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Innula Zenovka wrote:

It's going to be very interesting to see how many of these "games of skill" survive the requirement that a lawyer provide a reasoned opinion that they're games of skill according to how that term is defined by the jurisdiction in which s/he practices. 

I'm interested in that too. Bit I have a sneaking suspicion that a number of pure gambling games will get through. I'm not going to go looking though. I'll just read all about it in the forum.

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ETA: I do have to applaud the Lab for having someone here to answer our questions rather than let us argue amongst ourselves as to what we can and can not do. Bravo!

 You can stop applauding now Tex because they've stopped answering.  It was shortlived!  Now we just "argue amongst ourselves".  Par for the course?

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Hello, Linden Lab.
 
I need a clarification to file EchoSign for Skill Gaming Policy ( as an operator).
 
https://secure.echosign.com/public/hostedForm?formid=9EX6XU7I3J32XJ
2 SKILL GAMING APPLICATION REQUIREMENTS
(ii) A sworn affidavit or declaration from the applicant that...
 
 
Do you require a sworn affidavit or a declaration? 
Do I need an attorney for this or not?
 
 
In the SKILL GAMING POLICY THREAD, pag 29, this is what You replied to Gaia Gabe:
 
 
"The reasoned legal opinion has to be from a credible attorney in good standing and licensed to practlce law in the U.S.
The sworn affidavit comes from the applicant."
 
Does this mean that I do not need an attorney for this sworn affidavit?
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Pluto Shelman wrote:

Hello, Linden Lab.
 
I need a clarification to file EchoSign for Skill Gaming Policy ( as an operator).

 

2 SKILL GAMING APPLICATION REQUIREMENTS

(ii) A sworn affidavit or declaration from the applicant that...
 
 
Do you require a sworn affidavit or a declaration? 
Do I need an attorney for this or not?
 
 
In the SKILL GAMING POLICY THREAD, pag 29, this is what You replied to Gaia Gabe:
 
 
"The reasoned legal opinion has to be from a credible attorney in good standing and licensed to practlce law in the U.S.
The sworn affidavit comes from the applicant."
 
Does this mean that I do not need an attorney for this sworn affidavit?

 

an affidavit and a declaration are really the same thing. a declaration is an alternative form for people who have, for example, religious objections to making oaths. these are usually signed off by a notary, and your lawyer can do this as part of the job. they can help you with the wording too, they assemble documents like this all day.

 
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Linden Lab wrote:

If you’ve read the
,
s and
documentation on our revised
and have comments and/or questions, you can post them here. We’ll be keeping an eye on this forum thread regarding Skill Gaming.

 

I see now where I made my mistake.  You did say that we could post our comments or questions here.  And you did say that you'd be keeping an eye on this thread.  Now - why did I think you would be answering those questions?  My mistake.

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Durandir Darwin wrote:


Sorina Garrigus wrote:


"Zyngo and No Devils are not too terribly different in game play than they have been for years. Zyngo was around for over 7 years. So your implication that it is changed drastically from way back when compared to now is not accurate other than improved scripting."


 

When the hammer fell before on gambling (JP Linden, autoplay, devils stealing points), Aargle quickly came up with a different version of Zyngo, v8.0 (Zyngo Hunt). And that one was different from other Zyngo versions: Special symbols could be found by deducting them (skill element), clicking wrong numbers resulted in a loss of points, letters (Z,Y,N,G and O) gave points a different value (each letter appeared 20 times in a game), no devils to substract points from your total score, the right order in filling a line, pattern or the board was important and so on. Sounds complicated? Then it might contain a higher percentage of skill.

The way that all unfolded it came off very much like an outside attack on Zyngo and Deal specifically. Some games like No devils and King Bing didn't seem to have to deal with those changes for some reason. At the same time new games came out allegedly using the guidelines LL put out or suggested to game designers. Games that came out shortly after that allgedly using those guidelines were in my opinion easily measurably more into the chance realm than Zyngo or Deal. Knowing the industry like I do I am possitive they were ARed more than a few times and LL allowed them to remain. That would be a possible reason why some games that changed may have went back to some variations of its past versions which were deemed ok because of competitive reasons and LL was allowing these new "edgier" games. When the masses are presented with a simple game to a more complicated game they will go to the simpler. The more complicated games became niche games for a different kind of gamer. Much like how the RL board game industry is. More people will play quick fun good for laughs games like Say anything, Cards Against Humanity, Cranium than those that will play things like Agricola, PowerGrid, or Twilight Imperium. But when LL allows edgier games like they have in the past it pushes out the more strategic games. My personal favorite skill games in second life are almost always not the popular ones personally and some you can't even find out.

