Here is part of it for you DiscoBob...
NanoTech Gaming
December 8, 2015
Via Electronic Mail
Bruce Band – Assistant Director of Investigations and Enforcement Bureau
Massachusetts Gaming Commission
101 Federal Street, 12th Floor
Boston, Massachusetts 02110
bruce.band@state.ma.us
Re: A Request for Public Comment: Skill Based Gaming
Dear Director Brand,
As Creative Director for NanoTech Gaming, I have ensured that my company has been at the
forefront of recent changes to Nevada Gaming Regulations. We have always made our
expertise in skill-based games available for furthering the discussion.
With regards to Massachusetts adopting regulations regarding skill-based gaming, we are also
willing to participate in your process, and honored to be included in the request for comment.
To the specific points of your email request:
• Areas where GLI-11 as it presently exists (or other applicable GLI standards) are
insufficient to provide for the regulation of skill based gaming devices;
o In 3.4.1a, Optimum Play Used for Skill Games we read: Gaming devices that may
be affected by player skill shall meet the requirement of this section when using a
method of play that will provide the greatest return to the player over a period of
continuous play.
At NanoTech Gaming, we have experimented with what we call the ‘effect of skill’ on the
observed payback percentage. The subsection above indicates that an ‘optimum play’ method
should be the standard by which this requirement is met. However, we believe that the 75%
minimum payback should be a standard for all new skill-based games. A clear example of how
only looking at ‘optimum play’ could damage player perception of skill-based games is found in
the example of Video Poker.
NanoTech Gaming
7180 Dean Martin Drive Suite 300
Las Vegas, NV 89118
Stephen Riesenberger – Creative Director
stv@nanotechgaming.com
In a Jacks-or-Better Video Poker game, skilled players will use the ‘optimum play’ method, and,
with little to no mistakes, earn a payback that is well above the 75% minimum. In contrast, a
player who is unskilled at Video Poker and not knowledgeable of the game rules could play the
game by drawing 5 additional cards each game. A player who demonstrates this lack of skill
would earn a payback far below the 75% minimum – at worst case a Wizard of Odds study put
the payback somewhere around 3%.
Because my company is focused on bringing skill-based games to casinos where physical
dexterity is the means by which the player is judged, we are convinced that penalizing the
player in the same way Video Poker does for lack of skill would result in an extremely
dissatisfying experience for new players.
o In 3.17.2, Last Play Information Required we read: Last play information shall
provide all information required to fully reconstruct the last ten (10) games. All
values shall be displayed; including the initial credits or ending credits, credits
bet, and credits won, payline symbol combinations and credits paid whether the
outcome resulted in a win or loss. This information can be represented in
graphical or text format. If a progressive was awarded, it is sufficient to indicate
the progressive was awarded and not display the value. This information should
include the final game outcome, including all player choices and bonus features.
In addition, include the results of double-up or gamble (if applicable).
The Nevada Gaming Control Board recently amended their technical standards to address this
section under STANDARD 1 INTEGRITY OF DEVICES, under section 1.080 Control program
requirements:
7. All gaming devices must have the capacity to display a complete play history for the most
recent game played and nine games prior to the most recent game. Retention of play history for
additional prior games is encouraged. The display must indicate the game outcome (or a
representative equivalent), intermediate play steps (such as a hold and draw sequence or a
double-down sequence), credits available, bets placed, credits or coins paid, and credits cashed
out. Gaming devices offering games with a variable number of intermediate play steps per
game may satisfy this requirement by providing the capability to display the last 50 play steps.
We drafted a letter to Technology Division Chief Jim Barbee pointing out that even this new
standard may not be sufficient in the face of highly complex, physics-intensive, and chaotic skillbased
games (a copy of our letter is attached). Even though Chief Barbee noted our comment,
he believed that the language drafted above would be sufficient for the time being.
