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Sunday, February 28, 2010

Casino Wager Tracker

Casino wager tracker by "Squigg" is a very useful little software utiliy that records your blackjack wagering, either for the purpose of tracking bonus wagering requirements or simply as a statistical record of your play.

Casino Wager tracker

From the launch screen, click on "start new session" -

Wager tracker start screen

Fill in the details and click "start", which takes you to the screen where you can start recording your blow by blow results, after you select a bet size from the "wager" menu -

Wager tracker results input window

Click the "statistics" link at the bottom right of the input screen and you bring up a statistical analysis screen for your session - full breakdown of results both numerically and graphically, highs and lows, percentage return, an approximation of the standard deviation / probability and an option to view your results as a graph -

Wager tracker stats

Just about everything you could want to know.

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Thursday, February 25, 2010

Grand Prive affiliates and eCOGRA: follow-up from the chaos resulting from the audit

This article follows on from my most recent Grand Prive affiliate issue comments of six days ago.

To sum up the recent events: after eCOGRA issued its findings on their audit of the Grand Prive affiliate programme, there was general outrage from all involved parties on the basis of the derisory amounts of compensation that were offered. It turned out that the most likely reason for this was the existence of a previous affiliate programme, one Referspot, whose accounts had not been examined and from which the majority of the affiliate earnings had been generated.

eCOGRA CEO Andrew Beveridge responded thus to a query from the owner of the GPWA affiliate organisation:

We have noted your concern raised as to the adequacy of the settlement amount recommended by the eCOGRA investigators.

We would like to emphasise that our mandate from Grand Prive was to review all records provided by the company in respect of the Grand Prive Affiliate Program software and related database. We were not requested to review any other affiliate program system or information, nor were we made aware of any other system or pertinent information.

We are confident that the settlement amounts have been correctly calculated based on our mandate and the affiliate and player data provided to us by Grand Prive at the time of the review. Regrettably we cannot legally perform any further investigation work into this matter unless mandated by Grand Prive management. Such a mandate has not to date been forthcoming.

And that was that. The audit that wasn't an audit. The audit that didn't really audit anything, because there was nothing of any substance to audit.

In response, the GPWA owner had this to say, which I quote here in part:

22nd-February-2010, 05:32 PM

From my perspective Grand Prive just spat in the eye of eCOGRA. And they spat in the eye of Microgaming too.

I don't quite agree with this comment.

Grand Prive didn't spit in the eye of eCOGRA. This implies victimhood, and eCOGRA are not victims in this. eCOGRA could have set out to insist on full access. That said, if they were lied to, if data was withheld, then eCOGRA are not to blame in the first instance. But they now know the facts, and are fully conversant with the nature of the problem.

Yet, as noted in their above comments, they consider their task complete.

At this point, they are no longer blameless. They are a part of the problem. That they could only work with the data they were given is a empty excuse. You either audit everything or nothing, and less than everything is, to all intents and purposes, nothing.

If you audit only the tied bets of a casino's monthly wagering statistics, then it would appear that nobody had won or lost anything, casino and players alike. This would be pointless and misleading, but it would nonetheless be in keeping with the remit of an audit based on the premise of data provided.

This is essentially what eCOGRA has done - audited the pushes and ignored the wins and losses. And it was equally pointless.

I'm also not especially sold on the idea of Grand Prive spitting in the eye of Microgaming. A child can spit in a parent's eye, but this is a rather futile gesture of disobedience, as the parent holds the ultimate power and the child is unlikely to emerge happily from the act. Much the same goes for a licensee of a software provider - the provider holds all the keys.

Microgaming and eCOGRA have not been disrespected by Grand Prive, because Grand Prive is simply in no position to do so. Microgaming can, at any time, revoke the casino group's license, and eCOGRA can, at any time, revoke their "play it safe" seal.

They have all the power, and Grand Prive has none.

And yet, Grand Prive is still a Microgaming licensee, in full possession of the eCOGRA "quality" seal. As such, Microgaming and eCOGRA are not victims of eCOGRA, but rather, complicit in their deception.

The GPWA boss goes on to ask:

What do you think are the odds eCOGRA and Microgaming will just wipe the spit off their eyes and pretend nothing happened over the long term?

Certainly, their subsequent reaction does determine their complicity. Am I being too hard on them? Will Microgaming pull the license, and will eCOGRA insist their "play it safe" seals be removed?

Possibly telling is a reaction from self-proclaimed player watchdog Bryan "Casinomeister" Bailey to the situation:

24th February 2010, 11:12 AM

It's pretty much clear to me that the operators of Grand Prive are the sole offenders in this unprecedented eff-up. I don't see how eCOGRA or MGS can be thrown into the same blame pit.


One can dwell on the fairness of accusing people who have been mistreated as "whining"; on the assertion that the eCOGRA audit-that-wasn't-an-audit was in fact "fair"; that eCOGRA is not to blame for sheer lack of focus; and that Microgaming is guiltless because noone has actually spoken to them about it, when in truth Microgaming has in fact specifically ducked or ignored all attempts to raise the matter with them - more on this in a later article.

But putting all that aside, you could fairly say: the above comments represent the industry position.

And as such, I suspect that the hypothesis above regarding Microgaming and eCOGRA's reaction to being ostensibly spat at, or otherwise disrespected, by Grand Prive, will prove to be correct, and the people who hold the keys to Grand Prive's office will do nothing.

