eCOGRA interview at Winneronline

[jetset]

Interview on eCOGRA now up at Winneronline...


10 Minutes With...Andrew Beveridge from eCOGRA
by Max Drayman, WINNERonline.com
9 June, 2004



Max Drayman: Tell us a little about your background and your role within eCOGRA.

Andrew Beveridge: I assumed the role of CEO on a full-time basis in October 2002. I initially embarked on a career in investment banking in London and Hong Kong, having qualified as a Chartered Accountant and complimented this with an MBA.....

And the rest can be read here :

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[GrandMaster]

Of course, Gamblegirl immediately spotted the PwC-TGTR issue.

 

[jpm]

The testing methodologies adopted by the audit firms are left to the audit firm's discretion, and the Board does not dictate what tests should be adopted and the degree of testing. This kind of information is proprietary to the audit firms - it is at their discretion whether or not they wish to make this information public.

It seems to me that this says it is NOT eCOGRA who is keeping the methodology secret, its actually the accounting firms. Looks like all the eCOGRA bashing will have to shift to auditor bashing now for keeping things confidential.

 

[GrandMaster]

It seems to me that this says it is NOT eCOGRA who is keeping the methodology secret, its actually the accounting firms. Looks like all the eCOGRA bashing will have to shift to auditor bashing now for keeping things confidential.

Ecogra could have insisted on the methodology being public, and if PwC did not like this, some other firm could have done the job instead.

 

[jpm]

But that doesn't change the fact that eCOGRA is not the one keeping the information private. The decision was not made by them, so blame the auditors for the secrecy, not eCOGRA.

 

[caruso]

That's a quite nonsensical argument. The "fair gaming" seal is issued by Ecogra. It makes no difference who they pass this or that task over to, everything is done under their authorization and the responsibility is theirs. I offer a food product, some component of which may be damaging to the health. That particular component I therefore shovel off to someone else to manufacture so that when my customers say "please give us details of component X so that we can assess the danger level" I can come back with "oooh, very sorry, Company Y manufactures that, and they refuse to issue details, so you'll have to take their word for it. It's not my fault if you die."

Who is accountable? I am, of course. It's my product, my responsibility and the lawsuits will be faced by me. No customer would by that BS line of argument.

The information is private because it suits Ecogra that it be private. Nobody forced them to include a software "guarentee" in their "seal"; they chose to include it because it suited them, and they chose a auditor they knew would insist on keeping everything under wraps because THAT suited them - because, as we know, their is no software audit. All we have is PWC doing what they always did - rubber stamping figures handed over by Microgaming and gleefully banking the bucks.

Good questioning from Draymann, I thought he'd fudge it. Kudos to him for getting confirmation of what we knew anyway.

 

[jetset]

Living up to your promise to post the same old stuff every time the eCOGRA name comes up, I see Caruso.

And your resentment against Max Drayman resulting from your deliberate confrontation with him at WOL on an unrelated matter is in evidence here too. FTR imo he asked legitimate questions in a professional manner here, as any unbiased reader of the interview can see for him or herself.

Once again, you make stunningly irresponsible, inaccurate and assumptive statements like this:

"The information is private because it suits Ecogra that it be private. Nobody forced them to include a software "guarentee" in their "seal"; they chose to include it because it suited them, and they chose a auditor they knew would insist on keeping everything under wraps because THAT suited them - because, as we know, their is no software audit. All we have is PWC doing what they always did - rubber stamping figures handed over by Microgaming and gleefully banking the bucks."

What factual evidence can you produce that justifies such a statement? You are back to unfounded allegations like "...there is no process, there is no data" with the comcomitant implication that both eCOGRA and PwC (and presumably Microgaming and CON too judging by the above statement) are maliciously fraudulent, and that is simply neither fair or true.

And your analogy is out of context.

Regardless of whether you, personally feel that the interview covers "...what we knew anyway" it is informative and useful for those who have not followed eCOGRA's progress in player protective regulation as closely as yourself. Or dismissed it from the outset.

Read the interview again, and you will see that eCOGRA and its not inconsequential members does not share your personal problem with confidence in PwC's ability to produce what it claims for its proved testing process as a responsible, professional and expert organisation.

