CASSAVA CASINOS AWARDED eCOGRA SEALS

caruso

Banned User - repetitive violations of 1.6 - troll
Joined
Jan 16, 2002
Location
England
Clayman said:
Why didn't you feel this way the day after True Gambler released his results?

Because I know them a bit, and trust their integrity impliciltly since they have no alternative agenda or otherwise malicious motivation. Of course, my attitude was unprofessional and I wouldn't repeat it. 20/20 hindsight and all that. I don't trust PWC one iota, and in light of the various incidents of auditor malpractice, that's a pretty fair stance.

To say it's a leap of faith to play blackjack in Nevada and therefore online play should not be subject to different requirements is really going it some. In this country, a deck must be fanned out for public inspection prior to play. I'm pretty sure it's the same over there. That a card may be "dropped" unnoticed, or that the deck is fixed between inspection and placing in the shoe is really not credible. But cheating online happens TODAY - it's been proved several times. To say that the two situations are comparable is not justifiable.

If the data and the collection processes were publically available it would be a GARGANTUAN step towards 100% assuredly authentic reporting. There would be no "leap of faith" - much as there isn't playing Nevada blackjack - above comments notwithstanding. THEN the two situations would be comparable.

Jetset, you got that contact Email for them, or should I pick one at random from the site?
 

jetset

RIP Brian
Joined
Feb 22, 2001
Location
Earth
Use info@ecogra.org Caruso, although I think you are now fudging this issue in an attempt to find an easier way than actually mustering support for your views.

I do not think a communication without evidence of solid and significant support is going to cut it, as I said in my post above. That will call for some commitment and effort beyond drafting a letter or making message board posts. Well worth it, though imo.

I repeat:

However, I think you need a little more organisation of effort than simply making ad hoc nominations on a single message board if you are to have credibility.

There are hundreds of players (and I include all genuinely concerned and interested posters in that) on the leading message boards, and if you can organise yourselves so as to marshal a strong representation from this audience, an open dialogue with eCOGRA may be the most powerful and constructive thing you have done thus far....and have the best chance for success.

It may require Grandmaster, Eek, Cipher, DaveR, DirkD or one of Caruso's other supporters to work those boards from which Caruso is excluded but that should not present too great a problem.

IMO, this is not a promising way to kickstart an initiative that shows eCOGRA you speak for a significant number of people who share your views to the extent that they should consider an approach more in line with your thinking.

This could entail expense and a significant policy shift from their obvious present comfort level with the professional integrity and honesty of a major third party service provider, and the level of support for your suggestions would definitely be a consideration.

We all have busy lives, but many people in this industry make space for voluntary causes in which they strongly believe.

Your personal views and position are well established, but in the present impasse I am suggesting the more constructive course of you and your supporters taking the time and trouble to assess public opinion on eCOGRA and then act on it.

If this public opinion conforms to your views then taking the issue to a more productive level than hostile message board posts would be a valuable move forward.

I think I am going to let your comments on PwC vs Truegambler in terms of integrity and agenda, and the validity of a condemnation based on information on which we have no detail yet pass in the interests of focus here!
 

caruso

Banned User - repetitive violations of 1.6 - troll
Joined
Jan 16, 2002
Location
England
Fudging? I don't recall offering, or accepting, the role of General Secretary of the Squeeze Ecogra's Nuts committee which has been graciously, if, I might add, possibly a tad ironically:), bestowed upon me. I pursue things my own way. If others prefer other ways, may they go ahead; it won't be me, for the forseeable future.

Something like this would never have "majority" support, because the "majority" can't even find their way to a message board, let alone interest themselves in and absorb matters pertaining to regulation and the ifs and buts thereof. Those of like views represent an extreme minority. I challenge anyone to deny that it's a quality minority, however, compromising experienced, intelligent people - obviously rare amongst gamblers.