To quote one more industry stalwart:

22nd-February-2010, 03:24 PM

It thus appears that Microgaming is at least a compliant party and not just an onlooker. Microgaming is perfectly able to act in favor of ethical treatment of affiliates in this case.

IMO the ball is in Microgaming's court now.

Personal observation: So much for self policing of the industry. I am not so sure I want to be part of this industry anymore.

I agree on all counts. Microgaming is complicit, but has the opportunity to act fairly. It seems unlikely they will, which will further testify to the online gambling industry's ability to police itself.

After the Kahnawake Gaming Commission's unexpected step forward in recent days, it's a shame that players regarded as such leading lights of the industry are shown up to be so inadequate.

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Sunday, February 21, 2010

Jackpots Heaven Casino threatens webmasters on the basis of the publishing of libelous information

Jackpots Heaven Casino has recently been issuing threats against some webmasters on the basis of allegations that the casino regards as libelous: that the casino software uses games copied from established software providers Realtime Gaming and Microgaming, and is as such in breach of copyright law.


There is an alleged connection between Jackpots Heaven and little-known software provider Salus Technologies, whose games list shows many games which appear to be copies of games originally developed by Microgaming and RTG. As such, Salus Technologies is almost certainly in breach of copyright.

The connection between Salus Technologies and Jackpots Heaven is not currently verified to my complete satisfaction, but the indicators are strong: emails from Jackpots Heaven have apparently originated at servers belonging to Salus Technology, and there is compelling evidence that at least one slot game, "Caesar's Empire", until not long ago listed in the Jackpots Heaven games list page, is the property of Realtime Gaming.

As such, it looks very likely that the webmasters' allegations are founded.

Here is one version of the threatening letter currently in circulation:

Jackpots Heaven Casino OPU threat

Please stop spreading false rumors by opening new threads on forums. This is a friendly warning to advise you to STOP NOW. We know you live in USA and you will be help (sic) responsible for every post you have made with false information which ruine (sic) our business.

I assure you that your fees you charge to damage our casino reputation will be dwarfed by the legal fees to oppose our lawsuits. If you have an in-house attorney, I recommend that you forward this email to that office NOW.

We wish you only the best going forward and regret we must resort to this form of communication.

If you have any further questions, please do not hesitate to contact me.


Andrew Fenech

Public Relations


Software provider Microgaming long ago lost any claim to my sympathy. In recent times, the collapse of two of its largest poker rooms, Tusk Gaming and Eurolinx, resulted in losses to players running to millions of dollars, and Microgaming has refused to acknowledge any responsibility in the matter nor issue any meaningful comment. As to Realtime Gaming, their licensees have been causing problems for players from the moment this provider opened its doors for business.

I will not waste my time worrying about potential breach of their copyright until such a time as both these providers start to take their responsibilities a bit more seriously.

However, other webmasters are welcome to hold their own opinions, and if such opinions result in factually-supported material being published on the web, they do not deserve to find themselves the recipients of such unpleasant and unfounded legal threats.

Rather, Jackpots Heaven should conduct its business in such a way as to not illicit such comment in the first place. I'm sure everyone would be happier.

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Thursday, February 18, 2010

Kahnawake Gaming Commission: an unexpected step forward

There's something in the air; over the space of just three weeks, two online gambling regulators have done what I had long considered would never happen this side of the next millenium: on the basis of complaints received, they issued comprehensive and detailed findings, and delivered sound, fair judgements. Not only that, but the judgements favoured the complainants - the players.

The first I narrated in my Bet365 article. This involved an established advertising ombudsman whose judgement, though remarkable in a gambling context, was not particularly unusual when viewed as a part of the day to day work of a company that upholds complaints on a regular basis (for more details on this, see the ASA adjudications page).

The next judgement was a horse of a different colour.

I received a complaint from a player who'd had a €10,000 winning cashout withheld by UK Casino Club, part of the Casino Rewards network.

The problem was that he had infringed a bet size restriction found in the general terms and conditions, to the effect that placing bets greater than 30% of the total bonus amount would result in confiscation of winnings:

The Casino reserves the right to withhold any withdrawals and/or confiscate all winnings for irregular play. 'Irregular play' includes but is not limited to any one or more of the following types of play:

Placing single bets equal to or in excess of 25% or more of the value of the bonus credited to the account prior to the play-through requirement for that bonus having been met.

The player argued that this very important term was not listed alongside all the other relevant bonus information on the bonus page, and neither was there a link to it in the terms. Since it wasn't there, he argued that he should not be held to it.

Here's a screenshot of those terms as they were at the time:

UK Casino Club bonus terms

I agreed with him - to me, this appeared an act of deception by the casino. Why place all terms bar one on one page, but relocate one of the most vital terms to another?

Was the casino trying to conceal this term?

The player mentioned filing a complaint with the Kahnawake Gaming Commission, as UK Casino Club is located in their jurisdiction. With some knowledge of the operational standards to date of the KGC, I suggested that this was a complete waste of time.

On February 8th, I posted a UK Casino Club and Casino Rewards discussion at the GPWA to air the matter, and members were supportive almost to a man. The Casino Rewards affiliate rep, however, reinforced the company line that the player had effectively signed away his rights to receiving his money on agreeing to the terms and conditions when he signed up his account, irrespective of the placing of the terms.

