "reasonable", so you can carry on inventing misinterpretations as you like. UNQUOTE
I am glad to see you have moderated your original view and accept there is a need for regulation by others less experienced and knowledgable than yourself. Now we're arguing what you personally regard as acceptable regulation, given that you personally have no need for it! I'll ignore the offensive nature of the last sentence, as your customary discourtesy really doesn't further the exchange.
QUOTE I have also clearly expressed what I regard as valid regulation, transparent in all matters and uncompromised (the "uncompromised" aspect is not so relevant given total transparancy, as I see it) - none of which can be claimed by Ecogra-PWC. The OCA model, which fulfilled the criteria of no compromise and transparent data (although more details on the collection process would have been needed, as was stated at the time, and no doubt those requisite details would have been published if it had been necessary, ie. if the data had not been found to be error-ridden, thus invalidating the exercise) satisfies the criteria. I have no projects of my own and no influence with the OCA, and neither is it my job to offer alternatives. That I do not have my own software regulator to offer in place of PWC does not in any way invalidate the fact that the PWC model is meaningless - it has no relevance to the matter. UNQUOTE
Clearly expressed? IMO this is another model of equivocation. Other than your constant but non-specific cavilling regarding PwC opening up their proprietary software, what is there about eCOGRA that lacks transparency to justify your statement "- none of which can be claimed by Ecogra-PWC."?
And we're back to your favourite but failed hobby-horse, the OCA again. Can you see the bias in this statement ? "The OCA model, which fulfilled the criteria of no compromise and transparent data (although more details on the collection process would have been needed, as was stated at the time, and no doubt those requisite details would have been published if it had been necessary, ie. if the data had not been found to be error-ridden, thus invalidating the exercise) satisfies the criteria." The presentation was indeed notable for its errors and the fact remains that this information was not made available - that was one of the reasons you were opposed on it. IMO your concept of OCA verification is remarkably more lenient than the demands expressed on your attacks on eCOGRA.
QUOTE "Are you suggesting that the monthly publication of massive amounts of statistical data by PwC a la OCA would constitute verification for you?"
It would certainly be a large part of it.UNQUOTE
What else would you see as being "a part of it"? Let's look at the practicalities of this, bearing in mind that your demand is for independent verification that the third party PwC TGTR system is fair and accurate. We are talking about something an order of magnitude or more in excess of the OCA effort here - very large volumes of monthly statistical data. Every single transaction in every one of the 43 and growing Seal casinos. How would you suggest this material be handled, by whom and what sort of auditing and analytical processes would be appropriate to establishing the cross check correlation between players experiences and the data, and the ongoing validity of the processes developed by PwC?
These were all hurdles that were presumably faced by the PwC specialists who designed this proprietary system.
Or would you be satisfied with a single examination that established in the opinion of an appropriate expert the veracity of the PwC process?
QUOTE "I haven't yet seen any objections from you to the claims made by some major casinos and licensing jurisdictions that specified softwares are tested by traditional testing laboratories"
LOL, I know nothing about that. It remains equally meaningless, for the same reasons.UNQUOTE
It is somewhat amusing in a strange sort of way, is it not? I think this is part of your problem, Caruso - you "know nothing about" issues such as this but that does not stop you proclaiming upon them, or casting doubts and aspersions on sincere moves to improve the business.
I asked legitimate questions with the aim of moving this conversation beyond stalemate. I asked you, "Assuming that the testing laboratory concerned has a respectable reputation, what amount of disclosure on the testing techniques and software used would you regard as acceptable, and what level of independent technical/professional capability would you deem necessary to make the judgement that the tests were competent and relevant?
Who would you suggest makes such an evaluation? Would this constitute sufficient validation in your opinion?"
Do I assume from your offhand response that you do not have an opinion on the role of traditional testing laboratories, other than the dismissive "It remains equally meaningless for the same reasons"? It seems to me that we are running out of testing options here. Could initiatives such as Alderney be going the wrong way on the subject of software verification in your opinion?