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Durandir Darwin wrote:


Sorina Garrigus wrote:


...
But LL allowed Zyngo for years and has been considered by them to be a game of skill. As I recall it was demonstrated that a more experiernced skilled player can attain on average a higher score than a less experienced player....

_______________________________________________________________________________________

 

Do you know how Aargle defined games of skill?

"A game of skill isn't a game of skill because skill makes you win; instead, it's a game of skill because your failure to apply skill prevents you from winning."

In one RL lottery in my country you are allowed to mark a maximum of 6 numbers. If i mark more numbers because i'm missing the skill to count, my lottery ticket will be invalid. Failure to apply skill here (choosing 6 instead of 7 numbers) prevents me from (having the chance of) winning. So lottery is a skill game?

I doubt that is Aargles "definition" of a games skill but I understand what he is trying to say. Many times in any kind of game you will lose or win not only for what you do in a game but what you fail to do. In chess for example if you fail to see that your opponent is about to put your king in check in 2 moves that will cost you the game. Basically he was trying to put out some yoda like wisdom in relation to games. To put it in more Yoda like terms he was trying to say. "What you do in a game is what makes you win not, What makes you lose, what you fail to do is."

 

 

In Slingo type games there are patterns, score multipliers, do you complete a line or the pattern now if the multiplier is not up now or wait until you find it. So comparing it to filling out a lottery ticket is silly. Is it a complex game to play say like Go? No but LL apparently considered it to be a game of skill for 7 years.

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outtaspace wrote:

Im really glad to see LL finally take action on the illegal gambling that has been in SL for the last years.

99% of the games on offer in SL are GAMBLING, minimal skill invovled if any at all. This should have stopped years ago.

I just laugh reading this thread... operators so concerned with getting their licences.. do you really think there is any games currently in SL that a competant lawyer is going to give a reasoned legal opinion to say that the game in question is skill based, with only a very minimal element of chance to it?.. are they F**k.

I personally am looking forward to 1st Aug.. got my list of games to go out AR'ing.. yes sad i know lol

Fishing games... 7 seas, Go Fishin, Fish Hunt... Pay bait entry, press auto cast, chance of win. no skill

Breedable Pets, paid food entry, very minimal skill in pairing pets.. gives offspring with potential L$ value.

and of course every  sploder and no devil style machine i can find..

 

LL has actively allowed and profited off of what you are labeling as "illegal gambling" for 7 years. Also their not taking action on games of skill, they are just putting out more red tape to protect themselves so they can continue to profit off them. Possibly more with these new fees. These new policies are about restricting access to those in states and countries that do not allow games of skill as pay and win games.

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Phil Deakins wrote:


Innula Zenovka wrote:

It's going to be very interesting to see how many of these "games of skill" survive the requirement that a lawyer provide a reasoned opinion that they're games of skill according to how that term is defined by the jurisdiction in which s/he practices. 

I'm interested in that too. Bit I have a sneaking suspicion that a number of pure gambling games will get through. I'm not going to go looking though. I'll just read all about it in the forum.

"pure gambling" games are not getting through now as in games of pure chance. Techinically blackjack and poker are not games of pure chance but those are not allowed either.

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WhataBig Camel wrote:

 
ETA: I do have to applaud the Lab for having someone here to answer our questions rather than let us argue amongst ourselves as to what we can and can not do. Bravo!

 You can stop applauding now Tex because they've stopped answering.  It was shortlived!  Now we just "argue amongst ourselves".  Par for the course?

As far as I can tell and I could be wrong, they gave up responding after 8 pages worth of post which tells me they never had any serious intentions on answering questions keeping an open dialgue on a complicated topic and short turn around policy as it relates to the complexity of the issue.

Also I think Tex was sarcastically appluading.

https://www.youtube.com/watch?v=Eo7ySyy2Z4k

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Pluto Shelman wrote:

Hello, Linden Lab.
 
I need a clarification to file EchoSign for Skill Gaming Policy ( as an operator).

 

2 SKILL GAMING APPLICATION REQUIREMENTS

(ii) A sworn affidavit or declaration from the applicant that...
 
