How can all groups know that they will have a fair share at the profits from the network Bingo. It would seem that if it is played weekly on the same day and the same time only certain groups would get the best shot at selling these games. I believe that a regularly scheduled program where all Bingo halls and Businesses and Homes could turn on and watch would be the fair way to approach this great opportunity. Add other incentives dealing with the time of day they are bought and the day of the week they are bought in order to give all sessions across the state of Virginia ample sales opprtunities. Also i believe that if a certain percentage of each sell goes to the group that sold it, a bonus amount to the hall that it was bought in would also increase the sells of this game plus encourage all halls and groups to participate. In turn making it a profitable venture for all including the state.

November 25, 2013

TECHNOLOGY CONCERNS

The technology needed to implement a Network Bingo system currently exists.  All types of networks exist today in our society and there should not be major problems in establishing a network.  Items to be considered are:

•           Access and general security of the system.

•           Player-owned devices such as smart phones, web tablets and mobile PCs should be permitted for those networks that can accommodate their use. These devices are simply meant for the players to view their activity and have no bearing on sales, playing or outcomes.

•           Possible use of a Random Number Generation System (RNG) instead of the standard ball blowing machine.

•           If use of a standard ball blowing machine is required then making each participating End User of a particular network be the “caller”, for a session of play on a rotating basis should be a requirement.

•           Point-of-Sale (POS) and reporting requirements.

•           All POS stations must be linked together within the network of participating End Users to properly “pool” together and track all of the bingo cards being played in the network.

•           Multiple ways in which players may deposit or otherwise purchase their bingo cards or packages for a session.

•           The means by which verification of a winning bingo is done must be in a manner that simultaneously provides proof of verification to all the players of all the End Users of the Bingo Network.

•           Manner in which players are paid out winnings.

•           Means by which game information is announced to the players.

•           Prevention of client terminals from being able to access physical sites or Internet sites outside the required or permitted sites of the Networked Bingo system.

CONCERNS OF IMPLEMENTATION

Actual implementation of the Networked Bingo system is probably more important that technology concerns.  While technology is very important, rules related to non-technical issues could harm current play of session bingo and doom the ability of the Networked Bingo system to be a practical alternative.  We respectfully submit to you that in order to be truly successful, the Networked Bingo system must be setup so that it is made as easy as possible for End Users to join and participate.

Items to be considered:

•           Consider that not all organizations play bingo at the same time.  This is an obvious statement but not to be taken lightly.  Many organizations are limited as to what day or time they can play.  Commercial lessors who have more than one location of operation have a much greater flexibility in their ability to schedule when sessions can play.  Potentially they could quickly be setup in Networked Bingo and be at a severe competitive advantage for the bingo-playing public.

•           Commercial lessors should not be allowed to force organizations to participate in a particular Network Bingo system.

•           Commercial lessors should not be involved with any of the financial transactions involving use of the Networked Bingo system.

•           The Network Bingo system must allow for individual organizations to shop and look for convenient days and times by which they could join and play.  This way a small hall could more easily find other members to join and play with across the state.

•           Place a limitation on the prize payouts, number of members and possibly the number of players that may exist in a particular Networked Bingo system at one time.  This is needed to offer some protection to smaller networks of bingo within the state.

•           There should be multiple Suppliers of a Network Bingo system.  The state should not be limited to one Supplier unless of course only one applies to setup a system.  The free market and competition should dictate pricing.

•           Each Supplier must be able to setup multiple networks of bingo in order to accommodate the scheduling of the organizations.

•           The means by which funds are collected and paid out in the network is not to be taken lightly.  By way of example, consider that you have two End Users in a network.  Organization A collects $8,000.00 and Organization B collects $5,000.00 and the payout for playing on the network is $10,000.00.  The players at Organization B win $7,000.00 of the prize payout.  Organization B does not have enough funds on hand for the payout.  How is this to be handled?