QUOTE "It seems to me that you would rather see no attempt at regulation at all than a fully structured one like eCOGRA ."
Nothing at all rather than bogus offerings. Ecogra is "bogus" in the software aspect only, so they are certainly better than nothing, and they offer a handy, if unlikely to be over-used, dispute service.UNQUOTE
Well, you've yet to prove your personal assertion that eCOGRA is "bogus" in any aspect in my opinion. But again you indulge in some qualification in expressing a more moderate view on the initiative, and that is welcomed, although I suspect it is a reluctant case of damning with faint praise. "Better than nothing" indeed! There is nothing available that is comparable.
QUOTE Regarding all your questions about the actual details beyond the simple fact of "transpancy", I've already made comments here or at WOL about that. UNQUOTE
I repeat - I suggest that from the outset you clearly have made assumptions and formed an opinion that insists that PwC and everything associated with it in this debate is up to no good.
You suggested some pretty nasty and unjustified corporate practices by PwC and eCOGRA, such as "No data and no process" Do you seriously believe that a member of the Big 8 international financial services companies would be a malice aforethought party to this? That they would run the legal and reputation risk of "rubber stamping" and making "fictional statements" on results from their third party clientele?
Or is there the possibility that they will not open up their independent system to the sort of inspection you appear to be demanding because it is developed in-house at considerable expense and effort by appropriate professionals and has a commercial proprietary value as a consquence?. I realise that you and you supporters will not accept that possibility, but imo it is far more likely than the ridiculous allegations you are making here about PwC's and for that matter eCOGRA's integrity.
I'm not surprised you prefer to set that rather extreme language to one side for when you write this letter of yours, which I presume you still intend to send with no evidence of significant support.
QUOTE In a nutshell, I wish everybody would drop any claim, or intention, or hope to regulate software. Regulate everything else, please. Get the likes of crooks like Cloud, Friedmann etc out of the picture once an for all by establishing a valid body that will never accept them, thus consigning them to the slag heap. Just ditch these bogus software attempts. They're (sorry, have to say it again) meaningless and they just get in the way. As somebody said, you believe it or you don't. If you believe the game is fair, play it. If you don't, either stay away or be a sucker and play a rigged game. But these things are best left I think to the players to decide for themselves, as providing authenticateable verification seems to me currently prohibitatively difficult. UNQUOTE
What a remarkable change from your earlier demands that the "tester's tests be tested" regarding software.
I don't personally agree with either your "bogus software" comments or your wish that "...everybody would drop any claim, or intention, or hope to regulate software." I think real software verification is important, and I believe PwC is providing it.
We can at least agree on the desirability of making this industry difficult for the crooks and shysters to flourish through solid regulation. We can also perhaps agree on the players deciding for themselves - especially on whether eCOGRA is making an impact or not on providing safer and more efficient gambling.
I don't think eCOGRA's Seal holders are going to toss their initiative for comprehensively fair and regulated gaming out the window as easily as you seem prepared to do, however. This move represents a serious commitment and my sense is that they will see it through to the benefit of the playing community and themselves.
Regulate everything else? That is what eCOGRA is doing despite your attacks. And that includes the conscientious software surveillance by it's independent tester PwC against whom you rail.
I think you need to step back and honestly reconsider some of the extreme statements you have made regarding this intitiative. There is much that is good about eCOGRA, and as I have said before the independent directors are reasonable people who will listen to constructive criticism courteously offered, and given credible support.
"Apologist"? I think not, for eCOGRA has nothing but positive, concrete and genuine developments to offer the industry. Which is considerably more than you are presenting at present, I have to say. Support and engagement with eCOGRA certainly does not preclude the expression of my personal belief in the need for genuine regulation and the right to challenge your repetitive and extreme views and suggestions of corporate impropriety. Nor does it make my personal beliefs and opinions any less valid or detract from their credibility.