 
Do you require a sworn affidavit or a declaration? 
Do I need an attorney for this or not?
 
 
In the SKILL GAMING POLICY THREAD, pag 29, this is what You replied to Gaia Gabe:
 
 
"The reasoned legal opinion has to be from a credible attorney in good standing and licensed to practlce law in the U.S.
The sworn affidavit comes from the applicant."
 
Does this mean that I do not need an attorney for this sworn affidavit?

http://en.wikipedia.org/wiki/Affidavit

"An affidavit (/ˌæfɨˈdvɨt/ A-fə-DAY-vət) is a written sworn statement of fact voluntarily made by an affiant or deponent under an oath or affirmation administered by a person authorized to do so by law. Such statement is witnessed as to the authenticity of the affiant's signature by a taker of oaths, such as a notary public or commissioner of oaths. The name is Medieval Latin for he/she has declared upon oath. An affidavit is a type of verified statement or showing, or in other words, it contains a verification, meaning it is under oath or penalty of perjury, and this serves as evidence to its veracity and is required for court proceedings."

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Hey Durandir, did you enjoy playing my games? You made 250L$ payins, when my sim minimum is 20L$, I hardly think you were testing to see how they're played.

 

The policy states that win or loss must be based primarily on skill. They do not say that the amount won must be determined based on score or skill. To be fair, a win should pay back at least what was paid in for that game...but there is no rule that appears to affect Winks and such. Further, luck can pay a small role - enough to ensure some profit to the owner. With a combination of a small luck element affecting say 10-15% of games, and unskilled players making mistakes, you have a profitable skill game. 

The owner could also take a rake - a percent from each game played. That is how Gridwide games work. Typically 80% of payins go to players, 10% to the owner of the sim, and 10% to the gridwide network operator. Players only compete against each other. 

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Ayesha Lytton wrote:

Hey Durandir, did you enjoy playing my games? You made 250L$ payins, when my sim minimum is 20L$, I hardly think you were testing to see how they're played.

 

The policy states that win or loss must be based primarily on skill. They do not say that the amount won must be determined based on score or skill. To be fair, a win should pay back at least what was paid in for that game...but there is no rule that appears to affect Winks and such. Further, luck can pay a small role - enough to ensure some profit to the owner. With a combination of a small luck element affecting say 10-15% of games, and unskilled players making mistakes, you have a profitable skill game. 

The owner could also take a rake - a percent from each game played. That is how Gridwide games work. Typically 80% of payins go to players, 10% to the owner of the sim, and 10% to the gridwide network operator. Players only compete against each other. 

Just to be clear, the new policy doesn't say that "win or loss must be based primarily on skill".   The new policy say that they are games "twhose outcome is determined by skill and is not contingent, in whole or in material part, upon chance," and requires reasoned opinions from both the creator's and operator's attorneys that this is the case of the game under consideration  (I know you know this, but other people reading the thread might not, and thus become even more confused).

However, I don't understand what  "Further, luck can pay a small role - enough to ensure some profit to the owner " means.   Whatever is ensuring the owner's profit, it's not luck.  

The game's  owner is not making 10% of turnover because she's consistently lucky, but because the game is set to deliver that.   Luck doesn't enter into it. 

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Durandir Darwin wrote:

Do you know how Aargle defined games of skill?

"A game of skill isn't a game of skill because skill makes you win; instead, it's a game of skill because your failure to apply skill prevents you from winning."

Who cares how Aargle defines games of skill? He doesn't get a say in it.

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I don't particularly care if giant "casino" and "gaming" sims are slapped with extra fee's and the need for licenses to be honest, they fleece enough people everyday and make a giant profit to be able to afford it. I can understand why these places may need legitimate licenses.

What I care about and can't understand is the absolute disregard LL has shown for the average person, yet again, who run games, contests, trivia and other random events for FUN that "oh no" sometimes includes linden prizes.

These prizes (at my venue at least) are -gifts- from myself (or my staff) to our VIP's. It's a simple fun random thing to do every now and then. My community is non-profit, and has fed LL's grid with a steady stream of traffic for nearly 6 years. 6 years of tiers and you expect more, from countless non-profit entities that simply exist for the pleasure of others.

I cannot afford to run a non-profit community, and pay for a "gaming" sim + license + application fee + solicitors fees purely so I can GIVE AWAY small amounts of L$ as gifts occassionally, using random things like trivia balls (skill) or contest boards (chance mostly), and I find this, "Second Life residents will need to make this determination on a case by case basis" to be a complete cop-out in regards to simply leaving us all open for a hard slap we don't deserve.