•           Suppliers should not be required to fund payouts unless the Suppliers are empowered to collect player revenue for the payouts.  What happens if End Users do not pay for participating?

•           Credit and debit card processors may view a Networked Bingo system as Internet Gaming and may automatically block processing of credit and debit card transactions.  The State of Virginia must properly inform credit and debit card processors that the transactions are legal and that a special transaction code is assigned to transactions made in the network.

•           Rules will be needed to govern a situation when a network goes down, or is down for some of the End Users in the network, or is otherwise disabled in a session.  Reasons could be technical or an act of God such as weather.

With the extreme decline of groups taking part in the charitable gaming and the associated reduction in monies being raised and given away to worthy causes, 'network bingo' can be an access for groups to participate in. This of course will depend of IF the game and the regulation of such, is attractive enough to make the groups want to take part in this new game. First, the money spend by the players needs to be removed from the normal 'gross receipts audit fee' which is currently in effect. How can one group be responsible to all of the receipts into a 'pool' event ? Also, how can one group pay-out a winning ticket, if that group does not have the funds to award the prize. The prize needs to be paid out from a centralized 'pool' account. Who will handle this account ?? Who will oversee this account ? These are just some of issues which will be need to addressed when the rules and regulations are considered. Also, do the proceeds fall under the 'use of proceeds' regulations for the groups ? 
We welcome this opportunity to address Network Bingo as well as the EXTREME audit fee and the use of proceeds issues concerns. These issues need to be changed NOW -before more groups stop playing chartiable bingo and before more charities suffer because of loss revenues. The state should STOP taxing groups and judging groups' performance based on gross sales. This is grossly unfair and NOT a normal healthy business practice, This is proven out by the numbers provided by DCG - revenues are down...we need to make changes immediately.
It would be my pleasure to assist in any way to help many these changes come about.

Marty Williams, FOP of Virginia

Gaming Arts, LLC is pleased to submit comments to the Charitable Gaming Board regarding network bingo.

• Network bingo game providers and qualified organizations should be permitted to use a certified random number generator (RNG) for determining the outcome of network bingo games, as opposed to a ball blower.  Technical standards for certification of qualified RNG should be included in the regulations.  The use of a certified RNG will enhance the security and integrity of network bingo games.

• Qualified organizations participating in a network bingo game should be permitted to pre-sell network bingo cards.  Meaning, if an organization is scheduled to participate in a network bingo game on a Friday, that organization should be permitted to sell network bingo cards for the Friday game during the preceding calendar week. We believe this is necessary to maximize participation in the network bingo games and to promote the success of those games.

• Participating organizations cannot be expected to have enough funds on hand to pay network bingo prizes, up to $25,000. The rules should permit organizations and/or network bingo providers to pay verified winners within a calendar week.  This will allow enough time for game wins to be verified by the network bingo provider and for the “pooled” funds to be aggregated and accounted for.

• Pari-mutuel games of chance have a risk of failure due to lack of initial player interest and participation.  In order to generate player interest and enhance participation in network bingo games, licensed network bingo providers should be permitted to seed network bingo game jackpots and fund prizes. Meaning, the prize funds available for each network bingo game should not be limited to a percentage of the total amount of network bingo cards sold in a particular network, so long as no single network bingo prize exceeds $25,000.  

• The Charitable Gaming Board has been tasked with establishing a “percentage of proceeds derived from network bingo sales to be allocated to (i) prize pools, (ii) the organization conducting the network bingo, and (iii) the network bingo provider.”  The adopted rules on this point should allow for flexibility by use of a minimum threshold as opposed to a fixed amount for the organizations.  For example, the allocation for the organization conducting the network bingo should be a “minimum of ___% of the proceeds derived from network bingo sales.”   The allocation for the prize pools and the network bingo provider should be left to the discretion and mutual agreement of the organizations and network bingo providers.

James Robertson

General Counsel

Gaming Arts, LLC

(702)818-8943