However, a few days later, the casino had in fact chosen to place a link to the section containing the term in question within the bonus terms page - note that term "13" has now appeared:

updated term placement

In the meantime, the player filed his Kahnawake complaint, something I had already signed off as an excercise in pointlessness. The player proposed that the casino either pay him half his balance, or return the full amount to his account with the stipulation of a large additional wagering requirement. I supported both suggestions.

To my complete astonishment, the Kahnawake disputes representative delivered her verdict just eight days later, in favour of one of the proposed resolutions:

Hans N complaint against UK Casino Club

As the Commission's Dispute Resolution Officer, I have had numerous communications with the complainant, Hans N, and with UKCasinoClub (the "Casino") concerning a complaint lodged by Mr. N against the Casino.

We have now finally completed our investigation into this complaint and are prepared to direct Mr. N's complaint be resolved as follows.

We have taken several factors into consideration in reaching our decision in this matter.

Clause 13 of the Casino's Terms & Conditions (the "T&C") states as follows:

"The Casino reserves the right to withhold any withdrawals and/or confiscate all
winnings for irregular play. 'Irregular play' includes but is not limited to any one or more of the following types of play:

i. Placing single bets equal to or in excess of 25% or more of the value of the
bonus credited to the account prior to the play - through requirement for that
bonus having been met;
ii. Using the double-up feature to increase bet values;
iii. Even money bets on Sic Bo, Craps and Roulette"

Mr. N specifically accepted the Casino's T&C, including Clause 13, at the time he registered his account.

After registering his account, Mr. Niemz engaged in a pattern of play that breached Clause 13(i). Mr. Niemz does not dispute this fact.

Mr. N's dispute centres on the argument that, at the relevant time, some additional terms and conditions that were posted on the Casino's site regarding signup bonuses (the "Terms and Conditions - Multiple Bonus Promotion") did not clearly incorporate the provisions of the Casino's T&C.

However, given the fact that Mr. Niemz did accept the T&C and that his pattern of play subsequently breached Clause 13(i) of the T&C, we cannot conclude that it is reasonable to direct the Casino to reimburse Mr. Niemz for 100% of the amount of the disputed amount - 10,000 Euro.

We do accept that the Casino must bear some responsibility for failing to make it clear that the Terms and Conditions - Multiple Bonus Promotion incorporated the provisions of the Casino's T&C.

In view of the foregoing, we hereby direct that:

1. The Casino must, on or before 8:00 p.m ET on February 18, 2010, deposit 50% of the disputed amount - i.e. 5,000 Euro - into Mr. N's account and permit him to withdraw this amount, and

2. The Casino must immediately amend its Terms and Conditions - Multiple Bonus Promotion to clearly indicate that they incorporate the provisions of the T&C.

Given that Mr. N previously chose to make his dispute with the Casino a public
matter, we do not consider the terms of this decision to be confidential.

The Commission's file in this matter is now closed.


Per: Micki Oster, Dispute Resolution Officer

The case was looked at fairly, blame reasonably attributed to both sides, and a sound resolution made.

The KGC has been the butt of my and many others' mirth in the years it's been in operation: flat out ignoring players, giving canned responses apparently cut and pasted from the casino, whitewashing Absolute Poker and effectively ignoring Golden Palace's olympic sabotage stunts to name a few. Not a good track record.

So what happened to make me eat my words?

The answer might partially lie in the current text on the KGC home page:

On behalf of the Kahnawake Gaming Commission, I would like to thank everyone who visited our stand at the 2010 International Gaming Exposition (IGE) held in London from January 26 - 28, 2010. The Commission was well represented at this year's IGE and, based on the high level of interest and positive feedback we received from those in attendance, we consider our participation to have been very successful.

We are presently implementing many new initiatives that will enhance the Commission's ability to better protect players, that will set new and progressive regulatory standards and that will affirm the Commission's position as a leading igaming regulator.

We welcome your feedback and we look forward to seeing you at IGE 2011.

Kahnawake Gaming Commission
Dean Montour, Chairman

So it looks like the KGC is looking to move in a new direction of accountability and responsibility. They've made the right start here, and have sent a message out to their licensees that they're taking a more hands on approach.

The only unsatisfactory aspect of the matter to remain is that UK Casino Club has chosen not to include the "30% maximum bet" rule in with the promotion terms, but to link to it - I checked today, the day after the expiry of the deadline for the implementation of the KGC requirements, and I note that the general terms link has been emboldened, but the contentious term not specified:

latest term placement

This is slightly altered in comparison to the amended version of a few days ago -

updated term placement

I assume therefore that this is the version UK Casino Club and Casino Rewards have decided respects the KGC dictat, and I also assume that the KGC approves. That much is a pity, as I see no earthly reason, other than unpalatable ones, to not include the rule in with all the other terms.

However, as far as the KGC goes and notwithstanding that one remaining niggle, it looks all good at the moment.

If you want to file a complaint with the KGC, fill in the feedback form.

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I don't own Blogger, LOL. However, if you mean with my site here, then no, I'm sorry but I don't link-trade.

By Blogger 100% Gambler, at 2:28 pm  

I would like to exchange links with your site www.blogger.com
Is this possible?

By Anonymous Anonymous, at 4:55 pm  

Can't you read?

See the above response:

>>>>> NO <<<<<<


By Blogger 100% Gambler, at 8:02 pm  

It's worth noting that Casino Rewards has somewhat improved its bonus terms layout. There are now no terms on the bonus invitation page - all are located on one general terms page.