Do us a favour and actually answer someones question about THIS. Non-profit gifted PRIZES and CONTESTS. And don't sling out the same response about items being able to be paid into either, thats ridiculous and answers nothing. We're all aware these items can be "paid into", but it doesn't fall into the same category as a giant "gaming sim", nor should it.

You need to ammend this change to include SOMETHING for normal users so as not to screw over the majority of the grid, which is exactly what you're about to do.

Money-grab much?

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To an extent, I agree with you Snowpaw. If money is just being used for tier and not cashed out, some of these rules shouldn't apply, I'm OK with requiring games to be approved, but to operate them you should only have to sign an agreement that you'll only run approved games. It's ridiculous to require expensive legal opinions just to have games. 

 

On a related note, there is a licensed attorney writing creator legal opinions for L$30k, and operators as low as L$5k per game if you run 20+ games. While still costly, this is FAR less than others have wanted, and is helpful for ensuring games can continue. If anyone needs the name of this attorney please IM me inworld. 

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LL have made it clear they're not going to reply to questions about individual cases.    That, to my mind, is wholly understandable, since they've only got your description to go on, and if, in effect, they give you a ruling this way, then they have to give one to everyone.

The important question, to my mind, is whether people have to pay to enter your contests.   If they don't, I don't think you need to worry.  

You say " We're all aware these items can be "paid into", but it doesn't fall into the same category as a giant "gaming sim", nor should it." but I've never entered a contest at club or joined a triva quiz where I had to pay, so it comes as news to me..  

However, LL have made it clear that, if an item can be set to "pay to play" then it falls within the ambit of the policy, even if you've set it not take money.   If that is the case, to my mind you need to be asking the creator for an updated version that doesn't allow people to pay in.

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Hi

 Giant snail racing the sport that's been in second life since 2004,  I would like to know if I can continue accepting donations that go into a pot and are divided up amongst the snails that raced each week. We do not require anyone to pay money to race. We do not want to be a gamming sim as there is no profit made by the sim owner or me.   

 

looks like the answer is in the reply above this one as no one is required to pay any money i guess were ok oh thats not from a linden nm

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Innula Zenovka wrote:


Ayesha Lytton wrote:

Hey Durandir, did you enjoy playing my games? You made 250L$ payins, when my sim minimum is 20L$, I hardly think you were testing to see how they're played.

 

The policy states that win or loss must be based primarily on skill. They do not say that the amount won must be determined based on score or skill. To be fair, a win should pay back at least what was paid in for that game...but there is no rule that appears to affect Winks and such. Further, luck can pay a small role - enough to ensure some profit to the owner. With a combination of a small luck element affecting say 10-15% of games, and unskilled players making mistakes, you have a profitable skill game. 

The owner could also take a rake - a percent from each game played. That is how Gridwide games work. Typically 80% of payins go to players, 10% to the owner of the sim, and 10% to the gridwide network operator. Players only compete against each other. 

Just to be clear, the new policy doesn't say that "win or loss must be based primarily on skill".   The new policy say that they are games "t
whose outcome is determined by skill and is not contingent, in whole or in material part, upon chance," and requires reasoned opinions from both the creator's and operator's attorneys that this is the case of the game under consideration  (I know you know this, but other people reading the thread might not, and thus become even more confused).

However, I don't understand what 
 "Further, luck can pay a small role - enough to ensure some profit to the owner " means.   Whatever is ensuring the owner's profit, it's not luck.  

The game's  owner is not making 10% of turnover because she's consistently lucky, but because the game is set to deliver that.   Luck doesn't enter into it. 

Games are set by score not by how much they want to make off of it. A game operator that tries to make X% off a game will calculate average scores and determine the the most fair score in most cases. I have never seen a single game that the owner sets how much they want to make from a game and I seen hundreds of games and their configs.

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RacerX Gullwing wrote:

Hi

 Giant snail racing the sport that's been in second life since 2004,  I would like to know if I can continue accepting donations that go into a pot and are divided up amongst the snails that raced each week. We do not require anyone to pay money to race. We do not want to be a gamming sim as there is no profit made by the sim owner or me.   

 

looks like the answer is in the reply above this one as no one is required to pay any money i guess were ok oh thats not from a linden nm

LL stopped answering all these questions 8 pages in. But based on my experience with a wide variety of games in SL and the policy I can try to give you my best guess.

