- Nevada’s “Fast Track” for New Gaming Devices
- November 25, 2016 | Authors: Mark A. Clayton; Erica Okerberg
- Law Firm: Greenberg Traurig, LLP - Las Vegas Office
- Prior to a gaming device being given final approval by the Nevada Gaming Commission, the device must successfully pass a “field trial.” This field trial allows the gaming device to be deployed in a casino and played by casino patrons. Upon the successful completion of the field trial, the Nevada Gaming Commission will consider granting final approval of the gaming device.
The field trial process serves two primary functions. First, the field trial process allows the Nevada Gaming Control Board’s Technology and Enforcement Divisions to observe the device in a “real-life setting” and determine if there are any items to address that were not previously detected in laboratory tests and observations. Second, the field trial process allows the gaming device manufacturer to evaluate how a new gaming device performs in the “real world,” including how patrons perceive and react to the gaming device.
After various consultations with the Nevada gaming industry, the Nevada Gaming Commission adopted amendments to Regulation 14 to streamline the field trial and gaming device approval process. The amendments incorporate a “New Innovation Beta” process, pursuant to which, manufacturers can offer their gaming devices in a limited field trial while the regulatory approval/review process is pending.
To quote from the Nevada Gaming Control Board’s Industry Notice regarding the New Innovation Beta process:
A manufacturer who wishes to have their gaming device considered under [the New Innovation Beta process] must submit the following information:
- A letter addressed to the Board Chairman requesting product consideration for participation in the NIB process. The letter must contain the justification for participation, including a detailed description of the innovative aspect of the gaming device.
- A detailed overview of the game outcome determination process including, as applicable, the random number generation process; the mapping of random numbers to game elements; and the evaluation of the game elements to determine win or loss.
- The test procedures and results used to determine the accuracy of the game outcome determination process.
- The test procedures and results used to determine the accuracy of adding and removing credits to the gaming device including the deduction of credits for game play; the payment of winning wagers; the addition of credits via any mechanism available to the device; and the cashing-out of credits via any mechanism available to the device. Examples of available mechanisms include a currency acceptor; a currency dispenser; a voucher printer; and monetary transactions conducted with associated equipment.
- A compliance report that documents in detail how the device either currently complies with or the intended method of compliance with each of the requirements of Regulation 14 and the Technical Standards for Gaming Devices.
- A letter from a licensed gaming operator stating their intention to host a NIB field trial of your gaming device and their commitment to abide by the terms and conditions the Board Chairman may prescribe.
- Any other information the manufacturer would like reviewed by the Chairman, such as approval information from another jurisdiction, when requesting consideration to participate in the NIB process.
The manufacturer is strongly encouraged to contact the Technology Division prior to submitting a request for participation in NIB to review their gaming device and the NIB process.
The Nevada Gaming Control Board’s and Nevada Gaming Commission’s action in this space demonstrate their continuing desire to encourage innovation and remain at the forefront of gaming technology.