The 25% rule is still consigned to the very bottom of the bonus section of the general terms, but this is still an improvement.

By Blogger 100% Gambler, at 7:07 pm  

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Wednesday, February 17, 2010

Gambling problem in the UK, says report

As reported by the BBC:

Concern grows over gambling in UK

There is growing concern over the number of people turning to gambling to survive the recession, a charity says. Research by Credit Action shows that nearly one in 10 adults in the UK has used gambling in an attempt to manage their finances and make extra money.


In addition to the two evidently useful organisation mentioned in the article, Breakeven and the Gordon Moody Association, see also:

Gamcare. You can contact Gamcare, on 0845 6000 133, post in the forum (you need to register first) or chat online with a Gamcare helper.

Gamblers Anonymous. You can contact GA on the relevant number, post in their rather basic looking forum, or live chat - you can type in any username you like, and you don't need to register.

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Tuesday, February 16, 2010

eCOGRA concludes the Grand Prive investigation, and chaos immediately follows

I reported on the eCOGRA investigation into Grand Privè a few weeks ago.

Yesterday, 15th February, the eCOGRA report on the Grand Prive affiliate programme investigation was released...and immediately provoked quite a storm of controversy.




Further reading

15 February 2010 -

Following a number of Internet-based allegations concerning the closure of the Grand Privé Affiliate Program ('the Program') on 1 December 2008, eCOGRA's Compliance and Advisory Services department was engaged by the management of the company on 17 November 2009.

Pursuant to an independent and fair resolution of the issues involved, eCOGRA was tasked with:

• Independently investigating the manner in which the Program was terminated and the reasons therefore.

• Carrying out a full and independent review of the program software and data to confirm amounts owed to claimants.

• Determining a fair settlement for claimants, taking into consideration the potential lifetime earnings of each affiliate’s respective players; and
• Compiling a full and transparent report which will be publicly released on conclusion of the investigation.

According to our mandate, the following actions were taken in order to ensure the maximum number of affiliates were afforded the opportunity to submit legitimate and verifiable claims:

• On 7 December 2009 both eCOGRA and Grand Privé issued widely distributed press releases advising affiliates of the opportunity to submit claims, and also urging affiliate watchdog organisations to assist in ensuring their respective affiliate members were informed of this opportunity.

• After noting affiliate concerns regarding the limited reach of affiliate representative bodies and webmasters, Grand Privé management expanded the communications exercise by emailing every affiliate who had active players on the Program's records during the 3 months prior to 1 December 2008 when the Program closed; and

• An online Claim Submission Form for affiliates was made available from 7 to 31 December 2009 and claims were collated by eCOGRA.

Our investigation included confirming the accuracy and completeness of the database list of emails used in the expanded communications exercise in 2. above.

Our findings are as follows:

1. Termination of the Affiliate Program and reasons therefore:

Following various meetings with management and an onsite investigation at the Grand Privé operational base during the months of January and February 2010, an inspection of supporting evidence allowed eCOGRA to substantiate that:

• For commercial reasons, in August 2008 a decision to close the Program effective 1 December 2008 was taken.

System problems were being experienced on an ongoing basis due to the Program using software in Beta testing. In order to maintain the integrity of the data three permanent employees were required to manage the Program software. In addition the software provider was required to spend an extensive amount of time assisting and troubleshooting ongoing system problems. This resulted in escalating costs, deteriorating service levels and reputational damage.

Due to the high operational overheads and the relatively small portion of income being derived from the affiliate business associated with the Program, losses were incurred by the Program over a period of more than 12 months.

After carefully considering alternative courses of action, management decided to close the Program in order to protect other areas of the organisation from further losses.

• All affiliates were informed of the intended closure by email on 7 November 2008 and encouraged to move their accounts and players to the Villa Fortuna Affiliate Program, which used improved affiliate program software. A follow up email with the same message was sent again on 21 November 2008. Termination was conducted according to the termination clauses stipulated in the affiliate contracts.

• During November 2008 management entered into mutually agreed compensation arrangements for related future player activity with the majority of affiliates who at that time had players considered to be reasonably active. We have however confirmed that certain affiliates were overlooked in this process.

• On 1 December 2008 all affiliates were paid November commissions, and the Program was officially closed.

2. Review of the program software and data to confirm amounts owing to claimants

58 claims were submitted to eCOGRA, of which 7 were found to be invalid, and 26 earned commissions during the period 1 December 2008 to 31 December 2009. The following steps were taken by two eCOGRA employees, both qualified Chartered Accountants with substantial industry experience, in order to substantiate amounts owing to claimants during this period:

• A comprehensive completeness and accuracy audit on the affiliate database provided by the Program was conducted.

• The relevant claimants' information was located in the database and information used for the linking and tracking of players associated with the claimants was obtained, in part using information supplied in the claim submissions received from affiliates.

• This information was used to manually source all players linked to the relevant claimants within the casino back office database.

• The underlying data for the players linked to the relevant claimants was scrutinised to identify players who were still active in the period 1 December 2008 to 31 December 2009.

• The actual commission amounts per affiliate were then recalculated using the gaming data, from 1 December 2008 to 31 December 2009, for the linked active players.

3. Determination of a fair settlement for claimants

We have been able to accurately calculate the commission accruing to each claimant for the period 1 December 2008 to 31 December 2009.