They clearly do not agree with your view that a third party tester's refusal to open up its proprietary testing system invalidates the eCOGRA initiative in its entirety.

But you know all that already, and it has been debated extensively elsewhere on Casinomeister. Once again you offer nothing here that is useful.

 

[caruso]

"Living up to your promise to post the same old stuff every time the eCOGRA name comes up, I see Caruso."

Yes, posting the same facts about this fit-up "verification" job. While they remain valid, will continue to do same.

"FTR imo he asked legitimate questions in a professional manner here, as any unbiased reader of the interview can see for him or herself."

Do you actually read anything I write, or do you just see I responded, post and hope for the best? I said "Good questioning from Draymann". Necessary translation for Jetset: "I thought it was conducted well."

(Me) The information is private because it suits Ecogra that it be private...All we have is PWC doing what they always did - rubber stamping figures handed over by Microgaming and gleefully banking the bucks.

"What factual evidence can you produce that justifies such a statement?"

Duuh, the fact that it's all done in private?

"Read the interview again, and you will see that eCOGRA and its not inconsequential members does not share your personal problem with confidence in PwC's ability to produce what it claims for its proved testing process as a responsible, professional and expert organisation."

Oh well, that's that sorted. The corrupt endorsing the corrupt. Must be true then. LOL.

"And your analogy is out of context."

LOL. Jet, an analogy is always out of context. That's why it's an analogy - it seeks to clarify / explain a situation by way of a different one. Look up "analogy" in a dictionary sometime.

Necessary summary for Jetset: Good questioning by Draymann - I didn't expect him to raise the player concern matters. Expected responses from Ecogra, but the confirmation that all "validation" matters are to be kept strictly under wraps for reasons of the total lack of any actual EXISTENCE of said matters was useful.

 

[jpm]

That's a quite nonsensical argument. The "fair gaming" seal is issued by Ecogra. It makes no difference who they pass this or that task over to, everything is done under their authorization and the responsibility is theirs. I offer a food product, some component of which may be damaging to the health. That particular component I therefore shovel off to someone else to manufacture so that when my customers say "please give us details of component X so that we can assess the danger level" I can come back with "oooh, very sorry, Company Y manufactures that, and they refuse to issue details, so you'll have to take their word for it. It's not my fault if you die."

This is not a good analogy since there are government regulators who require such things to be disclosed by federal (or similar outside the US) regulations when it involves food or drugs, etc. and we are dealing with an unregulated industry. A better analogy would be something like H&R Block saying they certify your returns will pass an audit, and they will cover the costs if the returns they prepared and certified are audited. But they don't know the method the IRS will use to decide if they are going to audit your returns, since the IRS won't disclose them all.

 

[caruso]

That's one heck of a nit-pick, JPM. OK, for the sake of argument let's assume a similar level of unregulation. Analogies aren't generally governed by US regulations - the purpose is to make a point with the aid of an analogious situation, not be accurate on all matters of law.

I offer a food product ***Ecogra***, some component of which may be damaging to the health***software validation, which, assuming false, is obviously potentially damaging to the financial health***. That particular component I therefore shovel off to someone else to manufacture ***PWC***so that when my customers say "please give us details of component X ***software validation***so that we can assess the danger level" I can come back with "oooh, very sorry, Company Y ***PWC***manufactures that, and they refuse to issue details, so you'll have to take their word for it. It's not my fault if you die***get cheated***."

Hope that's clarified. But I think you're nit-picking for the sake of it - the point is clear enough: the product is mine and I alone am responsible for all the component parts. To suggest that I am NOT responsible for the misfunction of one part in particular because I was not privvy to its manufacture is ridiculous.

 

[GrandMaster]

He who pays the piper calls the tune. This is fine, but I don't like someone else claiming it is my favourite song if he has not asked me beforehand.

Ecogra could have insisted that the methodology be public, and if PwC did not like it, then maybe Ernst&Young or one of the other firms could have done it. Even Microsoft will allow governments to inspect the source code for its software, if it want to win contracts.