NanoTech Gaming
7180 Dean Martin Drive Suite 300
Las Vegas, NV 89118
Stephen Riesenberger – Creative Director
stv@nanotechgaming.com
• Whether the Commission should set a maximum tolerance for skill based games
o It’s unclear what your definition of ‘tolerance’ is here; whether it pertains to the
tolerance of the maximum degree to which skill is allowed to affect the outcome,
or the tolerance of the maximum payback which may be achieved based on skill
If ‘tolerance’ refers to the maximum degree to which skill is allowed to affect the outcome, to
our previous point regarding 75% minimum payback, we have developed a patent-pending
system – the NanoTech Advantage – which allows the player to adjust this skill effect from 0%
to about 25%. In this case, the ‘maximum tolerance’ for skill to affect the outcome is about
25%. Percentages higher than this maximum would reduce the payback for unskilled players,
and is a dissatisfying experience in our observed tests.
If ‘tolerance’ refers to the maximum payback which may be achieved based on skill, this refers
to GLI-11 section 3.4.1a on ‘optimum play’. Using our NanoTech Advantage system, a range of
possible payback percentages is displayed to the player before starting a game. This range is
based on the history of previous player scores and bets, and the player’s chosen bet amount,
goal win amount, and the effect to which skill will influence the outcome.
Using Nevada state minimum payback of 75%, in an example where the casino wants a Return
to Player of 99%, the ‘maximum tolerance’ for an instance of a wager is 123%; the sum total of
all wagers made on the machine will never return more than 99% to the players in this
example.
• Unique issues involving skill based gaming devices that require clarification from the
Commission.
We exhibited our games and gambling technology at the Global Gaming Expo in October of
2015. We also saw a number of other gaming companies exhibiting their ‘skill-based’ game
machines. However, none of the manufacturers could succinctly explain how a very skilled
player could see a benefit for demonstrating their skill. Many of the games featured math
models which were based on existing slot machine models, where the payback for very skilled
players is still well under 100%, and players who lack skill will be penalized.
We believe that games like this that operate on deception, or ‘illusion of skill’, or utilize slotmachine-style
‘redemption wins’ (which are actually net losses) are designed to perpetuate the
status-quo of slot machine manufacturers.
At NanoTech Gaming, we are offering the first opportunity for players to gain value for
demonstrating their physical skill at playing videogames, combined with casino math, which
also guarantees that there is no exposure to the operator due to pricing errors, or extremelyskilled
players, or those who exploit the game to earn high scores.
NanoTech Gaming
7180 Dean Martin Drive Suite 300
Las Vegas, NV 89118
Stephen Riesenberger – Creative Director
stv@nanotechgaming.com
We appreciate this opportunity to share knowledge, and look forward to your response.
Sincerely,
Stephen Riesenberger
NanoTech Gaming
7180 Dean Martin Drive Suite 300
Las Vegas, NV 89118
Stephen Riesenberger – Creative Director
stv@nanotechgaming.com
NanoTech Gaming
October 30, 2015
Via Electronic Mail
Jim Barbee – Technology Division Chief
NEVADA GAMING CONTROL BOARD
555 E. Washington Avenue, Suite 2600
Las Vegas, NV 89101
jbarbee@gcb.nv.gov
Re: Request for Industry Comment for Proposed Changes to Technical Standards for Skill
and Hybrid Gaming Devices
Dear Chief Barbee,
NanoTech Gaming is focused on bringing skill-based games to casinos, and committed to
ensuring that gaming regulations and technical standards are created not only to protect the
players and the operators, but to increase gaming revenue for the state of Nevada and the
casino industry worldwide.
Reading through the current and proposed language of the technical requirements, we have
concern over the requirements set forth in the first four sentences of STANDARD 1 INTEGRITY
OF DEVICES, under section 1.080 Control program requirements:
7. All gaming devices must have the capacity to display a complete play history for the most recent
game played and nine games prior to the most recent game. Retention of play history for additional prior
games is encouraged. The display must indicate the game outcome (or a representative
equivalent), intermediate play steps (such as a hold and draw sequence or a double-down sequence),
credits available, bets placed, credits or coins paid, and credits cashed out. Gaming devices offering
games with a variable number of intermediate play steps per game may satisfy this requirement by
providing the capability to display the last 50 play steps.
NanoTech Gaming
7180 Dean Martin Drive Suite 300
Las Vegas, NV 89118
Stephen Riesenberger – Creative Director
stv@nanotechgaming.com
NanoTech Gaming’s first two casino games, “Vegas2047” and “CasinoKat” were created with
the full capability of complying with this standard.