In order to take into account any potential future earnings, we have added to this amount an additional commission amount for any claimant's players that were active during the 6 month period prior to 31 December 2009. The effect of this is that we have implied an average lifetime value for each of these players of at least 3.5 times the actual2 average lifetime of all Grand Privé players.

In our opinion, this is fair and reasonable compensation for the likely future earnings of these players.

We wish to thank all those representing affiliates' interests for their feedback and support throughout the investigation. We would also like to note that the investigation team received the full cooperation of the Grand Privé management.

A little history of eCOGRA's involvement.

Towards the end of 2009, affiliate interest watchdog Affiliate Guard Dog had been engaging with Grand Privè, with a view to resolving the conflict by conducting an audit of the affiliate programme in question. eCOGRA was mooted as a possible auditor, but rejected on the basis that their close ties with Microgaming represented potential impartiality.

However, in their Grand Prive and eCogra announcement of December 11th, AGD explained that Grand Privè had rejected their services and engaged eCOGRA directly themselves, ending at a stroke the prospect of a genuinely impartial set of eyes on the process.

Why they chose to do this remains unclear. However, assuming it wasn't based on a desire to keep any and all data concealed from the view of anyone outside the immediate Microgaming family, it was a very strange decision, as to let the AGD team in would have ended any possible suggestion of lack of impartiality of the investigation.

Neither eCOGRA nor Grand Privè have ever explained why they chose to keep the trusted affiliate auditor at arms' length.

In the report, eCOGRA refers to "technical system problems" in the old programme, and that affiliates were encouraged to move to promoting new casino Villa Fortuna, which was, apparently, problem-free:

System problems were being experienced on an ongoing basis due to the Program using software in Beta testing...all affiliates were informed of the intended closure by email on 7 November 2008 and encouraged to move their accounts and players to the Villa Fortuna Affiliate Program, which used improved affiliate program software.

Why not simply shift the ostensibly "clean" Villa Fortuna programme back to application of the original casinos? Why simply dump the other casinos? The new programme could only have made more money with all the other casinos included.

This I find odd.

Another worrying statement:

58 claims were submitted to eCOGRA, of which 7 were found to be invalid1, and 26 earned commissions during the period 1 December 2008 to 31 December 2009.

The first issue is that claims had to be submitted at all. eCOGRA had access to the database; why could they not use this to establish who was owed what?

The second issue was raised by another affiliate organisation manager in this forum post:

"some 26 legitimate commissions were overlooked. These omissions were most definitely unintentional and are regretted."

Unintentional? Are they unable to read the data from their own software? Surely if eCogra representatives are able to do so, then they must have the ability to do so.

eCOGRA is evidently being a tad euphemistic in the use of the word "overlooked". Although, that said, the entire "settlement" claim appears to be something of a farce anyway, with no affiliate acknowledging receipt of such a thing (see point below). As such, how Grand Privè justified their non-actions seems rather beside the point.

This statement is frankly ludicrous:

During November 2008 management entered into mutually agreed compensation arrangements for related future player activity with the majority of affiliates who at that time had players considered to be reasonably active. We have however confirmed that certain affiliates were overlooked in this process.

They refer to the overlooking of certain affiliates, but a satisfactory resolution with the majority.

This simply cannot be.

Not one former member of the Grand Prive programme came forward, in the twelve months or so between the closure of the programme and the launch of the investigation, to claim any form of settlement. Not a single one. None of the many people who complained received any kind of settlement.

Yet eCOGRA claims that a majority was settled with, leaving only an outstanding minority - an absolute reversal of the truth.

Even accepting the caveat that not all affected members would have had "players considered to be reasonably active" as per the stipulation, this claim by eCOGRA is impossible. It may be the case that they are simply passing on a claim from Grand Prive, who are, in their turn, lying; but this would nevertheless represent extremely sloppy investigation on the part of eCOGRA.

eCOGRA says:

The relevant claimants' information was located in the database and information used for the linking and tracking of players associated with the claimants was obtained, in part using information supplied in the claim submissions received from affiliates.

And yet, looking at the immediate fallout from the report, noone received a satisfactory settlement. Clearly, the database is wrong.

On that note, a technicality was raised about the possible loss of data from a predecessor affiliate programme, one "Referspot", which very likely would explain the discrepancy - see this GPWA forum post. This may or may not be the case, but at best some very sloppy accounting has taken place here, on the back of the withholding of vital information on the part of Grand Privè.

And on a sidenote: all this brings the issue of the trusted third party, AGD, back into the frame: their input would have headed off any such discrepancies or red herrings, as well as guaranteeing overall impartiality. The eCOGRA findings fell apart at the seams almost before they were issued precisely because just such a voice was not present.

Even assuming the most cynical of motives for chosing to keep them out, this was a blundering mistake on the part of the Grand Prive / eCOGRA / Microgaming triangle.

At this moment in time, thirty six hours after the release of the findings, eCOGRA appears destined to be going back to the drawing board and redressing the matters resulting from their less than successful accounting practices on view to date, described by one GPWA employee as representing a "botched audit", which seems a pretty fair description.

For discussion on this matter, see also:

Final report: Grand privé affiliates program investigation at CAP

GP claim & eCOGRA at AGD

eCOGRA report on the Grand Privè affiliate programme investigation at Casinomeister

eCogra final report on Grand Prive at the GIA.

