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.