From the Skill game policy.

“Skill Game” or “Skill Gaming” shall mean a game, implemented through an Inworld object: 1) whose outcome is determined by skill and is not contingent, in whole or in material part, upon chance; 2) requires or permits the payment of Linden Dollars to play; 3) provides a payout in Linden Dollars; and 4) is legally authorized by applicable United States and international law. Games in which Second Life residents do not pay to play are not within the scope of this Skill Gaming Policy. “Skill Games” are not intended to include and shall not include “gambling” as defined by applicable United States and international law.

The skill game policy states a game that requires OR permits the payment of linden dollars to play and pays out in Linden Dollars. As it is written snail racing with paid donations with money to win would be considered to be permitting the payment to play. So unless LL reworks some of these issues then you wouldn't be able to take donations that pay out to the winners unless you get go through the approval process as an operator and whoever created the game would also have to get legal opinions and go through the approval process.

Its effing stupid unfortunately but as it is written that is the case. Your only option might be to have a tip jar for any tipper that has nothing to do with the pots, have free entrys, and just pay out completely separately. Perhaps by sponsers?

I think people don't understand how much this policy affects content in SL wide spread. Its not about "illegal gambling games on games of pure chance" these new policies have nothing to do with that at all. Especially since they are not allowed at all. These policies are affect ALL games of skill with pay and win options.

It pisses me off LL is clamming up and SL traditions like the Snail Races have to change or talk to their lawyers and run on gaming sims or not able to pay the winners or take entree fees.

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Sorina Garrigus wrote:


RacerX Gullwing wrote:

Hi

 Giant snail racing the sport that's been in second life since 2004,  I would like to know if I can continue accepting donations that go into a pot and are divided up amongst the snails that raced each week. We do not require anyone to pay money to race. We do not want to be a gamming sim as there is no profit made by the sim owner or me.   

 

looks like the answer is in the reply above this one as no one is required to pay any money i guess were ok oh thats not from a linden nm

LL stopped answering all these questions 8 pages in. But based on my experience with a wide variety of games in SL and the policy I can try to give you my best guess.

From the Skill game policy.

“Skill Game” or “Skill Gaming” shall mean a game, implemented through an Inworld object: 1) whose outcome is determined by skill and is not contingent, in whole or in material part, upon chance; 2)
requires or permits the payment of Linden Dollars to play
; 3) provides a payout in Linden Dollars; and 4) is legally authorized by applicable United States and international law. Games in which Second Life residents do not pay to play are not within the scope of this Skill Gaming Policy. “Skill Games” are not intended to include and shall not include “gambling” as defined by applicable United States and international law.

The skill game policy states a game that requires
OR permits the payment of linden dollars to play and pays out in Linden Dollars
.
As it is written snail racing with paid donations with money to win would be considered to be
permitting the payment to play
.
So unless LL reworks some of these issues then you wouldn't be able to take donations that pay out to the winners unless you get go through the approval process as an operator and whoever created the game would also have to get legal opinions and go through the approval process.

Its effing stupid unfortunately but as it is written that is the case. Your only option might be to have a tip jar for any tipper that has nothing to do with the pots, have free entrys, and just pay out completely separately. Perhaps by sponsers?

I think people don't understand how much this policy affects content in SL wide spread. Its not about "illegal gambling games on games of pure chance" these new policies have nothing to do with that at all. Especially since they are not allowed at all. These policies are affect ALL games of skill with pay and win options.

It pisses me off LL is clamming up and SL traditions like the Snail Races have to change or talk to their lawyers and run on gaming sims or not able to pay the winners or take entree fees.

"As it is written snail racing with paid donations with money to win would be considered to be permitting the payment to play."

That is a question I would love to see clarification on because is it payment to play or payment to compete?  Altough it is virtual, we are talking about a 'sport competition' which I'm not sure of all the laws, but I don't think that is in and of itself considered "gambling."  I'll admit, I don't know enough about it.

If no one is betting on the outcome of the race does it fall under the umbrealla of the gambling laws?

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Sorina Garrigus wrote:


Innula Zenovka wrote:


Ayesha Lytton wrote:

Hey Durandir, did you enjoy playing my games? You made 250L$ payins, when my sim minimum is 20L$, I hardly think you were testing to see how they're played.