(page top)

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Saturday, February 13, 2010

Bet365 bonus offer deemed misleading by the Advertising Standards Authority

As W.H. Auden almost, but didn't quite, say:

Stop all the clocks,
Cut off the telephone,
Prevent the dog from barking with a juicy bone,
Silence the pianos,
And with muffled drum...

...announce the fact that a regulator, the Advertising Standards Authority, has actually just done its job, made a fair judgement based on a sensible adjudication without recourse to "must-back-casino-at-all-costs" mentality, and found for the player, against the casino.

No, I did not write that backwards. I did not say "for the casino, against the player". I wrote it right first time: for the player, against the casino.

Read it and weep, online gambling industry:

ASA Adjudication on Bet365 Group Ltd


A TV ad for Bet365 stated "Back any single winner at 4/1 or more on any race shown live on Channel 4 and we'll give you a free bet to the same stake on the next live Channel 4 race. Your free bet also wins at odds of 4/1 or more, you qualify for a free bet on the next Channel 4 race. Keep backing those winners and we’ll keep giving you free bets!"


Three viewers challenged whether the ad was misleading, because after winning one free bet they were told they could no longer take part in the promotion.


Bet365 said they believed the three viewers had unusual betting patterns and were exploiting the free offer. They believed two viewers were using betting exchanges whereby they could offset the risk of a bet and gain a free bet without risking any of their own money. Bet365 contended that an examination of the customers accounts showed that they bet on races with the same odds and, because they did not bet on all races, said it appeared they were systematically selecting races that allowed them to exploit the free bet offer.

Bet365 stated that the third viewer also made selective bets and suspected they used a betting exchange. They believed the viewer backed horses each way, effectively giving them a bet on the horse both to win and lose, and they were unlikely to lose any money, which was "bad business". Bet365 said their terms and conditions made clear that promotional offers were only available for recreational players and explained they would only take the step of excluding a customer from the offer after a full investigation of their account and historic betting activity. Bet365 said only 2.5% of customers on their database were deemed to be non-recreational and were excluded from offers.

Clearcast said the ad was not directed toward professional gamblers and considered the specific issues raised by viewers about their accounts was a matter between them and the advertiser.



The ASA considered that the ad was likely to be interpreted as encouraging viewers to place successive bets on the condition that if they won they could place a further bet for free. We understood that Bet365 excluded a proportion of customers who they deemed to be non-recreational players; however, we considered that without defined criteria, it appeared that Bet365 had excluded customers from the offer when they were winning or were no longer profitable.

We noted the ad did not state that customers who made each way bets, won frequently on similar bets, or used betting exchanges would be excluded from the offer. Although we understood that Bet365 believed the viewers were exploiting the offer, in the absence of qualification in the ad to make Bet365s limitations on the offer clear, we concluded the ad was likely to mislead.

The ad breached CAP (Broadcast) TV Code rules 5.1.2 and 5.2.3 (Misleading advertising.)


The ad must not appear again in its current form. We told Bet365 to make the limitations of offers clear in future.

Forget about the Kahnawake Gaming Commission, that merry band of tomahawk-toting tribesmen of the Canadian Indian reserve so beloved of crooked online casino operators the world over, who recently told us that the last ten years of fakery and negligence didn't matter, because they'd now turned over a new leaf and appointed eCOGRA, that renowned Microgaming puppet operation of industry whitewash plasterers, to "test compliance of KGC licensees", representing a New Dawn For Kahnawake.

Forget about the Malta LGA, that reknowned Maltese cartel of shady government officials and dark threats, who don't respond to player complaints in anything less than a year, if at all, and who continue to license sportsbooks long after they've stopped paying players - but who are now a new, improved, groovy and cool operation of industry movers and shakers because they've got a hot new director and 335 operations on their books.

Forget about the Alderney Gambling Control Commission, who when just once put to the test, found for the casino because the player obviously abused the bonus, irrespective of the fact that he followed all the rules to the letter.

In fact, you can pick up all those industry fakes and dump them straight in the recycle bin.

Because there's a new man in town, one who doesn't fall over and ask for his tummy to be tickled when an operator tries to pull the wool over his eyes with incoherent, unsubstantiated babbling about "non-recreational players" who were "bad for business", all long after their bets had been accepted and the players had (horror of horrors, kill me now) won.

When this happens, the ASA says "This is what you said, this is what you did, what you did wasn't what you said you'd do, so go take a hike because you're not doing it on our turf".

Wow and double wow. A regulator that does its job. A regulator that, when it says...

Our aim at the ASA is to ensure that consumers do not just enjoy the ads they see, but they can trust them too.

...it actually means it, and stands by its promise by enforcing the rules.

This is some bad news for the online gambling industry if it ever wants to gain a foothold in the United Kingdom. It'll have do what it says it'll do, or face having to stop saying it.

Kahnawake, Malta, Alderney and eCOGRA must be shaking their heads in horror. What will their world come to if their industry ends up having to stand by its promises and pay what it says it'll pay?

Putting the irony aside, it bears reading again the ruling the ASA made, as their clarity of perception is spot on:

We understood that Bet365 excluded a proportion of customers who they deemed to be non-recreational players; however, we considered that without defined criteria, it appeared that Bet365 had excluded customers from the offer when they were winning or were no longer profitable.

We noted the ad did not state that customers who made each-way bets, won frequently on similar bets, or used betting exchanges would be excluded from the offer.

