Last month the International Masters of Gaming Law (IMGL) held their Winter Conference in New Orleans, where W. Owen Nitz and Jeffrey M. Cooper, were honored as the 2006 gaming executives of the year.
The keynote presentation made by Nitz was thought invoking, as the history of the IP and rebuilding of the Gulf Coast were the primary theme. Nitz spoke of the contributions made by the industry to achieve the rebuilding process, and how the IP and other gaming operators supported their employees throughout the process. New Orleans was also a gleam, and the people—working people whom I came in contact with during the IMGL conference—were an example of the future of their city.
Real World Game Technology
During the many interesting presentations during the IMGL winter conference, there was a panel moderated by Robert W. Stocker II, partner, Dickinson Wright PLLC and vice president of the IMGL, on “The Real World of Gaming Technology.”
The panelist were: Kevin Molloy, general counsel and director of governmental affairs for Gaming Laboratories International; Larry Gregory, executive director for the Mississippi Gaming Commission; Tina R. Singletary, lawyer for Singletary & Thrash, P.A.; Jerry Smith, Sr. VP and general counsel for Shuffle Master, and myself. The panel focused on “the realities of dealing with state gaming labs and getting new technology to market in a reasonable time,” which ultimately impacts the use and adaptation of emerging software and hardware solutions.
During our discussion, the concern and impact of informing and educating employees on the limits of technology were addressed. Some interesting elements we considered include: how to regulate technology; how to standardize certification; software; mathematics; and networking/communications versus empowerment of financial transactions and accountability.
Most of these elements are server based technologies and are administered by a property’s IT personnel, which increase the need for secure network access and firewalls between systems.
Our IMGL panel also talked about perhaps the greatest technological adaptation today: digital video recording (DVR) of CCTV surveillance and security cameras. DVR is often more available for systems integration. Can your archived DVR tapes in the form of RAID 5 or SANS (storage area networking systems) really be associated with player tracking for slot machines, table game data, POS (point-of-sale or cash register) data, or financial transactions of sophisticated video analytics?
Fairness and Integrity
My answer to these questions is that responsible manufacturers should be able to provide answers and should demonstrate how they achieved them and with what systems. A complicated answer for a sophisticated solution does provide some level of empowerment and responsibility. The consensus of our panel during IMGL’s Winter Conference was: does an associated system like DVR technology or video analysis add or detract from the integrity of the game, and is it “fair?”
The idea is to formulate the answers when the technology is applied and discover how to establish accountability to overcome the aspects of the new data (in this case video analysis).
Recently, one well-known Nevada Gaming Control Board (NGCB) enforcement agent advised how table games personnel might use this new knowledge to impact outcomes, or the “fairness” of the games. The NGCB enforcement agent is correct to have these concerns, as there are no standards for how the technology should be controlled or limited.
As the director of gaming for a DVR manufacturer, we must also take fairness and how outcome is or is not influenced into consideration before creating new technologies. This thinking would lend itself to early adoption of technology by the regulators, and contribute to the “approval process” for “the realities of dealing with state gaming labs and getting new technology to market in a reasonable time.”
This thinking would also contribute to the education process for security and surveillance executives, who would later manage the new systems used specifically on table games or slots, but offer an association to the recorded video that is now managed by enterprise class DVR systems.
Server to Server and Meta-Data
Servers connecting to servers and immediate access to “meta-data” (data collected by business and marketing systems on all types of transactions) in turn would provide the link to the video evidence. This video recorded on a closed DVR network that only surveillance, security, investigators, and regulatory entities should have access to, meets the “legal challenge” of the courtroom for criminal and civil matters.
These videos include something as simple as a claim made by a player, or as sophisticated as a gaming scam or crime that usually involves some form of forensic accounting and video to provide proof, as opposed to the analytic video data, which usually provides an analysis of the image combined with another form of technology like RFID (radio frequency identification) embedded into gaming devices.