The technology that makes this possible is not new, and has gained popularity through
recording and playback of performances in traditional videogame platforms like the Multiple
Arcade Machine Emulator (MAME) and the MAME Action Replay Page (MARP). The technology
records every player input with timestamped data which can be replayed to produce
a complete play history, showing the game outcome and all intermediate play steps, not just
the last 50 play steps. We believe that the current technical standard is insufficient to provide
fair and robust review of a game’s play history.
With the intent of skill-based gaming to provide a more interactive experience for the player,
and to protect them as well as the operators from exploits of bugs or loopholes in the game’s
code, we believe it is necessary that all skill-based games adhere to a standard which requires
the full and complete play history, showing all intermediate play steps, that is logically viewed
as a game replay; simply displaying a list of player inputs and timestamps for a traditional
videogame is nearly impossible to make sense of.
“Vegas2047” and “CasinoKat” have the capacity to recall and playback the full and complete
play history in a game replay for the most recent game played, the nine games prior to the
most recent game, and all games for several years’ worth of continuous operation, only limited
to the internal storage capacity of the hard disk drives in the machines.
We believe that adopting the language highlighted in green above will protect both players
and operators, will quickly uncover flaws in the game code or unintended play behaviors which
could result in exposure to the operator or game malfunction.
NanoTech Gaming applauds your work with skill-based gaming. Please consider our company as
a resource for any further information in this regard.
Sincerely,
Stephen Riesenberger
December 16, 2015
Mr. Stephen Crosby
Chairman
Massachusetts Gaming Commission
101 Federal St., 12th Floor
Boston, MA 02110
Via email: mgccomments@state.ma.us
Re: Support for Skill-Based Gaming / Variable-Payback Slots
Dear Chairman Crosby:
I am the Executive Director of the Association of Gaming Equipment Manufacturers (AGEM) and thank
you for the opportunity to comment on the future of gaming in Massachusetts.
AGEM is a non-profit international trade association representing manufacturers and suppliers of
electronic gaming devices, systems, lotteries, table games, and components for the gaming industry.
AGEM works to further the interest of
NanoTech Gaming
December 8, 2015
Via Electronic Mail
Bruce Band – Assistant Director of Investigations and Enforcement Bureau
Massachusetts Gaming Commission
101 Federal Street, 12th Floor
Boston, Massachusetts 02110
bruce.band@state.ma.us
Re: A Request for Public Comment: Skill Based Gaming
Dear Director Brand,
As Creative Director for NanoTech Gaming, I have ensured that my company has been at the
forefront of recent changes to Nevada Gaming Regulations. We have always made our
expertise in skill-based games available for furthering the discussion.
With regards to Massachusetts adopting regulations regarding skill-based gaming, we are also
willing to participate in your process, and honored to be included in the request for comment.
To the specific points of your email request:
• Areas where GLI-11 as it presently exists (or other applicable GLI standards) are
insufficient to provide for the regulation of skill based gaming devices;
o In 3.4.1a, Optimum Play Used for Skill Games we read: Gaming devices that may
be affected by player skill shall meet the requirement of this section when using a
method of play that will provide the greatest return to the player over a period of
continuous play.
At NanoTech Gaming, we have experimented with what we call the ‘effect of skill’ on the
observed payback percentage. The subsection above indicates that an ‘optimum play’ method
should be the standard by which this requirement is met. However, we believe that the 75%
minimum payback should be a standard for all new skill-based games. A clear example of how
only looking at ‘optimum play’ could damage player perception of skill-based games is found in
the example of Video Poker.
NanoTech Gaming
7180 Dean Martin Drive Suite 300
Las Vegas, NV 89118
Stephen Riesenberger – Creative Director
stv@nanotechgaming.com
In a Jacks-or-Better Video Poker game, skilled players will use the ‘optimum play’ method, and,
with little to no mistakes, earn a payback that is well above the 75% minimum. In contrast, a
player who is unskilled at Video Poker and not knowledgeable of the game rules could play the
game by drawing 5 additional cards each game. A player who demonstrates this lack of skill
would earn a payback far below the 75% minimum – at worst case a Wizard of Odds study put
the payback somewhere around 3%.