Although we understood that Bet365 believed the viewers were exploiting the offer, in the absence of qualification in the ad to make Bet365s limitations on the offer clear, we concluded the ad was likely to mislead.

Job well done, ASA. Job well done indeed.

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Aah, so you noticed it then.

By Blogger Sandracer, at 7:25 pm  

Your enthusiasm for the ASA is a little misplaced I feel. They're not a regulator, and all they can do is ask for an advert not to be repeated in exactly the same way as the one complained about.

For example William Hill recently had a complaint against them upheld, because their adverts claim "best prices FACT" based on a comparison that doesn't include Betfair. If it did they wouldn't top the comparison.


Even before the adjudication was published they just carried on with the same dishonest claim, but with a disclaimer "not all bookmakers appear in the comparison". So that's perfectly OK apparently.

It's like saying "3 is the smallest whole number, FACT" with a disclaimer in smaller type that "not all numbers were included in the comparison".

The Bet365 advert you're crowing about was back on TV with a disclaimer no one would read the Saturday after this ruling.

By Blogger Alice Klar, at 7:47 pm  

The link you posted is to another successfully upheld complaint - William Hill must not repeat the advert. Obviously, the advert cannot be retrospectively aborted.

As such, this would appear to be another successful ruling in the players' favour.

As to the point of the article, again, the complaint was upheld and the advert must not be repeated. In other words, a successful result.

The ASA "regulates" adverts. Noone is claiming it does anything else, that it handles non-payment complaints or whatever. And it appears to work very successfully within its remit, going by these two cases.

The online gambling industry is built on BS. However, at least in this country it looks like the BS merchants are now being held to account. This is excellent.

By Blogger 100% Gambler, at 11:03 pm  

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By Anonymous Anonymous, at 9:18 pm  

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Monday, February 08, 2010

Mastercard and Visa online gambling crackdown

Mastercard and Visa have recently imposed restrictions on online gambling transactions to US customers. The following was reported by eGaming Review:

Mastercard crackdown leaves US players unable to pay

US-facing operators have been hit by an overnight crackdown on online gambling payments by credit card giant Mastercard. The US company is believed to have toughened its stance on the widespread practice of operators coding egaming transaction as other kinds of online commerce, which will all (sic) its US customers from using their cards to gamble online.


In the followup article it was established that Visa was also implementing the restriction on US customers:

Visa declining US egaming payments

The crackdown on US online gambling credit card payments that began on Wednesday is being operated by Visa as well as rival US credit card giant Mastercard, EGRmagazine has now confirmed, with tens of thousands of US online gamblers likely to have been affected.



In order to better avoid of the USA anti-gambling radar, some gambling operators accepting US customers have been coding their Visa and Mastercard transactions in a manner as to not appear as gambling-related. The correct "internet gambing" merchant code is 7995; some operators have been putting their transactions through thus, and taking a chance as to whether or not the deposit goes through; others have not.

To put it another way: they've been trying to circumvent the system.

Since the February crackdown appears to have been applied retrospectively to January, players now face the prospect that their deposits - with which they will have had plenty of time to play, and lose or win on accordingly - will now almost certainly not be honoured by Mastercard and Visa, resulting in an effective chargeback. This may have a knock-on effect when it comes to winning players receiving their payments.

And while the general tone of the internet discussion on this matter has been one of condemnation of the US administration in the wielding of its prohibitionist axe, I'm personally interested to ask this question: why should we not lay the blame for this squarely at the door of the online gambling operators, still dealing to US customers, who tried to cheat the system in the first place?

Their motives were purely profit-driven in attempting to stay below the radar. But it is the players, who committed no wrongdoing, who may suffer as a consequence.

It is of course also the case that not all operators have been trying to cheat the system. Some, such as Pokerstars, have been coding their transactions upfront as "internet gambling"; in fact, in another EGR article they made a point of distancing themselves from the practice:

PokerStars does not, nor ever has engaged in the practices of mis-coded credit card transactions. We have therefore been unaffected by any crackdown by Visa or MasterCard to close down such mis-coded processing accounts.

So, all well and good for the folks who've behaved honestly.

But the casinos and sportsbooks that have been trying to put one over Mastercard and Visa, whatever the ultimate cost they pay as a result of this matter may be, do not deserve any sympathy.

They particularly do not deserve any sympathy from those players who may end up seriously inconvenienced, and possibly out of pocket, as a result of their duplicity.

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Thursday, February 04, 2010

Online gambling rules, terms and conditions: 32Red shows Fortune Lounge and Spin Palace et al how it should be done

32Red has given the lie to the apparent stance of the online gambling industry that it is largely impossible to write terms and conditions that are not vague, inadequate, waffling and player-unfriendly.

After writing my 32Red article last week, which included copies of the 32Red welcome bonus terms and bonus balance terms, it struck me how clear and concise they were, with no vague language to give the casino room for manouevre when it comes to paying the player, and no stones left unturned.

Most noticeable is section 6:

• In the interests of fair gaming, players may not place individual bets equal to or in excess of 25% or more of the value of the bonus credited to their account until such time as the playthrough requirements for that bonus have been met.

• Any winnings derived from bets placed to the value of 25% or more of the bonus before playthrough requirements for that bonus have been met will initiate a further playthrough requirement of 100 times the amount won.

• For the purposes of this rule, a bet is one roulette spin or one dealer's dealt hand in any table game, or one deal in any Video or Power Poker game (this includes Multi-Hand/Play games).