The problem with ecogra is that principles were formulated without any reference to the players. I would consider game fairness, good customer service, prompt payment and clear bonus terms to be the top issues. I don't think many people would get excited about daily reconciliation of balances. Game fairness is an issue on which ecogra made a mistake which cannot be rectified easily. Outcome based testing can never prove absolute fairness, only that the results are consistent with the games being fair, so it would be important to know what the tests measure and how thorough the they are. This is also something which does not lie in the traditional area of expertise of an accounting firm.

If ecogra made Golden Nile to pay promptly, then it has done something useful, although it came too late for me, but as far as game fairness is concerned, ecogra has done nothing for me.

I have been reading about voting machines in the US, there are some similarities in the story. If you are a US citizen or even if you are not, you should be worried. The next presidential election won't be decided by hanging chads, but by the manufacturers of the voting machines, and the biggest one, Diebold, is a major donor to the GOP. Diebold won't allow independent experts to test the machines for reasons of commercial confidentiality, although it will allow the states to test them. The California primaries were a mess, the machines malfunctioned, and it was later found that they contained uncertified code despite Diebold's assurances to the contrary. In other places the machines recorded more votes than the number of registered voters, or all votes were cast for the same candidate, and nobody know if there were any less obvious mistakes. This is what the lack of independent scrutiny can lead to.

 

[jetset]

No need for the rude asides, here Caruso - please try to debate like an adult.

You are imo becoming quite obsessive about this issue, to the exclusion of reason and your accusations need to be brought into line with reality.

QUOTE Yes, posting the same facts about this fit-up "verification" job. While they remain valid, will continue to do same." UNQUOTE

So much for your assertion that your behaviour does not constitute "spoiling tactics" And we still await evidence that your "fit-up job" is a fair and accurate comment. I personally doubt that we will see much in that line from you beyond mere posturing. And you have already illustrated that that is about all you're prepared to do to improve things in the industry.

"Do you actually read anything I write, or do you just see I responded, post and hope for the best? I said "Good questioning from Draymann". Necessary translation for Jetset: "I thought it was conducted well."

Indeed I do Caruso, although it takes a great deal of patience and occasionally your sarcasm and subsequent back-offs as is the case here does make the subtext fascinating. My point is made - Max did a good job on the interview, and eCOGRA did not hold back in its answers, even regarding the stalemate on your TGTR hobby-horse.

QUOTE (Me) The information is private because it suits Ecogra that it be private...All we have is PWC doing what they always did - rubber stamping figures handed over by Microgaming and gleefully banking the bucks.

"What factual evidence can you produce that justifies such a statement?"

"Duuh, the fact that it's all done in private? UNQUOTE

The accusation of unethical conduct inherent in that statement is clearly intended. But again it is without foundation or fact. The fact that PwC as an independent contractor regards it's proprietary testing process as confidential does not in any way constitute evidence of this or your other irresponsible and totally unsubstantiated comments alleging that "there is no data, there is no process"

But then you seem to feel that there must be some data after all, because PwC are accused of simply rubber stamping it. You go on to top your previous outlandish accusations about eCOGRA, it's members and PwC by referring to their acceptance of a professional and proven outsourced test system as "...the corrupt endorsing the corrupt"

You continue to irresponsibly throw these ridiculous slurs around when there is nothing to support such unreasonable statements, and your implication that eCOGRA, the Seal casinos and PwC (and presumably Microgaming and CON too judging by the above) are corrupt and fraudulent are preposterous.

QUOTE Oh well, that's that sorted. The corrupt endorsing the corrupt. Must be true then. LOL. UNQUOTE

Doesn't cut it. Where is your proof of corruption and the detail thereof - the fact that an independent, outsourced and reputable testing group refuses to bow to your demands that it opens up it's proprietary technology?

But this is old and repetitive argument. There is a stalemate because PwC do not seem to have moved from their position, and your personal view that their refusal to do so invalidates the whole eCOGRA initiative and makes all involved corrupt is certainly not shared by everyone.

Yet you are personally striving, fortunately without too much success to destroy an honest and well structured effort to improve things for the player and the industry. You are not prepared to show the strength of your convictions in a constructive manner by gathering solid player support and trying to change the status quo.

I'm with JPM on this one - your analogy does not hold water and certainly does not clarify the existing situation.

Grandmaster.