However, I WILL go ahead as I've suggested.
 

rowmare

Dormant account
Joined
Sep 25, 2003
Location
Vancouver Island
This going 'round and 'round, searching for and demanding absolute perfection reminds me of a quote by George F. Will:

The pursuit of perfection often impedes improvement. ;)
 

jetset

RIP Brian
Joined
Feb 22, 2001
Location
Earth
caruso said:
Fudging? I don't recall offering, or accepting, the role of General Secretary of the Squeeze Ecogra's Nuts committee which has been graciously, if, I might add, possibly a tad ironically:), bestowed upon me. I pursue things my own way. If others prefer other ways, may they go ahead; it won't be me, for the forseeable future.

Something like this would never have "majority" support, because the "majority" can't even find their way to a message board, let alone interest themselves in and absorb matters pertaining to regulation and the ifs and buts thereof. Those of like views represent an extreme minority. I challenge anyone to deny that it's a quality minority, however, compromising experienced, intelligent people - obviously rare amongst gamblers.

However, I WILL go ahead as I've suggested.

OK, so we've established that:

Caruso doesn't like eCOGRA because he's unhappy with the software verification. He can't say that it is right or wrong due to PwC's lack of transparency, but he does feel that the present eCOGRA Seal holders offer a fair game.

His way of expressing this personal opinion is to post on the message boards that accept him. He intends to do this every time the eCOGRA name appears, even where he has nothing new to add.

He isn't prepared to do anything more than that, although he did offer to draft a letter to eCOGRA.

He doesn't feel that regulation is necessary.

He thinks the OCA is conditionally the best way to test software.

He feels that any attempt to assess and muster public support for a persuasive and organised submission of his objections to eCOGRA is not an option because, "Something like this would never have "majority" support, because the "majority" can't even find their way to a message board, let alone interest themselves in and absorb matters pertaining to regulation and the ifs and buts thereof."

He names those whose supportive views he respects, "Those of like views represent an extreme minority. I challenge anyone to deny that it's a quality minority, however, compromising experienced, intelligent people - obviously rare amongst gamblers."

I guess that's the end of this exchange, then - very positive as usual, Caruso. Not.
 

caruso

Banned User - repetitive violations of 1.6 - troll
Joined
Jan 16, 2002
Location
England
There's an awful lot in there which is misleading and incorrect:

"Caruso doesn't like eCOGRA because he's unhappy with the software verification. He can't say that it is right or wrong due to PwC's lack of transparency."

That is an ABSOLUTE misrepresentation and you know it very well at this point. What I may judge "right" or "wrong" is irrelevant because the lack of transparancy ITSELF is what invalidates the excercise and prevents the judgement. It is NOT that the L.O.T causes a failure to form an opinion. The L.O.T invalidates it. It is neither "right" nor "wrong". It is invalid.

"...but he does feel that the present eCOGRA Seal holders offer a fair game."

Irrelevant. My data proves nothing.

"He doesn't feel that regulation is necessary."

You should have been a politician - you misquote, and out of context. Point me to ANY remark I have made to say that regulation is GENERALLY unnecessary. The comment you are referring to contains a HUGE caveat. Can you correct your error before I point it out?

"He thinks the OCA is conditionally the best way to test software."

That much is correct, although a more accurate representation would be to say that the only VALID regulation of this kind is that which is independent from any compromise, independently collected and open for inspection. The OCA data was collected without Microgaming's knowledge (the first year or so), from actual players, some of whom have identified themselves publically as I recall. That's why I favour the OCA model - but the principle, not necessarily that ACTUAL model.

Simply because you don't agree with me doesn't make my contribution "not positive". The concerns have been publically aired and Ecogra - via yourself - has been challenged. We know now also that PWC have refused to publicise any aspect of the process or the data. That some players will now probably view in a more realistic light the software verification claim, based on the facts and opinions expressed, is to me a very positive move forward. That some players will NOT buy the hype and remain correctly cautious and sceptical, is positive. Calling to task regulation and pseudo-regulation is positive. If it weren't for the message boards, to this day I'd still be inspecting RTG sites to discover who is Gold certified and who is Platinum certified Safebet (LOL, I used to do that), and I might EVEN be taking Mike Craig's OPA stamp to actually mean something. That I do so no longer is very positive - for me and my wallet; not for Safebet's nor Craig's.
 

jetset

RIP Brian
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Location
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All I see is backpedalling, Caruso at the idea that you might actually need to do something beyond making repetitive postings if you want to bring about positive change for the benefit of players.