First, 32Red describes the exact betsize with relation to the bonus - 25% - which must not be exceeded without the risk of sanctions being imposed. This much is not unique, as most Microgaming casinos now carry this rule. However, it doesn't stop there.

Having specified the betsize, the terms then go on to clarify that winnings from bets exceeding this amount will not be confiscated, but will simply be subject to an additional (substantial) wagering requirement.

Having clarified all matters relevant to the basic betsize, the casino clarifies the nature of the composition of the maximum bet as one or more contemporaneous wagers, up to and including the given amount. In other words, assuming a bonus of £100, you cannot circumvent the £25 restriction by placing more than one £25 bet.

Clear as day, with no room for manoeuvre for either player or casino. Exactly as it should be.

So let's move away into murkier territory - or to put it another way, most, if not all, other Microgaming casinos.

Fortune Lounge's Vegas Palms bonus terms, clauses 27 and 33:

The Casino reserves the right to withhold any withdrawals and/or confiscate all winnings for irregular play. "Irregular play" includes but is not limited to any one or more of the following types of play:

1. Placing single bets equal to or in excess of 30% or more of the value of the bonus credited to the account prior to the play-through requirement for that bonus having been met.

2. Using the double-up feature to increase bet values.

3. Even money bets on Sic Bo, Craps, Baccarat and Roulette.

So, here again we have a description of the type of betting that will lead to sanctions. But this description is basically irrelevant, as Fortune Lounge has already stated that sanctions are not limited to the three instances they describe; there are others, which are unspecified.

The casino also tells us that, unlike 32Red, they will not apply an additional wagering tariff to any wins that result from "irregular play", but simply confiscate them - those winnings resulting from wagering that the casino is not able to fully explain. As such, a player has no way of knowing if his wagering will result in a complete confiscation of any cashout amount he is able to achieve.

The Fortune Lounge rules conclude thus:

Any person who in the sole opinion of the Casino deviates from a promotion's rules or from the Casino's General Terms and Conditions may be disqualified without notice and without liability on the part of the Casino.

There is no room for "opinion" in the 32Red rules - they are clear and comprehensive. This is how all rules should. In stating thus, Fortune Lounge is basically acknowledging that its rules are not worth the cyber paper they're printed on.

And I don't think anybody is going to argue with them about that.

Is Fortune Lounge alone in its abusive terms and conditions?

Not really. In fact, they're not even the worst.

Time to take a look at the Spin Palace welcome bonus terms. The point of interest here is the very last clause, right at the bottom of the page. Any particular reason for this clause to be as far as possible from the top of the page?

13. Before any withdrawals are processed, your play will be reviewed for any irregular playing patterns. In the interests of fair gaming, equal, zero or low margin bets or hedge betting, shall all be considered irregular gaming for bonus play-through requirement purposes.

Other examples of irregular game play include but are not limited to, placing single bets equal to or in excess of 30% or more of the value of the bonus credited to their account until such time as the wagering requirements for that bonus have been met.

Should the Casino deem that irregular game play has occurred, the Casino reserves the right to withhold any withdrawals and/or confiscate all winnings.

Again, we have a bet size limitation of 30%, which is all well and good. But again, we have "irregular" play which the casino cannot fully describe, and which may result in confiscation of all funds.

Why can this casino also not define the rules properly?

What is "equal betting"? Does it relate to "hedge betting"? Neither of these are standard casino gambling terms, and therefore they need defining. But they are not defined, it is left to the player to guess.

And what is a "low margin" bet? How low is low? What is a "margin", anyway? Very few gamblers will have heard of this term. Why doesn't the casino define it?

This casino group is well-regarded in the industry. But when you chip away at the surface you find the same vague, undefined, inadequate and player-unfriendly language passed off as "rules" that you will find in the worst casinos on the internet.

I then took a look at the Allslots bonus terms - Allslots is part of the Jackpot Factory group, another well-regarded operation. To my surprise, I couldn't find any vague or unsubstantiatable language that threatened general hell, fire and brimstone, so I looked a bit further down the general terms page.

Sure enough:

10.3 In the event that we believe a user is abusing or attempting to abuse a bonus or other promotion, or is likely to benefit through abuse or lack of good faith from a gaming policy adopted by us, then we may, at our sole discretion, deny, withhold or withdraw from any user any bonus or promotion, or rescind any policy with respect to that user, either temporarily or permanently, or terminate that user's access to the Casino and/or block that user's account.

I can barely be bothered to start taking this one apart. I think they should remove all that and substitute something like "we'll confiscate your money if we don't like you". It would hardly make a difference.

But I do like the reference to the player's potential "lack of good faith". Players gamble in order to win money from the casino in question. What kind of "good faith" is that?

And so on and so on. You can find the same rambling, undefined nonsense on just about any Microgaming site other than 32Red and Ladbrokes. And these operations are all heavily marketed by the affiliate industry: self-professed player "watchdog" Bryan Bailey lists all these casinos, and many more, on his accredited casinos list, replete with accolades of "best casino".

No, Bryan. "Worst casinos". Get it right.

One would hope that as online gambling becomes more mainstream and attracts the big corporations, all such disreputable outfits so beloved of the industry will fall by the wayside or be taken over, to be replaced by operations residing in the kind of reputable jurisdictions which have no option but to enforce only the fair, clear and concise terms that 32Red somehow manages to uniquely achieve.

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