QUOTE Ecogra could have insisted that the methodology be public, and if PwC did not like it, then maybe Ernst&Young or one of the other firms could have done it. Even Microsoft will allow governments to inspect the source code for its software, if it want to win contracts.UNQUOTE

We are not talking about government here - we are talking about a private initiative involving major industry companies with good records trying to bring some safety and order to an unregulated industry that spans international boundaries and clearly has problems.

I interpret the interview to convey the fact that eCOGRA's Board sees no reason to consider a replacement of their independent and outsourced service provider as you suggest because as an organisation they have trust and confidence in the specialised skills and integrity of PwC. You mention Ernst and Young in your post, and this similarly respected and independent international body serves C.O.N. where there was inevitably some interaction between these two respected names in the eCOGRA process.

QUOTE Game fairness is an issue on which ecogra made a mistake which cannot be rectified easily. Outcome based testing can never prove absolute fairness, only that the results are consistent with the games being fair, so it would be important to know what the tests measure and how thorough the they are. This is also something which does not lie in the traditional area of expertise of an accounting firm. UNQUOTE

In your opinion. I am not sufficiently expert in this field to argue your that here, and as I do not know what your field of expertise is I must respect your statement that "...Outcome based testing can never prove absolute fairness, only that the results are consistent with the games being fair..".

But that, I would suggest is what most of us are looking for?

eCOGRA has already said that it consulted widely with experts on the formulation of its eGAP, and its advisers felt that the TGTR method for assuring games fairness on an ongoing basis was the way to go.

I believe the point has been previously made that like other major international financial and business services groups, PwC's expertise is not confined to being simply "...an accounting firm"

However, you seem from your postings to have some special expertise in this area so perhaps we can move on from the deadlocked transparency issue and explore some of the areas that Caruso has previously left unanswered in the other thread on this issue.

What in your opinion is the main objective here - is it to provide reassurance that PwC's TGTR system is honest and provides an acceptable level of comfort for the player that the games being presented are fair, or do you have some other and higher benchmark in mind? If so, what is it and how can it be achieved and judged?

If outcomes based testing is not in your opinion the answer, what is? Are you recommending the traditional testing laboratories and do these have access to the source codes of the software companies whose products they are testing? How is the confidentiality issue of this critical proprietary company asset protected - by NDAs? Do you consider this to be sufficient protection?

Is the testing carried out on a "one-off and here's your certificate" basis, or is there ongoing monitoring, top-up inspections and supervision of every access to the software? How is that achieved?

What "fourth party" validation do these traditional outsourced testing laboratories provide ie who is testing the testers? Is another testing lab contracted and if so how is the danger of collusion avoided? If there is such validation does the laboratory being tested open up all of its testing and analytical processes to the testing laboratory? Again, how is confidentiality assured?

Do you accept that in online gambling there may be practical difficulties to implementing traditional test procedures used in the land casinos ie chip handling security and inspection? Access to the software is frequently necessary for a variety of legitimate reasons in the industry, I am informed - how can a validation/inspection/test system be applied so as not to cause delays but still enforce the required level of independent supervision?

Do you have suggestions on any other testing methodology that might provide the sort of result you think regulation should be aiming for?

Speaking hypothetically, if proof of widespread and significant player distrust in PwC's system was adduced, and PwC were to seek another layer of validation, how could this be achieved whilst still guaranteeing the confidentiality of their critical TGTR asset?

Is there an alternative to the open public inspection that Caruso demands, for example a mutually agreed and relevantly qualified and respected neutral person who's validation would be accepted by all parties?





__________________

 

[amandajm]

Oh Max asked the questions for sure and he asked with the questions posed in other discussions with the players - for sure.

(Andrew Beveridge) :. PwC has done a remarkable job of getting all the major software suppliers (CryptoLogic, Random Logic, Microgaming and Boss Media) involved in the TGTR process, and I can understand why they wouldn't want to make public their proprietary information and technology which competitors could potentially exploit to take away market share. I think the players should respect this, and appreciate that this process is now tried and tested by PwC and these software providers over the last five years.

Says to me we have to trust PWC or not - (Q) Why the need for Ecogra then?

