Public Comments for: SB212 - Virginia Small Business Economic Development Act; established.
Last Name: Ko Organization: Law abiding citizens who want to protect ourselves from drugs Locality: Richmond area

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Last Name: Cencich Locality: Page

I am writing in connection with SB 212 and HB 590, relating to the legalization of so-called “skill games” in Virginia. I have seized hundreds of similar devices in every region of the Commonwealth and testified as an expert witness in many Virginia jurisdictions regarding these machines. While I take no position on the legalization of these devices, there are indeed problem areas with the legislation. 1. Most devices of this nature are not ones whereby the outcome is based predominantly by chance. This means that certain so-called skill games could still be seized after this legislation is passed because they are factually based predominately on chance. Either the devices—when examined by a laboratory—should be determined to be those by which the outcome is in fact determined predominantly by skill, or the Bill should be amended to say any combination of skill or chance. The former determines that the games are indeed ones based predominately on skill (which is not likely) and the latter simply legalizes this form of gaming. 2. The Bill would allow for one-armed bandits as well as automatic payouts of cash dispensed directly from the devices. 3. As the Bill is currently written, manufacturers and not regulated in any fashion and there are no background checks for distributors or operators. While I make no allegations against anyone or any company, my past investigations in Virginia have linked similar devices to organized crime in Pennsylvania, New Jersey, and New York. 4. Many of these types of devices contain computerized programs that would be considered a type of fraud as they defeat elements of chance and skill in order to maintain a pre-determined house percentage. Please see attached report.

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