Because my company is focused on bringing skill-based games to casinos where physical
dexterity is the means by which the player is judged, we are convinced that penalizing the
player in the same way Video Poker does for lack of skill would result in an extremely
dissatisfying experience for new players.
o In 3.17.2, Last Play Information Required we read: Last play information shall
provide all information required to fully reconstruct the last ten (10) games. All
values shall be displayed; including the initial credits or ending credits, credits
bet, and credits won, payline symbol combinations and credits paid whether the
outcome resulted in a win or loss. This information can be represented in
graphical or text format. If a progressive was awarded, it is sufficient to indicate
the progressive was awarded and not display the value. This information should
include the final game outcome, including all player choices and bonus features.
In addition, include the results of double-up or gamble (if applicable).
The Nevada Gaming Control Board recently amended their technical standards to address this
section under STANDARD 1 INTEGRITY OF DEVICES, under section 1.080 Control program
requirements:
7. All gaming devices must have the capacity to display a complete play history for the most
recent game played and nine games prior to the most recent game. Retention of play history for
additional prior games is encouraged. The display must indicate the game outcome (or a
representative equivalent), intermediate play steps (such as a hold and draw sequence or a
double-down sequence), credits available, bets placed, credits or coins paid, and credits cashed
out. Gaming devices offering games with a variable number of intermediate play steps per
game may satisfy this requirement by providing the capability to display the last 50 play steps.
We drafted a letter to Technology Division Chief Jim Barbee pointing out that even this new
standard may not be sufficient in the face of highly complex, physics-intensive, and chaotic skillbased
games (a copy of our letter is attached). Even though Chief Barbee noted our comment,
he believed that the language drafted above would be sufficient for the time being.
NanoTech Gaming
7180 Dean Martin Drive Suite 300
Las Vegas, NV 89118
Stephen Riesenberger – Creative Director
stv@nanotechgaming.com
• Whether the Commission should set a maximum tolerance for skill based games
o It’s unclear what your definition of ‘tolerance’ is here; whether it pertains to the
tolerance of the maximum degree to which skill is allowed to affect the outcome,
or the tolerance of the maximum payback which may be achieved based on skill
If ‘tolerance’ refers to the maximum degree to which skill is allowed to affect the outcome, to
our previous point regarding 75% minimum payback, we have developed a patent-pending
system – the NanoTech Advantage – which allows the player to adjust this skill effect from 0%
to about 25%. In this case, the ‘maximum tolerance’ for skill to affect the outcome is about
25%. Percentages higher than this maximum would reduce the payback for unskilled players,
and is a dissatisfying experience in our observed tests.
If ‘tolerance’ refers to the maximum payback which may be achieved based on skill, this refers
to GLI-11 section 3.4.1a on ‘optimum play’. Using our NanoTech Advantage system, a range of
possible payback percentages is displayed to the player before starting a game. This range is
based on the history of previous player scores and bets, and the player’s chosen bet amount,
goal win amount, and the effect to which skill will influence the outcome.
Using Nevada state minimum payback of 75%, in an example where the casino wants a Return
to Player of 99%, the ‘maximum tolerance’ for an instance of a wager is 123%; the sum total of
all wagers made on the machine will never return more than 99% to the players in this
example.
• Unique issues involving skill based gaming devices that require clarification from the
Commission.
We exhibited our games and gambling technology at the Global Gaming Expo in October of
2015. We also saw a number of other gaming companies exhibiting their ‘skill-based’ game
machines. However, none of the manufacturers could succinctly explain how a very skilled
player could see a benefit for demonstrating their skill. Many of the games featured math
models which were based on existing slot machine models, where the payback for very skilled
players is still well under 100%, and players who lack skill will be penalized.
We believe that games like this that operate on deception, or ‘illusion of skill’, or utilize slotmachine-style
‘redemption wins’ (which are actually net losses) are designed to perpetuate the
status-quo of slot machine manufacturers.
At NanoTech Gaming, we are offering the first opportunity for players to gain value for
demonstrating their physical skill at playing videogames, combined with casino math, which
also guarantees that there is no exposure to the operator due to pricing errors, or extremelyskilled
players, or those who exploit the game to earn high scores.