"Misquoted and out of context" - the standard political defence. What did you say about regulation that contains this huge caveat?

"I'm personally happy as things are." That's how you started out. Personally you see no need for regulation.

But then we have the OCA commercial: "And of course, my own preference is for a player-orientated, independent of ANY compromise type organization such as the OCA project. THAT is pure regulation."

And I suspect the real reason for your attacks on eCOGRA, which is independently governed and independently tested on player transactions.

But you then equivocate with "I acknowledge SERIOUS teething problems and the huge credibility dent it (OCA) took over the MG figures," Not a big deal - all it did was trigger people like yourself to vociferously attack respectable companies like CON and Microgaming on flawed information.

Yet despite this and the other now well known funding and validation problems with OCA and the unlikelyhood of it being seriously accepted as things stand at present you still see it as "....but in terms of real "regulation", that is the way forward."

And you therefore try to pull down an existing organisation like eCOGRA that is better equipped, structured and funded to undertake a more comprehensive task.

But hold on, then you say, "At the same time, 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."

Can we finally assume that in your personal opinion regulation is unnecessary, but that there might be some validity in contrary opinions on that?

Then you start dancing around the lack of PwC transparency which in your personal opinion invalidates the entire eCOGRA initiative and the benefits it offers to players. Your latest statement is a model of hand-waving and does not change the fact that your opposition to eCOGRA is focused on the third party software verification and your opinion (and that of the supporters you name) on it's transparency. And indeed you are definitely not in a position to say whether the TGTR does what PwC claims for it or not.

Then again you are of the personal opinion that Microgaming casinos offer a fair game anyway....but that doesn't really suit your argument. It's irrelevant, because you now say that your data proves nothing. So we're running on personal opinion again.

Let's look at another of your statements: "The OCA data was collected without Microgaming's knowledge (the first year or so), from actual players, some of whom have identified themselves publically as I recall. That's why I favour the OCA model - but the principle, not necessarily that ACTUAL model."

OK - so now it's not the OCA you favour but something unspecific that's like it but not currently available or identified?

And with a monitored regulatory regime does it matter whether the software provider knows it is being monitored or not? The eCOGRA concept of regulation is to provide players with the protection of continuously and independently monitored software, and the fact of enforced monitoring is in itself an incentive for continued compliance. So we have the OCA (or something like it) player input, and we have the TGTR which analyses every single player transaction at eCOGRA casinos.

The rest of your post seems to me to be an attempt to dress up your continued negative attacks on eCOGRA as positive moves forward, which of course they are not. They are personal opinions repeatedly made in an attempt to discredit eCOGRA and focused on yours and your supporters' view on it's outsourced professional services.

Your continued use of the word "hype" to describe factual descriptions of eCOGRA attributes is another indication of your bias.

You are attempting to influence player opinion against eCOGRA by your posts and that is about as far as your personal commitment to redressing the faults you perceive to exist apparently goes.

IMO, you are not interested in seeing what level of support your opposition to eCOGRA has, or in mobilising it in order to establish a useful dialogue with that organisation or with PwC aimed at addressing your objections in a reasonable manner.

We are therefore left with these sort of polarised exchanges and the fruitless prospect of a reprise of your views whenever eCOGRA announces a move forward.
 

caruso

Banned User - repetitive violations of 1.6 - troll
Joined
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Location
England
Positive change for the benefit of players is open to interpretation - you will inevitably see either myself or anyone else you regard as pissing on your patch as negative. I repeat, if gamblers can be be kept informed of your organizations shortcomings in terms of their transparancy and accoutability, in my opinion this is very positive. You regard it as negatve. Let others judge. And by others I mean the players, not the affiliates or the industry spokesmen.

Regarding regulation and your clearly intentional misrepresentation on my stance (intentional because I know what a wily old bird you are - no way are you capable of such a gross misunderstanding) this is what I originally said: At the same time, 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. you quote this yourself further down. Translation: it doesnt concern me, as an informed player who knows the ropes, but it does others. If you cannot distinguish between my own need for regulation and that of the gambling public, generally further down the evolutionary chain and in need of nannying, I leave you to yourconfusion.