===============================================

Andrew Beveridge mentioned the player angle and did so with the authority of one that does not accept players have had a fair deal often enough ::

(Andrew Beveridge) :. Players have reached the stage where they demand better treatment. No unreasonably delayed payouts; no questionably disqualified bonuses; no badly applied wager through rules; no ignored emails. They want fair games, financially sound casinos with efficient and responsive Support and an avenue through which legitimate complaints can be independently investigated

The players want fair games and Mr Beveridge acknowledges this. Many players have felt they have not had a fair game in the past and that is with the presence of PWC doing the auditing.

Catch 22 - For one like a Caruso who does'nt necissarily trust PWC audits to define a fair game in the past and Ecogra are banking on the players trusting and respecting PWC, means Ecogra are a welcome extra player resolution service and not necissarily an "e-Commerce and Online Gaming Regulation and Assurance " of any note more than the Meister is for example - to the likes of a Caruso.

I am a likes of he but I don't want to call anyone names, be called names, or argue about it, too serious a subject for that. (sarcasm and humour can work if one can think of a good gag, thats all good)

Oh, I can't answer the Jets question of what would be a better way of verification and await the answer to that one.

Shall we dance?

 

[jpm]

Is there an alternative to the open public inspection that Caruso demands, for example a mutually agreed and relevantly qualified and respected neutral person who's validation would be accepted by all parties?

I don't think there is jetset. I think we covered in the other thread that no matter who does the verification, how its done, and if its transparent, that some people won't accept it. Mainly because the testee can show the tester one thing and then do another after the tester leaves. Certainly a valid arguement that is akin to a company keeping 2 sets of books.

So, as an alternative, how about this: Instead of eCOGRA saying they certify that the games are fair at casino x, they say something like 'periodic random testing of casino x has produced results that indicate the games are fair at the time we tested them'. Would that work for you caruso, grandmaster?

 

[jetset]

A good suggestion, JPM - and certainly more constructive than we have seen hitherto on this subject. Obviously it is something that only eCOGRA and PwC could consider, and I have therefore drawn their attention to this thread. I guess that the level of player support or otherwise for the initiative informs their decisions.

 

[jetset]

"Says to me we have to trust PWC or not - (Q) Why the need for Ecogra then?"

and

"Catch 22 - For one like a Caruso who does'nt necissarily trust PWC audits to define a fair game in the past and Ecogra are banking on the players trusting and respecting PWC, means Ecogra are a welcome extra player resolution service and not necissarily an "e-Commerce and Online Gaming Regulation and Assurance " of any note more than the Meister is for example - to the likes of a Caruso."

and

"I am a likes of he..."


I would suggest that if this is the extent of your perception of the eCOGRA eGAP regulations, that you may need to do a little more homework on this, Amandajm.

 

[jetset]

Grandmaster.

QUOTE Ecogra could have insisted that the methodology be public, and if PwC did not like it, then maybe Ernst&Young or one of the other firms could have done it. Even Microsoft will allow governments to inspect the source code for its software, if it want to win contracts.UNQUOTE

We are not talking about government here - we are talking about a private initiative involving major industry companies with good records trying to bring some safety and order to an unregulated industry that spans international boundaries and clearly has problems.

I interpret the interview to convey the fact that eCOGRA's Board sees no reason to consider a replacement of their independent and outsourced service provider as you suggest because as an organisation they have trust and confidence in the specialised skills and integrity of PwC. You mention Ernst and Young in your post, and this similarly respected and independent international body serves C.O.N. where there was inevitably some interaction between these two respected names in the eCOGRA process.

QUOTE Game fairness is an issue on which ecogra made a mistake which cannot be rectified easily. Outcome based testing can never prove absolute fairness, only that the results are consistent with the games being fair, so it would be important to know what the tests measure and how thorough the they are. This is also something which does not lie in the traditional area of expertise of an accounting firm. UNQUOTE

In your opinion. I am not sufficiently expert in this field to argue your that here, and as I do not know what your field of expertise is I must respect your statement that "...Outcome based testing can never prove absolute fairness, only that the results are consistent with the games being fair..".

But that, I would suggest is what most of us are looking for?

eCOGRA has already said that it consulted widely with experts on the formulation of its eGAP, and its advisers felt that the TGTR method for assuring games fairness on an ongoing basis was the way to go.

