US - National Coalition Against Legalized Gambling
November 12, 2006
100 Maryland Avenue NE, Room 311, Washington, DC, 20002 ~ (800) 664-2680 ~ ncalg@ncalg.org
The National Coalition Against Legalized Gambling feels that the distinction between Class II and Class III gambling machines should be distinct and palpable to the players. If a machine looks like, sounds like, and feels like a slot machine in play, it should be categorized as a Class III gambling machine, regardless of whether or not the technology inside the machine pits player against player rather than player against a computer.
The National Coalition Against Legalized Gambling also feels that there are major problems relating to fraud and consumer protection under the current NIGC technical regulations concerning both Class II and Class III gambling machines.
Both Class II and Class III machines approved by the NIGC use a "conversion" process where a random outcome from a fixed prize pool, like a bingo game (Class II) or complex paytables (Class III) are converted and displayed as game outcomes on what appears to be real slot machines. Both may use mapping and unbalanced reels that are intended to distort players’ perceptions of the true probabilities of winning. It is our understanding that the NIGC and your testing labs do not check and scrutinize these concealed processes or features to see if they can distort players’ perceptions or if they contravene US federal fraud laws or consumer protections laws.
We would suggest that a new technical standard should be introduced that bans any process or feature that has the potential to mislead players by distorting the players perceptions in any manner. The use of mapping and unbalanced reels should be outlawed because their intended purpose is to give the player the perception the odds are better than they actually are by displaying game outcomes, using mapping to "weight" various outcomes that deliberately "distort" the true odds of winning. This appears to us to violate consumer protection standards that the federal government applies to almost every other industry in the country.
We will be watching closely and working with members of Congress to see if these major problems are corrected in your regulations, and will challenge regulations that we feel are in violation of federal standards.
Sincerely,
Dr. Guy C. Clark, chairman
National Coalition Against Legalized Gambling
p.s. for a more detailed examination into the deceitfulness of video slot machines, please read the attached research article by Falkiner and Horbay
