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