IAGA SUMMIT Macau 2018

monetarisation are structured and how closely the game is linked or resembles gambling that will be of core relevance from a consumer protection perspective and when determining which measures operators have to implement to ensure adequate protection.

John Lin:As the industry has evolved, many of the most successful games are those that leverage slot themes and features from real casino games, as those styles and brands are familiar to avid players of real slot machines. Te traditional real money slot machine manufacturers have taken notice and leveraged their proven real slot content in the space, and have taken a leadership position in social casino accordingly; 4 of the top 10 social casino operators are owned by real slot games companies. Te operators, both those that are ‘porting’ real slot machine games to social as well as those that are developing original game content, are focusing on themes and features that appeal to the core audience of adult slot players. Each developer is creating games with the objective of commercial success, which has consistently guided the content to appeal to experienced, adult slot players.

Does age verification in the social gaming sector need to be more robust?

John Lin: Independent research commissioned by the ISGA found that the present age distribution of social casino players is 99.41 per cent age 18 or older, which shows that the measures that the industry has implemented are strongly effective, in fact significantly more effective than age restrictions placed on many other recreational activities.

Jessica Maier:Not necessarily, but much will depend on the specific game in question and its potential for harm, e.g. to which extent it can potentially be confused with gambling offerings. Social games offered on social networking platforms (where there are usually are no age verification checks at all) will further often be considered to be particularly vulnerable to maybe be harmful.

In your view, is the social gaming space adequately regulated?

Jessica Maier:Despite social gaming not being “new,” I think that it is important to still look at social gaming regulation – and particularly the question of whether specific (gambling) regulation is necessary – as a “work in progress”. Te discussions on where exactly to draw the line between gaming and gambling and on how to determine whether specific regulation (and, if so, what kind of regulation) is necessary and effective are still ongoing. Tey are influenced by a variety of different factors and in need of more thorough and continued research and analysis.

From a European perspective, I believe social gaming specific regulation will probably not be necessary, not least since consumer protection is ensured by other mechanisms, namely consumer protection legislation. It will, however, be interesting to see whether and how considerations such as those of the Washington Court of Appeals ruling on Big Fish Casino on the worth of virtual items will influence on

the social gaming sector and these ongoing discussions.

John Lin: Social gaming is actually highly regulated, although not by gambling regulators as it is not real gambling. Te distribution platforms Apple, Google, and Facebook among others each have substantial compliance and policy functions that enforce specific requirements and restrictions on our games. Tese platforms study and monitor prevailing laws and regulations across international jurisdictions, and require compliance to their established policies by all developers. It is also notable that these platforms do not permit real money gambling. In addition to the platforms, the social games developer community is subject to comply with prevailing and relevant laws of any jurisdiction where our games are offered that apply to our core business of offering free-to-play social games. As such, we find the social games business to be substantially and sufficiently regulated.

When does social gaming become a problem for the online/land-based gambling operator and what protection measures should the industry adopt?

John Lin:On the contrary, our experience is that social gaming is a valuable complement to land-based gaming operators. Social games provide a cost-free and casual channel for gamers to engage with their preferred style of games, with much greater frequency and much lower commitment of time and money than real money casino gaming. Real casino resorts offer enveloping experiences that delight the senses for players in a much deeper and dimensional way. In this way, social casino players refresh players’ engagement to their favourite games through their casual play, which enhances their excitement for the peak experiences that casino resorts offer.

Jessica Maier: Social gaming, if offered in parallel to an online/land-based gambling offering, will likely become a problem for operators if it lacks

Jessica Maier, LLM, Melchers

Jessica Maier is a German attorney with MELCHERS and advises clients on all aspects of gambling law with a focus on regulation, licensing and compliance. She has been involved in regulatory due diligence reviews in the context of corporate acquisitions and also supports clients in competition and antitrust related matters as well as in administrative court proceedings or out-of-court negotiations and interactions. She has provided guidance to clients in various licensing proceedings and advises clients on the regulatory developments in Germany which impact on their business. This includes developing strategies for the implementation of new products on the German market and marketing thereof. Jessica is experienced in lobbying and regularly contributes to gambling law and industry publications. She is a member of the International Association of Gaming Advisors (IAGA) and Global Gaming Women (GGW).

I do not consider the debate on acceptable/unacceptable themes to be of a major relevance. In the end, it will almost certainly not be the theme of the game but rather how the game and monetarization are structured and how closely the game is linked or resembles gambling that will be of core relevance from a consumer protection perspective.

transparency and displays gambling in a way that does not match the reality of things, e.g. if it raises false expectations with regard to the likelihood of winning in the real world since more favourable odds or higher RTP rates compared to real-money gambling offerings might be used in social gaming. Operators hoping to attract new gambling customers by offering social gaming will further have to analyse from a business perspective whether this can actually be achieved considering that gamblers and social gamers will not necessarily fall within the same demographic. From a responsibilities and consumer protection perspective, they will have to be prepared to apply particular caution e.g. in their marketing and the overall design and structure of the social gaming offering


The International Association of Gaming Advisors (IAGA) will hold its 37th annual International Gaming Summit May 14 - 16 at the Four Seasons Macao in Macau, China.


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