I believe the point has been previously made that like other major international financial and business services groups, PwC's expertise is not confined to being simply "...an accounting firm"

However, you seem from your postings to have some special expertise in this area so perhaps we can move on from the deadlocked transparency issue and explore some of the areas that Caruso has previously left unanswered in the other thread on this issue.

What in your opinion is the main objective here - is it to provide reassurance that PwC's TGTR system is honest and provides an acceptable level of comfort for the player that the games being presented are fair, or do you have some other and higher benchmark in mind? If so, what is it and how can it be achieved and judged?

If outcomes based testing is not in your opinion the answer, what is? Are you recommending the traditional testing laboratories and do these have access to the source codes of the software companies whose products they are testing? How is the confidentiality issue of this critical proprietary company asset protected - by NDAs? Do you consider this to be sufficient protection?

Is the testing carried out on a "one-off and here's your certificate" basis, or is there ongoing monitoring, top-up inspections and supervision of every access to the software? How is that achieved?

What "fourth party" validation do these traditional outsourced testing laboratories provide ie who is testing the testers? Is another testing lab contracted and if so how is the danger of collusion avoided? If there is such validation does the laboratory being tested open up all of its testing and analytical processes to the testing laboratory? Again, how is confidentiality assured?

Do you accept that in online gambling there may be practical difficulties to implementing traditional test procedures used in the land casinos ie chip handling security and inspection? Access to the software is frequently necessary for a variety of legitimate reasons in the industry, I am informed - how can a validation/inspection/test system be applied so as not to cause delays but still enforce the required level of independent supervision?

Do you have suggestions on any other testing methodology that might provide the sort of result you think regulation should be aiming for?

Speaking hypothetically, if proof of widespread and significant player distrust in PwC's system was adduced, and PwC were to seek another layer of validation, how could this be achieved whilst still guaranteeing the confidentiality of their critical TGTR asset?

Is there an alternative to the open public inspection that Caruso demands, for example a mutually agreed and relevantly qualified and respected neutral person who's validation would be accepted by all parties?

__________________[/QUOTE]

Grandmaster, this is not an ambush, but a genuine wish to explore your seemingly expert views on this software testing issue, and I would appreciate a response, please.

 

[caruso]

"So much for your assertion that your behaviour does not constitute "spoiling tactics"".

I said "facts". To you they are "spoiling tactics" because they upset your applecart. Call them what you will, they remain facts - and I'll repeat them later for clarity.

"...But then you seem to feel that there must be some data after all, because PwC are accused of simply rubber stamping it."

Data means the play logs leading to the "assertion" of fair play, the same as the OCA data releases. Sheets of paper sent to PWC for the rubber-stamp is not "data", it's "fiction." Got the difference now?

"You continue to irresponsibly throw these ridiculous slurs around when there is nothing to support such unreasonable statements"

There is nothing irresponsible or ridiculous about the truth. Again: see below.

"Yet you are personally striving, fortunately without too much success to destroy an honest and well structured effort to improve things for the player and the industry."

Negative on all fronts, and as long as your only recourse is to question my integrity I don't think any comment is necessary. People know what I stand for: I'm a players' player and I don't buy your organization's bullshit. You are an industry spokesman, representing a plainly "corrupt" organization - "corrupt" because they are making "verification" statements the validity of which is entirely unknown to everyone - including, it would seem, Ecogra themselves, since PWC are simply passing "stamps" onto them and not making them or anyone else privvy to any of the processes, and they are knowingly complicit in a lie.

Summary:

1) Ecogra claim that their "seal" guarentees a fair game.

2) This "guarentee" comes in the form of out-sourced "results analysis" from PriceWaterhouseCooper.

3) PWC refuse to both 1) issue the player data from which these conclusions are drawn and 2) issue any information on the collection process of said data - by way of allowing independent parties to verify to their / our satisfaction the validity of the claims.

(On a sidenote: it sould be borne in mind that JUST these requirements were made of the OCA project, identical insofar as it analysed player data and performed statistical tests for the purposes of establishing the random or non-random nature of the deal; and although the industry yes-men felt the need, correctly, to have all but the project participants' inside leg measurements on the table for the purposes of pulling it apart, as soon as Ecogra started making "fair game" statements based on essentially identical "analysis" on the part of PWC, these requirements were suddenly no longer appropriate - because PWC are "reputable" and they should therefore be trusted. ROTFLMAO - obvious bullshit.)

