Public Gaming Magazine November-December 2015

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12 // PUBLIC GAMING INTERNATIONAL // November/December 2015
PUBLIC GAMING
INTERVIEWS Kevin
MULLALLY
General Counsel and Director of Government Affairs
Gaming Laboratories International (GLI)
ON SKILL-BASED GAMES
Nevada recently legalized the con-
cept of skill-based wagering games.
It is expected that this new wager-
ing game-style will be quite popular
and spread to other jurisdictions.
Now begins the process of build-
ing the regulatory structures to en-
sure the security and integrity of the
skill-based games that operators will
want to bring to the market.
Paul Jason, PGRI: Skill-based games
would seem to represent a whole new layer
of regulatory complexity. What are some of
the issues as relates to ensuring the security
and integrity of skill-based games?
Kevin Mullally: At this point, GLI
is playing a supportive role with regula-
tors, helping them to sort through a lot
of the issues with regard to the blending
of two styles of gaming. We have a lot of
experience in dealing with both. On one
hand, we have random games like slots
and Lottery. We have a deep understand-
ing of all the regulatory issues relating
to this game style. On the other hand,
we have this new game style, and we are
now working with regulators to refine
the methods for ensuring the integrity of
skill-games. The operators also need to
have a precise understanding of the odds
and strategies to predict prize-payout
return percentages. Most often, skill-
games include an element of chance as
well. So we are blending those two con-
cepts. As you point out, skill games are
being developed that will include game
styles, game logic and components that
nobody has seen before. We will need to
develop technical standards and meth-
odologies to test and vet the security of
these new game styles. We are analyzing
prototypes now to acquire the techni-
cal understanding that will enable us to
then create a risk control model for the
new game styles. This will be an ongoing
iterative process. We provide informa-
tion and advice to regulators based on
our technical expertise and research, and
they will make the policy decisions.
The potential for cheating in skill-based
games would seem to be greater than in
random-based games of pure chance. How
do you apply technical solutions to prob-
lems arising from human behavior that
does not fit into the kind of algorithmic
modeling that work so well for random
games of chance?
K. Mullally: GLI is actively working
with regulators to assist them as they
develop the regulatory framework for
these games. There are some preliminary
versions of the regulations that allow for
the establishment of an expected return
based on optimal play that is based on
a scientific and mathematical analysis
of the device and the game. If there is
a variance above a certain percentage or
other kind of departure from the pre-
dicted range of outcomes, the operator
is alerted and enabled to then either con-
duct an investigation or even shut down
the game while they try to determine the
cause of the unexpected behavior. It is
important to provide transparency to the
range of expected outcomes based on a
mathematical model of the game design.
That range is the baseline. With that
knowledge he play can be monitored and
deviation can be identified. The, regula-
tors and operators are equipped with the
information they need to assess different
option and decide what to do about it.
The methods of assuring the integrity
of the games has always needed to adapt