Regarding OCA / Ecogra-PWC: there is no choice here. The OCA data was found to be incorrect. THE PWC data has not been found to be anything, because to all intents and purposes it does not exist! Neither situation is of much use to anybody invalid or non-existent. However, the transparancy of the OCA type of model whether that particular operation or another based on the same principles is the basis for genuine regulation, because GIVEN validated data (and this would always be open to corroboration, as weve seen) then you have a situation which fulfils the necessary criteria: no financial compromise and transparancy in all aspects. Ecogra-PWC does not fulfil ANY criterion for acceptable regulation with regard to the software verification. Hence the preference. If this is still not clear to you, Ill try to explain again next time.

Again you repeat this irrelevant remark: And indeed you are definitely not in a position to say whether the TGTR does what PwC claims for it or not. Correct, I am not. Why? Because everything is cloaked in secrecy to the extent that, to all intents and purposes, it can reasonably be assumed that there is NO data and NO process. Is this in PWCs favour? Is the fact that opinions cannot be formed because there is nothing more tangible than quite possibly fictional statements and rubber stamps for us to look at a good thing? Ill be able to form an opinion when they give us some evidence. Since they will NEVER give us any evidence most likely because there IS no evidence I will not be able to judge the process. And you consider this in their favour? LOL, I put you in a majority of one on that one. Breaking News!!! Its official!!! Ecogra-PWC cannot be judged to be either good or bad, because the facts required for judgement to be formed are HIDDEN FROM PUBLIC VIEW! They will NOT TELL YOU ANYTHING! Long Live Ecogra-PWC, the gods of honest software regulation!!

Did I say LOL?

We are therefore left with these sort of polarised exchanges and the fruitless prospect of a reprise of your views whenever eCOGRA announces a move forward.

Fruitless? If I present just ONE gambler with the facts from a rational perspective, I serve a useful purpose.
 

jetset

RIP Brian
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Location
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QUOTE "Positive change for the benefit of players" is open to interpretation - you will inevitably see either myself or anyone else you regard as pissing on your patch as negative. I repeat, if gamblers can be be kept informed of your organization's shortcomings in terms of their transparancy and accoutability, in my opinion this is very positive. You regard it as "negatve". Let others judge. And by "others" I mean the players, not the affiliates or the industry spokesmen."UNQUOTE

Nope - not "my" organisation or "my patch" - eCOGRA is independently governed and professionally managed beyond my control, but unlike yourself I certainly believe in the need for real regulation with the better player protection that flows from it and that this initiative offers.

You say "let others judge" and again attempt to fragment opinions into players and those you seem to view as having no useful contribution to make such as "affiliates or industry insiders". This is regardless of the fact that many of these may additionally be players and/or have proved to have a sincere desire to see that players are respected. IMO that sort of blinkered, polarised approach is not going to assist anyone as we try and find a better way forward.

However - back to your "let others judge" observation, I believe that is all eCOGRA expects - that it will stand or fall on the performance delivered by its Seal bearers. That benefits players in my book because these are operations where player-sensitive regulations are enforced.

QUOTE Regarding regulation and your clearly intentional misrepresentation on my stance ("intentional" because I know what a wily old bird you are - no way are you capable of such a gross misunderstanding) - this is what I originally said: "At the same time, 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." - you quote this yourself further down. Translation: it doesn't concern me, as an informed player who knows the ropes, but it does others. If you cannot distinguish between my own need for regulation and that of the gambling public, generally further down the evolutionary chain and in need of nannying, I leave you to your."confusion".UNQUOTE

Again, I don't see that as a misrepresentation at all. I note that you have ommitted the following from your latest quote, and that is revealing - but you actually posted "I'm personally happy as things are." That's how you started out, followed by some equivocation. Personally you see no need for regulation.

No matter how you dance around it, you personally do not see the need for regulation and are happy with the status quo. That goes to your attitude in this debate. We were discussing your personal opinions. Please have the integrity to stay with your comments or withdraw them.