4) In the absence of any proof of ANYTHING, it has to be assumed that PWC are doing nothing more than they were ever doing - rubber-stamping figures handed over from Microgaming, Cassava, etc. with no knowledge of the validity of the figures - they could be Moshul's lotto numbers for all PWC knows. Until we have evidence of the basis of these rather outlandish claims, the claims are by definition meaningless - "by definition" because they are made without any evident foundation and require blind acceptance on the part of the players (Ecogra said this themselves in the interview), which is unacceptable insofar as the simple word or "assurance" of any one person or organization, uncorroboarated and in fact uncorroboratable, is worthless.

5) Therefore, the claim to "verified software" is meaningless.

All players should reflect on this whenever they're browsing over sites and looking at all those fake logos. These are unsubstantiated, fictional statements, to be ignored in as much as they claim any authority on game fainess.

 

[caruso]

JPM - your compromisatory suggestion is noted, but it really wouldn't change anything. How they specifically word their claims doesn't alter the fact of the lack of evidence of the data and processes behind those claims.

 

[jetset]

I think you may be right, JPM - nothing is going to moderate this extreme Caruso mindset.

 

[rowmare]

I think you may be right, JPM - nothing is going to moderate this extreme Caruso mindset.

I couldn't agree more.

 

[caruso]

Don't put words into JPM's mouth to suit your purposes. He wasn't remotely critisizing me, he was offering what he considered a compromise. He wasn't saying anything about me and the words "extreme mindset" are YOURS, not his.

Sorry you had your words twisted, JPM.

If you have valid rebuttal for my argument, state it. Insulting me is not "rebuttal".

 

[jetset]

This is pretty rich - Caruso whining about an attack on his integrity when for the past few weeks that is all he has done in the most reckless and unsubstantiated assaults on respectable and professional people with a real commitment to improving player protection and the industry.

People who are actually doing something beyond posturing on a message board.

Caruso has lunged at everyone who does not share his opinions as the self-styled "player's player." From *bullshitting* "industry insiders" to "corrupt" execs at eCOGRA and PwC he has trashed indiscriminately in a performance that daily grows more unreasonable and suggests to me a polarised view of the industry as "players" and "everyone else".

Caruso does not personally need the advantages of regulation although he concurs that others might.

His bone of contention with the entire eCOGRA initiative and its comprehensive, player-friendly requirements and top 43 casino membership is that it is totally invalidated by the refusal of an independent, third party company to open up its proprietary testing system for public inspection.

That is not a fact - it is an opinion.

In his opinion, this makes those concerned in the initiative "corrupt".

He has not in the past called for similar "testing the tests of the testers" in regard to other software verification alternatives, and he has no practical suggestions on how this might be done.

For someone who has been so vociferous he has actually done very little to take this issue forward, contenting himself with comments on threads here at Casinomeister.

As far as I know he has made no attempt to directly engage either eCOGRA or PwC with his inaccurate personal assumptions and views, and when it was suggested that he should muster credible player support for his "total invalidation" opinion as a solid base from which to attempt a policy change, he declined. Instead, he is prepared to "draft a letter".

My opinions, like Caruso's are personal. I certainly support this initiative, as eCOGRA is in my personal judgement the most sincere, comprehensive, practical and well-funded regulation movement yet, and it is clearly succeeding.

Unlike Caruso, I have taken the time and trouble to talk to the people involved since it was launched two years back at GIGSE in Montreal, and I have been impressed with their integrity, independence and commitment to safer, more efficient online gambling.

They certainly do not deserve the inaccurate and discourteous jibes that have been repeatedly thrown their way by this individual.

With Caruso's stated intention of trashing eCOGRA on this "testing the tester" stand-off every time it's name appears it is clear that this argument is going to be resurrected with monotonous regularity, and probably increasing frustration.

 

[amandajm]

I would suggest that if this is the extent of your perception of the eCOGRA eGAP regulations, that you may need to do a little more homework on this, Amandajm.

Fair enough, I have tried to keep up with the threads and read their stuff.