NanoTech Gaming
7180 Dean Martin Drive Suite 300
Las Vegas, NV 89118
Stephen Riesenberger – Creative Director
stv@nanotechgaming.com
We appreciate this opportunity to share knowledge, and look forward to your response.
Sincerely,
Stephen Riesenberger
NanoTech Gaming
7180 Dean Martin Drive Suite 300
Las Vegas, NV 89118
Stephen Riesenberger – Creative Director
stv@nanotechgaming.com
NanoTech Gaming
October 30, 2015
Via Electronic Mail
Jim Barbee – Technology Division Chief
NEVADA GAMING CONTROL BOARD
555 E. Washington Avenue, Suite 2600
Las Vegas, NV 89101
jbarbee@gcb.nv.gov
Re: Request for Industry Comment for Proposed Changes to Technical Standards for Skill
and Hybrid Gaming Devices
Dear Chief Barbee,
NanoTech Gaming is focused on bringing skill-based games to casinos, and committed to
ensuring that gaming regulations and technical standards are created not only to protect the
players and the operators, but to increase gaming revenue for the state of Nevada and the
casino industry worldwide.
Reading through the current and proposed language of the technical requirements, we have
concern over the requirements set forth in the first four sentences of STANDARD 1 INTEGRITY
OF DEVICES, under section 1.080 Control program requirements:
7. All gaming devices must have the capacity to display a complete play history for the most recent
game played and nine games prior to the most recent game. Retention of play history for additional prior
games is encouraged. The display must indicate the game outcome (or a representative
equivalent), intermediate play steps (such as a hold and draw sequence or a double-down sequence),
credits available, bets placed, credits or coins paid, and credits cashed out. Gaming devices offering
games with a variable number of intermediate play steps per game may satisfy this requirement by
providing the capability to display the last 50 play steps.
NanoTech Gaming
7180 Dean Martin Drive Suite 300
Las Vegas, NV 89118
Stephen Riesenberger – Creative Director
stv@nanotechgaming.com
NanoTech Gaming’s first two casino games, “Vegas2047” and “CasinoKat” were created with
the full capability of complying with this standard.
The technology that makes this possible is not new, and has gained popularity through
recording and playback of performances in traditional videogame platforms like the Multiple
Arcade Machine Emulator (MAME) and the MAME Action Replay Page (MARP). The technology
records every player input with timestamped data which can be replayed to produce
a complete play history, showing the game outcome and all intermediate play steps, not just
the last 50 play steps. We believe that the current technical standard is insufficient to provide
fair and robust review of a game’s play history.
With the intent of skill-based gaming to provide a more interactive experience for the player,
and to protect them as well as the operators from exploits of bugs or loopholes in the game’s
code, we believe it is necessary that all skill-based games adhere to a standard which requires
the full and complete play history, showing all intermediate play steps, that is logically viewed
as a game replay; simply displaying a list of player inputs and timestamps for a traditional
videogame is nearly impossible to make sense of.
“Vegas2047” and “CasinoKat” have the capacity to recall and playback the full and complete
play history in a game replay for the most recent game played, the nine games prior to the
most recent game, and all games for several years’ worth of continuous operation, only limited
to the internal storage capacity of the hard disk drives in the machines.
We believe that adopting the language highlighted in green above will protect both players
and operators, will quickly uncover flaws in the game code or unintended play behaviors which
could result in exposure to the operator or game malfunction.
NanoTech Gaming applauds your work with skill-based gaming. Please consider our company as
a resource for any further information in this regard.
Sincerely,
Stephen Riesenberger
December 16, 2015
Mr. Stephen Crosby
Chairman
Massachusetts Gaming Commission
101 Federal St., 12th Floor
Boston, MA 02110
Via email: mgccomments@state.ma.us
Re: Support for Skill-Based Gaming / Variable-Payback Slots
Dear Chairman Crosby:
I am the Executive Director of the Association of Gaming Equipment Manufacturers (AGEM) and thank
you for the opportunity to comment on the future of gaming in Massachusetts.
AGEM is a non-profit international trade association representing manufacturers and suppliers of
electronic gaming devices, systems, lotteries, table games, and components for the gaming industry.
AGEM works to further the interest of
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