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Amusement Devices

DIA regulates the registration of all electrical and mechanical amusement devices that are subject to regulation according to Iowa law. An amusement device must meet the following requirements: 

  • Prizes must be merchandise only and must not exceed $50 in value. No cash shall be awarded as a prize.
  • A device shall not be designed or adapted to cause or to enable a person to cause the release of free games or portions of games when designated as a potential award for use of the device.
  • An amusement device shall not be designed or adapted to enable a person using the device to increase the chances of winning free games or portions of games by paying more than is ordinarily required to play the game.
  • Amusement devices may not be designated or resemble a machine which is normally used for casino-type gambling. Slot machines are not permitted nor are devices capable of playing poker, blackjack, or keno. 
  • An award given for the use of an amusement device shall only be redeemed on the premises where the device is located and only for merchandise sold in the normal course of business for the premises.  

Please review Iowa Code Chapter 99B and administrative rules 481 IAC 104 and 481 IAC 105 for general provisions of amusement devices and registered amusement devices.

Registered amusement devices may only be located on the premises of an establishment for which a Class "A," Class "B," Class "C," Special Class "C," or Class "D" liquor-control license, OR a Class "B" or Class "C" beer permit has been issued, pursuant to Iowa Code Chapter 123.

Purchasing Amusement Devices

Iowa Code restricts the total number of registered amusement devices that may be placed in the state [see Iowa Code Section 99B.53(6)]. Anyone interested in purchasing an amusement device for placement in an approved establishment should contact the Social and Charitable Gambling Unit at SCG@dia.iowa.gov or 515.281.6840 for instructions on how they may place their name on the waiting list to register a device.

How to Register an Amusement Device

Individuals owning or possessing amusement devices may register electronically through the DIA's online Game Machine Management System (GMMS). Registrations may be purchased through the GMMS website as well. Once an account has been established, individuals may make changes to their information including changing the location of registered devices.

For assistance with the registration of electrical and mechanical amusement devices, please contact the department's Social and Charitable Gambling Unit at 515.281.6840 or send an email to SCG@dia.iowa.gov

Annual Cost

  • Each device must display a registration tag that is issued annually: $25 per device
  • Manufacturer registration: $2,500
  • Distributor registration: $5,000
  • Owner registration: $2,500 (no more than four devices may be placed at a single location)
  • Qualified organizations: $0 (no more than four devices may be placed at a single location)
    NOTE: A copy of 501(c) determination letter must be included with application

Industry Notice

Comments are due by close of business on March 22, 2021.

View the PDF of this letter.

March 3, 2021

TO:  Any Interested Parties

RE:  Petition for Declaratory Order to determine whether “Game Of Skill Multi-Game System version 13.3.1.1” is lawful and not subject to registration

Pursuant to Iowa Code Section 17A.9(3), this letter is to advise you that on February 25, 2021, the Iowa Department of Inspections and Appeals, Social and Charitable Gambling Unit, (Department) received a Petition for a Declaratory Order.  Petitioner requests the Department to determine if “Game Of Skill Multi-Game System version 13.3.1.1” is lawful and is not subject to the registration requirement. 

The Department invites you to comment about the issues presented in this Amended Petition for a Declaratory Order, if you so choose.  To do so, please send all comments in writing to the undersigned at the Iowa Department of Inspections and Appeals, Lucas Building, 321 E. 12th St., Des Moines, Iowa  50319, by the close of business on Monday, March 22, 2021. A copy of the petition is available on the DIA Amusement Devices page under Industry Notice.

If you choose to intervene in this matter and are qualified to intervene, please refer to Iowa Code Section 17A.9(4) and Iowa Administrative Code 481-Chapter 3.

Sincerely,

Dan Horner
Chief, Social & Charitable Gambling Unit
515.281.6840

View the PDF of this petition.

STATE OF IOWA
DEPARTMENT OF INSPECTIONS AND APPEALS
PETITION FOR DECLARATORY ORDER
Filed by Trestle Corporation Limited

FILING NO.

COMES NOW, Trestle Corporation Limited [hereinafter "Trestle Co"] and files this Petition for Declaratory Order with the Department of Inspections and Appeals [hereinafter the "Department"], and requests and declaratory ruling from the Department of lnspections and Appeals [hereinafter the "DDA"] pursuant to Iowa Code Section 17A.9 and 481 Iowa Administrative Code Chapter 3.

Petitioner requests that the Department declare the following:

1) Trestle Co's device known as "Games of Skill" is an electrical and mechanical amusement device that is lawful to own, possess, and offer for use by any person at any location because it complies with the provisions set forth in Iowa Code Section 99B.52(1).

