15-40-50 (R) – Conduct of bingo, instant bingo, pull-tabs, seal cards, event games, and raffles

                1.   If the distributed pull-tab system is capable of seamlessly switching between users/organizations we feel there is no need to suspend play during the mandatory break periods. In the case of multiple organizations operating at different time periods at the same location, each game set opened by an individual organization, such as a charity, can be owned by that organization and tracked accordingly. That particular game set will only be active while the owning entity is signed into the system. This eliminates the risk associated with paper pull-tabs.

 

15-40-170 – Dispensing of electronic game cards

1.       We recommend adding language regarding commingling such as exists under 11VAC15-40-60 that would be applicable to electronic distributed pull-tab systems.

 15-40-180 (2) – Game set requirements

1.       In our opinion, the deck size is too small. Increasing the deck size to 100,000, for example, will have the following effects;

a.      Dramatically decreases the likelihood of customer tracking.

b.      Decreases the risk of buy outs.

 

15-40-210 (E) – Security requirements

1.   The language here states that two-level pass codes are required to access all components of a distributed pull-tab system. While requiring two-level pass codes for any access to the system (e.g. central server, cashier POS terminal, etc.) is reasonable, it may be overly cumbersome for patrons. A one-level pass code for patrons accessing player accounts at terminals is more reasonable.

 

15-40-300 (H) - Player devices
              1.  We support no limits on the quantity of handheld devices present at any charitable gaming location.

 

15-40-410 (A(6))– Game play requirements

1. Additional sounds should be allowed as informational aids to the player, audio and visual cues. Such circumstances may include:

                a. Out of credits (audio)

                b. Crediting a win or additional credits inserted (audio)

                c. Highlighting wins (visual)   
                d. Error messages (audio and visual)

 

2. The lack of audio and visual cues may exclude patrons with visual or hearing impairments from playing the game and may open up the regulations to challenge based on ADA accessibility guidelines.

 See below for our comments on these sections;

15-40-210 (G) - Security requirements

15-40-220 – Backup and recovery

15-40-300 (D) – Player device general requirements

15-40-300 (D) – Player device general requirements

15-40-340 – Memory clear

15-40-350 – Critical memory

15-40-360 – Program storage devices 

We do not feel these sections are written in a way that adequately addresses a computer based system with a standard operating system such as Microsoft Windows. We recommend updating these sections to include language that covers the inclusion of networked computer systems utilizing off-the-shelf computer terminals, networked (wired or wireless (Wi-Fi)) to a central server.