I can't be with Caruso and say anyone is "corrupt" - I have no proof or anything of the sort.

I picked out Beveridges peice on trusting PWC as PWC have been around for ages ans have not necissarily bred lets say - complete trust in them.

So I check

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and find

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The Link Removed (invalid URL) report accused PwC of 'a regrettable lack of principle...not failures of technical competence but rather a failure of will - a lack of robustness and strength of purpose'.

What would I know Jet? Who do i believe? The department of trade and industry or PWC regarding lack of principles?

Who do you believe?

I am not sold either way yet.

This is who Ecogra want us to respect and trust without even questioning it?

 

[GrandMaster]

We are not talking about government here - we are talking about a private initiative involving major industry companies with good records trying to bring some safety and order to an unregulated industry that spans international boundaries and clearly has problems.

My point was that companies will do anything if you pay them enough money.

eCOGRA has already said that it consulted widely with experts on the formulation of its eGAP, and its advisers felt that the TGTR method for assuring games fairness on an ongoing basis was the way to go.

I believe the point has been previously made that like other major international financial and business services groups, PwC's expertise is not confined to being simply "...an accounting firm"

Who was their expert on the mathematical and statistical aspects of eGAP? As far as I can tell from their biographies, the directors of ecogra don't have any mathematical background and they approved flawed criteria for game fairness. If they did not hire anyone with mathematical expertise, I am very concerned about the standards of the secret statistical tests, if they did, they should ask for their money back.

However, you seem from your postings to have some special expertise in this area so perhaps we can move on from the deadlocked transparency issue and explore some of the areas that Caruso has previously left unanswered in the other thread on this issue.

What in your opinion is the main objective here - is it to provide reassurance that PwC's TGTR system is honest and provides an acceptable level of comfort for the player that the games being presented are fair, or do you have some other and higher benchmark in mind? If so, what is it and how can it be achieved and judged?

If outcomes based testing is not in your opinion the answer, what is? Are you recommending the traditional testing laboratories and do these have access to the source codes of the software companies whose products they are testing? How is the confidentiality issue of this critical proprietary company asset protected - by NDAs? Do you consider this to be sufficient protection?

Is the testing carried out on a "one-off and here's your certificate" basis, or is there ongoing monitoring, top-up inspections and supervision of every access to the software? How is that achieved?

Outcome based testing is fine with me. I think the pronciples of OCA were good, my biggest concern would be about the integrity of the data, I don't know what measures were taken to prevent players from submitting fake data or from selectively submitting data only from losing or winning session.

If I were doing it, I would first test the raw random number output. If there is not enough randomness here, the games cannot be fair.

I would then do game specific tests. In blackjack, I would test the joint distribution of the player's initial cards and the dealer's up card, the distribution of the dealer's hole card, dealer outcomes, the player's third and maybe even fourth card if the size of the data allows. I would also test whether the distributions are independent of the player's action, for example, is the probability of the dealer having BJ the same whether or not the player takes insurance, or if the player has A,2 vs 5, will he get the same distribution of cards whether he hits or doubles? In roulette, craps and sic bo, I would test distribution of the numbers, the independence of spins or rolls. I would also test whether the outcome are independent of the bets, so that red and black are equally likely when there is more money on red, and there would have to be a special test for bets such as pass/don't pass, come/don't come and hard way bets, which depend on the outcomes of several rolls to make sure that there are no hidden dependencies. There are some problems with video poker and slots because there may not be enough data to verify that royal flushes or jackpots occur with the correct frequency. Some testing for correct distribution and independence of the initial five cards dealt in VP should be possible, the hardest thing would be to test the distribution of the cards draw after the discard, I don't have an obvious solution to this. All these test should also be done grouped by bet level or coin size.

Testing should be done on an ongoing basis and cumulative data should also be tested, because a larger sample may produce statistically significant results where a smaller one does not. (For example, losing 10 units in 100 hands of BJ is not unusual, losing 100 units in 1000 hands would be very bad luck but still possible in a fair game, whereas losing 1000 units in 10000 hands would be very convincing evidence of cheating.)

My list may not be complete, other people may want to test other things, but I would want to be convinced that at least this level of testing is being carried out and that it is done competently.