2) Trestle Co's device known as "Games of Skill" is an electrical and mechanical amusement device that award a prize, but the outcome is primarily determined by the skill or knowledge of the operator; therefore, the electrical and mechanical amusement device is not subject to the registration provisions set forth in Iowa Code sections 99B.53(1).

3) Trestle Co's device known as 'Games of Skill" is an electrical and mechanical amusement device that awards a prize, but the outcome is primarily determined by the skill or knowledge of the operator; therefore, the use of the electrical and mechanical device is not subject to the penalty provisions set forth in Iowa Code sections 99B.54.

4) That Trestle Co's device known as "Games of Skill" is an electrical and mechanical amusement device that awards a prize, but is not an illegal gambling device under Iowa Code section 725.9.

I. STATEMENT OF FACTS

GAMES OF SKILL is a vertical screen skill device. Below is a description of the device and its respective skill functions.

  1. The Games of Skill is a machine that offers two (2) different game themes that a player may select to play.
  2. The Games of Skill device contains a touch screen display and two external buttons that are used to navigate throughout the terminal.
  3. A player inserts money into the Games of Skill device through a bill acceptor located at the front of the cabinet. The bill acceptor accepts U.S. notes of varying denominations.
  4. The Games of Skill device contain a ticket printer which, when the collect button on the exterior of the machine is pressed, or by pressing the "REDEEM" onscreen icon, prints a ticket that can be redeemed.
  5. The Games of Skill device contain a "Nudge" feature, which must successfully completed before the prize can be won.
  6. The Games of Skill device contains the "Skill It" feature, which determines the actual prize that will be awarded based on the patron's performance using the feature.
  7. The Games of Skill device contains a "Follow Thru" feature, which provides the patron with an opportunity to win up to 106% of the play level used in the base game. This feature always is available to the patron unless the patron has obtained a prize value greater than their initial play.
  8. The Games ofSkill devices offer several meters and logs on accounting, and maintains its own accounting data.
  9. Each game theme includes a Help feature. Activating the Help feature within a game theme produces a screen which furnishes explanations and the pay tables for the active game theme. The Help feature can be activated at any time prior to the engagement of play.

Nudge Feature

The Games of Skill device is a nudge style game. Upon selection of a game theme and play level, the player must activate the "Play" button which will initiate game play. As configured, when game play is initiated, the reels will spin and stop automatically or the patron may select the "Stop" button to manually stop the reels. Alternatively, the game display can be configured to display "Shutters" instead of spinning reels.

When game play is initiated on either of the game themes, an undecided reel outcome is displayed and the patron must make a decision to "Nudge" the symbols either left or right to essentially select the desired symbol in order to align a winning combination. During the Nudge function, a symbol position on one of the reels will be vertically split in half, displaying two (2) possible symbol combination outcomes. The "Nudge" function provides two (2) nudge buttons, which will be displayed to the patron side-by-side. The nudge buttons indicate the direction in which the symbols will be nudged, either left or right in order to select the desired symbol. The Nudge function requires the patron to evaluate the reels and select one of the buttons in order to nudge the symbols either left or right to align a winning symbol combination and complete the process. Alternatively, the game allows for the patron to select the desired symbol to nudge by simply using the touch screen displays to select the symbol instead of selecting the nudge buttons.

The Nudge function must be completed within a thirty (30) second time limit. Should a player fail to either nudge the symbols in the correct direction to obtain a winning combination, or complete the nudge function within the time limit, the potential prize will be forfeited.

Skill It Feature

The Games CJ/Skill device also contains the "Skill It" feature. The Skill It feature is presented after each successful completion of the Nudge feature. The Skill It feature provides the patron with the opportunity to receive between 55% up to 110% of the potential prize that was attained during the Nudge feature. The Skill It feature presents the patron with a circular meter (similar to a speedometer) with an arrow indicator that will traverse from side-to-side at a uniform speed. The Skill It meter contains various percentages ranging from 55% up to 110% (displayed in 10% percent increments starting from 55% up to 110% and from 110% back down to 55%), which can potentially modify the prize amount that was attained during the Nudge feature. The available percentages are arranged on the meter starting with 110% at the center most position of the meter and the 55% in the two furthest positions from the center position of the meter. During the Skill It feature, the patron is provided with a "Stop" button, which is used to stop the arrow  indicator on the meter. The patron will be able to attain 100% of the potential win by successfully stopping the arrow indicator within the 100% range of the Skill It meter. The further away from the center line that the patron stops the arrow indicator, the lower the actual prize value will be. The Skill It feature grants the patron twenty-five (25) seconds to complete the process. Should the patron allow the timer to reach zero (0), any potential prize will be forfeited. The outcome of the Skill It feature will determine the actual prize that the patron will receive. For example, if the potential prize that was attained during the Nudge feature was .50, and the patron stops the arrow indicator precisely on the center line, the patron will receive 110% of the potential prize, which would equate to a prize amount of .55. In this example, if the patron stops the arrow indicator at 55%, the patron will receive a prize equal to .28.