QUOTE For the last time, these are my expressed opinions (here) on regulation: "I'm personally happy as things are" and "I have no problem with player-friendly regulation as a necessary move forward in this industry, as you asked. It doesn't much concern ME, but players come in all shapes and sizes and there have to be benefits." A blind man in a fog can ascertain from this that I am happy as things are for myself, but I appreciate that the need is there for others. Those sitting in the Ecogra-PWC pocket I do not qualify as "reasonable", so you can carry on inventing misinterpretations as you like. UNQUOTE
I am glad to see you have moderated your original view and accept there is a need for regulation by others less experienced and knowledgable than yourself. Now we're arguing what you personally regard as acceptable regulation, given that you personally have no need for it! I'll ignore the offensive nature of the last sentence, as your customary discourtesy really doesn't further the exchange.
QUOTE I have also clearly expressed what I regard as valid regulation, transparent in all matters and uncompromised (the "uncompromised" aspect is not so relevant given total transparancy, as I see it) - none of which can be claimed by Ecogra-PWC. The OCA model, which fulfilled the criteria of no compromise and transparent data (although more details on the collection process would have been needed, as was stated at the time, and no doubt those requisite details would have been published if it had been necessary, ie. if the data had not been found to be error-ridden, thus invalidating the exercise) satisfies the criteria. I have no projects of my own and no influence with the OCA, and neither is it my job to offer alternatives. That I do not have my own software regulator to offer in place of PWC does not in any way invalidate the fact that the PWC model is meaningless - it has no relevance to the matter. UNQUOTE
Clearly expressed? IMO this is another model of equivocation. Other than your constant but non-specific cavilling regarding PwC opening up their proprietary software, what is there about eCOGRA that lacks transparency to justify your statement "- none of which can be claimed by Ecogra-PWC."?
And we're back to your favourite but failed hobby-horse, the OCA again. Can you see the bias in this statement ? "The OCA model, which fulfilled the criteria of no compromise and transparent data (although more details on the collection process would have been needed, as was stated at the time, and no doubt those requisite details would have been published if it had been necessary, ie. if the data had not been found to be error-ridden, thus invalidating the exercise) satisfies the criteria." The presentation was indeed notable for its errors and the fact remains that this information was not made available - that was one of the reasons you were opposed on it. IMO your concept of OCA verification is remarkably more lenient than the demands expressed on your attacks on eCOGRA.
QUOTE "Are you suggesting that the monthly publication of massive amounts of statistical data by PwC a la OCA would constitute verification for you?"
It would certainly be a large part of it.UNQUOTE
What else would you see as being "a part of it"? Let's look at the practicalities of this, bearing in mind that your demand is for independent verification that the third party PwC TGTR system is fair and accurate. We are talking about something an order of magnitude or more in excess of the OCA effort here - very large volumes of monthly statistical data. Every single transaction in every one of the 43 and growing Seal casinos. How would you suggest this material be handled, by whom and what sort of auditing and analytical processes would be appropriate to establishing the cross check correlation between players experiences and the data, and the ongoing validity of the processes developed by PwC?
These were all hurdles that were presumably faced by the PwC specialists who designed this proprietary system.
Or would you be satisfied with a single examination that established in the opinion of an appropriate expert the veracity of the PwC process?
QUOTE "I haven't yet seen any objections from you to the claims made by some major casinos and licensing jurisdictions that specified softwares are tested by traditional testing laboratories"
LOL, I know nothing about that. It remains equally meaningless, for the same reasons.UNQUOTE
It is somewhat amusing in a strange sort of way, is it not? I think this is part of your problem, Caruso - you "know nothing about" issues such as this but that does not stop you proclaiming upon them, or casting doubts and aspersions on sincere moves to improve the business.
I asked legitimate questions with the aim of moving this conversation beyond stalemate. I asked you, "Assuming that the testing laboratory concerned has a respectable reputation, what amount of disclosure on the testing techniques and software used would you regard as acceptable, and what level of independent technical/professional capability would you deem necessary to make the judgement that the tests were competent and relevant?