These devices can include the chips (gaming cheques) and in the future, undoubtedly other applications. These technologies usually lend themselves to accurate identification of values or assets, and can include human behavioral analysis to provide “alerts” or notification that something has happened from a known list of “filters” or “malfunction codes” that are linked to the live and recorded video for the area of concern.
Most of these technologies require a field of view on the camera sensor that can be interpreted by the computer software. The link to the live camera and to the archived video library is then achieved by associating the two applications together; easy to say, but not so easy to achieve.
Associated Systems
Then add the cost of “associated systems” (a system that does not change or alter the outcome of a game, but associates the application to a specific game for data collection purposes), like the commonly known Slot Tracking Systems. These associated systems usually “empower” the revenue department with player data and sometimes security features of each slot machine. The systems are layered as modules, or secondary components, to the machine or game and do not impact the known “outcomes,” which are whether someone won or lost usually followed by the data associated with wagers and financial outcomes.
This is over-simplifying a very complex process and then meeting standards with each regulated area.
DVR Standards and Regulations
In DVR applications, the regulators have established standards for recording frame rates (fps), meaning the real-time versus reduced time-lapse recording. Today’s fps is 30 in the U.S., or 25 ips (images per second). Outside the U.S., resolution of clarity is usually defined as 4 CIF that is at least 704 x 480 pixels; in Nevada, it is based on early adoption of VCR video (where “the clarity to determine the outcome of the game was 30 ips”). Although 4 CIF and an associated frame rate of 20 to 30 fps has been an accepted standard throughout the world.
Many regulations require that only surveillance and security have access to their cameras and their recorded video, or what is called a “closed network” also restricts access to review surveillance video and surveillance rooms.
Math
These regulations safeguard the integrity of the games and visually document the outcomes and fairness of the games. Games also have rules governed by mathematics for the odds of winning. In the past this was a straightforward process; technology has changed this playing field, and we will continue to discover the weaknesses of some new systems.
TITO Crimes
In most cases, TITO still requires collusion with an employee to be successful: We have seen abuses of slot clubs which are a result of player tracking systems; We have seen comp scams associated with even the most archaic table games rating systems; so why wouldn’t we expect to see some type of a scam develop from the more sophisticated computer analysis of games?
Better Analytics
One answer is that we use more than one sense to achieve a decision. Today our sense of sight is evolving in the CCTV surveillance applications, which in the past were, at best, only an extension of our un-aided eye.
Now these analytics provide better visual acuity much like glasses, binoculars, and now the microscope (an electron-microscope). Add to this RFID, which is like the sense of smell combined with application of rules to tell us outcomes, or the sense of hearing which we can now use to make decisions based on applying “computer senses,” or adding software to interpret what we have been looking at already.
The CCTV surveillance applications allow us to view the video in a much more timely and accurate manner than previously achieved. Studies have shown the typical surveillance or security officer can not maintain 100 percent observation and when searching days of video for a single event over a camera population of 500 or more cameras, it makes sense when we read “inconclusive” reports. (This was discussed at the G2E during the presentation, “Video Analysis: Investigative Resources,” provided by Ian Ehrenberg, VP and GM of Nice Systems Inc. and sponsored by the Gaming & Wagering Protection Council of ASIS International.)
Empowering Operator and Player
The panel at the IMGL Winter Conference prompted us to consider the role the manufacturer plays and the impact the technology provides for “empowerment” of the operator and the player. We need to better understand the role of the regulator and the importance of meeting their challenge to provide a “fair” game, or associated process that will benefit everyone if understood by all. Abuse can be detected, whether it is the player or the operator. Only then can we have a go-to market relationship with state gaming labs and regulators that will benefit the properties and the player.
Douglas L. Florence Sr., CPP, is a Surveillance and Security subject executive with more than 30 years of comprehensive security experience in security management, surveillance, investigations, systems integration and consulting. He can be reached at battleborn@mindspring.com.
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