Follow Thru Feature

The Games of Skill device contains a "Follow Thru" feature. The Follow Thru feature becomes available when a patron is availed  to a game outcome that does not have a potential winning outcome or in cases where the patron does not successfully complete the nudge function. The Follow Thru bonus feature will provide the patron with an opportunity to win up to 106% of the play level used in the base game. For example, in cases where the patron enters the Follow Thru feature with a play level of 1.00, successfully completing the Follow Thru feature will award a prize equal to 1.06. However, in cases where the patron enters the Follow Thru feature with a play level which causes the prize from the Follow Thru feature to have a residual value, the prize is rounded down to the nearest whole cent. For example, in cases where the patron enters the Follow Thru bonus feature with a play level of .25, successfully completing the Follow Thru feature will award a prize equal to .26 (the prize is rounded down to this amount).

The Follow Thru bonus feature is similar to the children's game "Simon", whereby the patron must repeat a sequence. When the patron elects to play the Follow Thru feature, the game will display a page detailing the "instructions" for the Follow Thru feature. The game will display a 3x3 grid of nine (9) colored circles. These circles will illuminate in a random sequence that the patron will have to repeat, starting with one (1) circle being lit. The patron will need to follow (repeat) the correct sequence for a total of six (6) rounds of play, with each sequence adding another circle, until a total of six (6) sequences are successfully completed. If performed successfully, the patron is assured a prize of 106% of the purchase price to play the game.

If the patron fails to complete the six (6) sequences, either by touching the wrong symbol, or by having approximately twenty (20) seconds of inactivity, the feature will end and no prize will be awarded. Upon completion of the "Follow Thru" bonus feature, the game will return to its normal operating state. The "Follow Thru" feature is offered if the patron successfully completes the nudge function to align a winning symbol combination.

The Follow Thru bonus feature ensures that the patron has the opportunity to win a prize for every play initiated on GAMES OF SKILL. In other words, the Follow Thru feature provides the patron with an opportunity to win a prize 100% of the time. Additionally, when the patron has the opportunity to access the Follow Thru feature, successfully completing the feature awards a prize up to 106% of the play level used in the base game.

II.  STATEMENT OF THE LAW

Iowa Code § 17A.9(1)(a) (2015) provides that "[a]ny person may petition an agency for a declaratory order as to the applicability to specified circumstances of the statute, rule or order within the primary jurisdiction of the agency."

PETITIONER HEREBY REQUESTS THAT:

1)  The lab report for "GAMES OF SKILL" be reviewed by the agency;
2)  That a live or remote inspection of the equipment and its features be conducted;
3)  That a ruling be issued that:

  1. Trestle Co's device known as "Games of Skill" is an electrical and mechanical amusement device that is lawful to own, possess, and offer for use by any person at any location because it complies with the provisions set forth in Iowa Code Section 99B.52(1).
  2. Trestle Co's device known as "Games of Skill" is an electrical and mechanical amusement device that award a prize, but the outcome is primarily determined by the skill or knowledge of the operator; therefore, the electrical and mechanical amusement device is not subject to the registration provisions set forth in Iowa Code sections 998.53(1).
  3. Trestle Co's device known as "Games of Skill" is an electrical and mechanical amusement device that awards a prize, but the outcome is primarily detennined by the skill or knowledge of the operator; therefore, the use of the electrical and mechanical device is not subject to the penalty provisions set forth in Iowa Code sections 998.54.
  4. That Trestle Co's device known as "Games of Skill" is an electrical and mechanical amusement device that awards a prize, but is not an illegal gambling device under Iowa Code section 725.9.

RESPECTFULLY SUBMITTED ALONG WITH THE LAB REPORT ON THIS 25TH DAY OF FEBRUARY, 2021.

Prepared by:

Edward R. T. Bullard
Law Office of Edward R. T. Bullard
401 Westpart Court, Suite 200
Peachtree City, GA 30269
(678) 961-0120
edward@bullardlaw.net
Edward R. T. Bullard
Outside General Counsel for Petitioner