Who would you suggest makes such an evaluation? Would this constitute sufficient validation in your opinion?"
Do I assume from your offhand response that you do not have an opinion on the role of traditional testing laboratories, other than the dismissive "It remains equally meaningless for the same reasons"? It seems to me that we are running out of testing options here. Could initiatives such as Alderney be going the wrong way on the subject of software verification in your opinion?
QUOTE "It seems to me that you would rather see no attempt at regulation at all than a fully structured one like eCOGRA ."
Nothing at all rather than bogus offerings. Ecogra is "bogus" in the software aspect only, so they are certainly better than nothing, and they offer a handy, if unlikely to be over-used, dispute service.UNQUOTE
Well, you've yet to prove your personal assertion that eCOGRA is "bogus" in any aspect in my opinion. But again you indulge in some qualification in expressing a more moderate view on the initiative, and that is welcomed, although I suspect it is a reluctant case of damning with faint praise. "Better than nothing" indeed! There is nothing available that is comparable.
QUOTE Regarding all your questions about the actual details beyond the simple fact of "transpancy", I've already made comments here or at WOL about that. UNQUOTE
I repeat - I suggest that from the outset you clearly have made assumptions and formed an opinion that insists that PwC and everything associated with it in this debate is up to no good.
You suggested some pretty nasty and unjustified corporate practices by PwC and eCOGRA, such as "No data and no process" Do you seriously believe that a member of the Big 8 international financial services companies would be a malice aforethought party to this? That they would run the legal and reputation risk of "rubber stamping" and making "fictional statements" on results from their third party clientele?
Or is there the possibility that they will not open up their independent system to the sort of inspection you appear to be demanding because it is developed in-house at considerable expense and effort by appropriate professionals and has a commercial proprietary value as a consquence?. I realise that you and you supporters will not accept that possibility, but imo it is far more likely than the ridiculous allegations you are making here about PwC's and for that matter eCOGRA's integrity.
I'm not surprised you prefer to set that rather extreme language to one side for when you write this letter of yours, which I presume you still intend to send with no evidence of significant support.
QUOTE In a nutshell, I wish everybody would drop any claim, or intention, or hope to regulate software. Regulate everything else, please. Get the likes of crooks like Cloud, Friedmann etc out of the picture once an for all by establishing a valid body that will never accept them, thus consigning them to the slag heap. Just ditch these bogus software attempts. They're (sorry, have to say it again) meaningless and they just get in the way. As somebody said, you believe it or you don't. If you believe the game is fair, play it. If you don't, either stay away or be a sucker and play a rigged game. But these things are best left I think to the players to decide for themselves, as providing authenticateable verification seems to me currently prohibitatively difficult. UNQUOTE
What a remarkable change from your earlier demands that the "tester's tests be tested" regarding software.
I don't personally agree with either your "bogus software" comments or your wish that "...everybody would drop any claim, or intention, or hope to regulate software." I think real software verification is important, and I believe PwC is providing it.
We can at least agree on the desirability of making this industry difficult for the crooks and shysters to flourish through solid regulation. We can also perhaps agree on the players deciding for themselves - especially on whether eCOGRA is making an impact or not on providing safer and more efficient gambling.
I don't think eCOGRA's Seal holders are going to toss their initiative for comprehensively fair and regulated gaming out the window as easily as you seem prepared to do, however. This move represents a serious commitment and my sense is that they will see it through to the benefit of the playing community and themselves.
Regulate everything else? That is what eCOGRA is doing despite your attacks. And that includes the conscientious software surveillance by it's independent tester PwC against whom you rail.
I think you need to step back and honestly reconsider some of the extreme statements you have made regarding this intitiative. There is much that is good about eCOGRA, and as I have said before the independent directors are reasonable people who will listen to constructive criticism courteously offered, and given credible support.