 

The policy states that win or loss must be based primarily on skill. They do not say that the amount won must be determined based on score or skill. To be fair, a win should pay back at least what was paid in for that game...but there is no rule that appears to affect Winks and such. Further, luck can pay a small role - enough to ensure some profit to the owner. With a combination of a small luck element affecting say 10-15% of games, and unskilled players making mistakes, you have a profitable skill game. 

The owner could also take a rake - a percent from each game played. That is how Gridwide games work. Typically 80% of payins go to players, 10% to the owner of the sim, and 10% to the gridwide network operator. Players only compete against each other. 

Just to be clear, the new policy doesn't say that "win or loss must be based primarily on skill".   The new policy say that they are games "t
whose outcome is determined by skill and is not contingent, in whole or in material part, upon chance," and requires reasoned opinions from both the creator's and operator's attorneys that this is the case of the game under consideration  (I know you know this, but other people reading the thread might not, and thus become even more confused).

However, I don't understand what 
 "Further, luck can pay a small role - enough to ensure some profit to the owner " means.   Whatever is ensuring the owner's profit, it's not luck.  

The game's  owner is not making 10% of turnover because she's consistently lucky, but because the game is set to deliver that.   Luck doesn't enter into it. 

Games are set by score not by how much they want to make off of it. A game operator that tries to make X% off a game will calculate average scores and determine the the most fair score in most cases. I have never seen a single game that the owner sets how much they want to make from a game and I seen hundreds of games and their configs.

  

To my mind, it doesn't really matter  whether the mechanics of the game are such that the owner is able simply to specify a percentage of the take she wishes to retain, or whether she has herself  to set the scores and prize levels to achieve this end.

If at the end of the process she is able to say with a fair degree of certainty that, under normal circumstances, her take from her games will be enough to cover her tier, she is predicting that she'll retain a certain percentage of her expected turnover.   If she's able to say that with any accuracy, she's not relying on luck (other than the element luck plays in the grid in general and her sims in particular remaining online).

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Innula Zenovka wrote:


Sorina Garrigus wrote:


Innula Zenovka wrote:


Ayesha Lytton wrote:

Hey Durandir, did you enjoy playing my games? You made 250L$ payins, when my sim minimum is 20L$, I hardly think you were testing to see how they're played.

 

The policy states that win or loss must be based primarily on skill. They do not say that the amount won must be determined based on score or skill. To be fair, a win should pay back at least what was paid in for that game...but there is no rule that appears to affect Winks and such. Further, luck can pay a small role - enough to ensure some profit to the owner. With a combination of a small luck element affecting say 10-15% of games, and unskilled players making mistakes, you have a profitable skill game. 

The owner could also take a rake - a percent from each game played. That is how Gridwide games work. Typically 80% of payins go to players, 10% to the owner of the sim, and 10% to the gridwide network operator. Players only compete against each other. 

Just to be clear, the new policy doesn't say that "win or loss must be based primarily on skill".   The new policy say that they are games "t
whose outcome is determined by skill and is not contingent, in whole or in material part, upon chance," and requires reasoned opinions from both the creator's and operator's attorneys that this is the case of the game under consideration  (I know you know this, but other people reading the thread might not, and thus become even more confused).

However, I don't understand what 
 "Further, luck can pay a small role - enough to ensure some profit to the owner " means.   Whatever is ensuring the owner's profit, it's not luck.  

The game's  owner is not making 10% of turnover because she's consistently lucky, but because the game is set to deliver that.   Luck doesn't enter into it. 

Games are set by score not by how much they want to make off of it. A game operator that tries to make X% off a game will calculate average scores and determine the the most fair score in most cases. I have never seen a single game that the owner sets how much they want to make from a game and I seen hundreds of games and their configs.

  

To my mind, it doesn't really matter  whether the mechanics of the game are such that the owner is able simply to specify a percentage of the take she wishes to retain, or whether she has herself  to set the scores and prize levels to achieve this end.

If at the end of the process she is able to say with a fair degree of certainty that, under normal circumstances, her take from her games will be enough to cover her tier, she is predicting that she'll retain a certain percentage of her expected turnover.   If she's able to say that with any accuracy, she's not relying on luck (other than the element luck plays in the grid in general and her sims in particular remaining online).

I think we are both arguing on the same side on this topic but to be devils advocate for a second Casinos in real life calculate odds on their games of pure chance also. Based on the laws of probability of course as opposed to in skill games a players ability to play the game.

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