[Replaced] In order to maintain the maximum level of game integrity, the central system shall be provided by a single vendor that has been contracted by the department to provide and to operate such a central system within the Commonwealth of Virginia.   All player terminals shall be connected to the central system prior to the play of any electronic game cards.  Manufacturers or suppliers who lease, rent or distribute player terminals; or sell or distribute electronic game cards shall pay a reasonable fee, which is determined by the department to such a single vendor.  Such a single vendor shall not offer to lease, lease, offer to rent, rent or distribute player terminals to any manufacturer, supplier or organization within the Commonwealth of Virginia. 

In order to maintain the maximum level of game integrity, all systems to be used as part of the electronic pull-tab program must be certified by an independent testing laboratory designated by the Division of Charitable Gaming.  Elements to be tested include the central system, site controller, player terminal(s), and games.  The independent laboratory will test and certify that the hardware, software, and communication methods between elements meet the requirements specified within these rules.  All fees and costs associated with the testing and certification will be the responsibility of the submitting manufacturer. 

[Comment: Requiring all player terminals to communicate directly with a single central system will significantly decrease the potential revenue to the charities by increasing the overall program costs.  Through testing and certification, central systems from multiple vendors can be just as secure as a single system, while offering the advantages of competition, lower costs, potentially increased reliability, and shorter time-to-market.]

[Part III, Section K, Item 3] 

[Edited] Each dispensing device shall be manufactured in such a manner that any visual animation does not simulate or display rolling, flashing or spinning mechanical or video reels or produce audible music or enhanced sound effects or any other attribute not explicitly approved by the department.  The following attributes of the dispensing device must be approved by the Division of Charitable Gaming prior to deployment: cabinet design (including artwork and lighting), communication methods, sounds, images, and animations. 

[Comment: Edited for clarity.  The latest generation of mechanical dispensing devices utilizes audio and video for point-of-sale promotion. While the machine is not being played, animation sequences run to promote games and charities. A touch screen monitor with on-screen buttons is used to dispense physical paper tickets. These innovations can significantly boost sales while maintaining the basic characteristics of a vending device.]

[Part III, Section N] 

[Edited] The total face value of tickets being dispensed from the instant bingo, pull-tab, or seal card dispensing device shall match the amount deposited in the bill acceptor device or coin acceptor less change provided. 

[Comment: It is not clear if this would allow a player to make multiple selections after inserting currency.]

[Part III, Section O, Item 4]

[Edited] The payout percentage for an electronic game card shall not be less than fifty percent (50%).and not be more than seventy-five percent (75%) for the entire electronic deal. 

[Comment: The current rules for paper pull-tabs do not limit game payouts. There is no reason to do so for the electronic version.  In order for electronic pull-tabs to compete with paper pull-tabs and other gaming options, they will need to provide an equivalent or better playing experience.  Also, capping the payout provides absolutely no benefit to players.]

[Part III, Section O, Item 6] 

[Deleted] The electronic game card shall only contain wagers in the amount of one dollar per card. 

[Comment: The current rules for paper pull-tabs do not limit ticket prices. There is no reason to do so for the electronic version.  In order for electronic pull-tabs to compete with paper pull-tabs and other gaming options, they will need to be offered at a number of different price-points.]

[Part III, Section O, Item 14] 

[Deleted] Following the initiation of a RAM reset procedure, the electronic game card shall execute a routine, which initializes each and every bit in RAM to the default state.  The RAM reset procedure shall be conducted by a certified RAM clear method as approved by the department.  For an electronic game card that allows for partial RAM clears, the methodology in doing so must be accurate and the electronic game card must validate the un-cleared portions of RAM.  After the conduct of the RAM reset procedure, the single video monitor or touchscreen shall not display the top award for the electronic game card.  In addition, upon entering game play mode, the default display for the electronic game card shall not be the top award.