However, let us agree that you do accept that despite your personal lack of the need for protection, most other players may be at a different level or have a conflicting opinion. I have to say, I find your rather patronising "...gambling public, generally further down the evolutionary chain and in need of nannying," attitude surprising to say the least.

I believe the message boards and private emails to mediators show daily that there are way too many clip joints out there. Consequently there is a need for regulation, and to distinguish casinos that are making a practical and honest effort to deliver enforced professional and trouble free service to players. As opposed to those that engage in no pays and slow pays, unfair bonus treatment and the other evils that we see in the daily parade. eCOGRA regulations are framed in such practical way and are conscientiously applied, which does that.


QUOTE Regarding OCA / Ecogra-PWC: there is no choice here. The OCA data was found to be incorrect. THE PWC data has not been found to be anything, because to all intents and purposes it does not exist! Neither situation is of much use to anybody - invalid or non-existent. However, the transparancy of the OCA type of model - whether that particular operation or another based on the same principles - is the basis for genuine regulation, because GIVEN validated data (and this would always be open to corroboration, as we've seen) then you have a situation which fulfils the necessary criteria: no financial compromise and transparancy in all aspects. Ecogra-PWC does not fulfil ANY criterion for acceptable regulation with regard to the software verification. Hence the preference. If this is still not clear to you, I'll try to explain again next time.UNQUOTE

You're going around the bushes again with this OCA thing, without offering a viable alternative. If you are now saying that OCA is not regarded as a viable alternative, why keep inserting it into the debate?

You say "However, the transparancy of the OCA type of model - whether that particular operation or another based on the same principles - is the basis for genuine regulation, because GIVEN validated data..." but there is as far as I can see no validation or conclusions beyond the publication of the stats....and you are proposing "what-ifs" models and not systems that are available for use and in existance. There is no other de facto system being presented by you here.

I am open to correction, but I cannot recall Truegambler providing the inner workings of his proprietary OCA analytical process that you seem to be requiring from PwC, and you should ask him for his views on the expense of validation btw, which has not been done on the OCA as far as I am aware.

Are you suggesting that the monthly publication of massive amounts of statistical data by PwC a la OCA would constitute verification for you?

It seems to me that you would rather see no attempt at regulation at all than a fully structured one like eCOGRA where you have a problem with the disclosure of third party proprietary testing procedures, even though you personally feel that the softwares being deployed by eCOGRA casinos are fair.

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, and this may be a useful area to explore in the present stalemate.

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?

QUOTE Because everything is cloaked in secrecy to the extent that, to all intents and purposes, it can reasonably be assumed that there is NO data and NO process. Is this in PWC's favour? Is the fact that opinions cannot be formed because there is nothing more tangible than quite possibly fictional statements and rubber stamps for us to look at a good thing? I'll be able to "form an opinion" when they give us some evidence. Since they will NEVER give us any evidence - most likely because there IS no evidence - I will not be able to judge the process. UNQUOTE

I would suggest that 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.

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...and please spare me the usual Enron and corruption retorts.

QUOTE Fruitless? If I present just ONE gambler with the facts from a rational perspective, I serve a useful purpose.UNQUOTE

I think the operative word here is probably "rational" when it comes to a personal perspective, and I don't personally see a lot of that here, Caruso. What I do see is a strong personal antipathy carried to extreme lengths, which unfortunately is blinding you to the great potential of eCOGRA and the improvement it brings to the industry .
 

caruso

Banned User - repetitive violations of 1.6 - troll
Joined
Jan 16, 2002
Location
England
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.

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. It isn't important to me that you fake misunderstanding of this. My opinion is as I've stated, it's clearly expressed and any reasonable reader can see that for themselves. Those sitting in the Ecogra-PWC pocket I do not qualify as "reasonable", so you can carry on inventing misinterpretations as you like.

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.

"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.

"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.

"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.

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. I don't want to repeat it all now, but I'll include it in the letter I hope to get around to writing soon to your folk on this matter.

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.

Anyway, that's all I have to say on this matter for the time being.
 

jetset

RIP Brian
Joined
Feb 22, 2001
Location
Earth
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.
 
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