A CASE FOR LEGALIZING POKER IN THE AGE OF ARTIFICIAL INTELLIGENCE: AN INTERNATIONAL PERSPECTIVE ON GAMBLING AND BETTING LAWS

Gaming Law ReviewVol. 24, No. 5 ArticlesFree AccessA CASE FOR LEGALIZING POKER IN THE AGE OF ARTIFICIAL INTELLIGENCE: AN INTERNATIONAL PERSPECTIVE ON GAMBLING AND BETTING LAWSAmogh Mittal and Sidheswar SahooAmogh MittalAmogh Mittal is a student at National Law University in Punjab, India.Search for more papers by this author and Sidheswar SahooSidheswar Sahoo is a student at National Law University in Odisha, India.Search for more papers by this authorPublished Online:16 Jun 2020https://doi.org/10.1089/glr2.2020.0003AboutSectionsPDF/EPUB ToolsAdd to favoritesDownload CitationsTrack CitationsPermissions Back To Publication ShareShare onFacebookTwitterLinked InRedditEmail 1. IntroductionIt is said that cricket is a game of uncertainty which is true for every other sport played out there. There are always big upsets and surprises depending upon the individuals who play the sport and they are bound to err after some consistent performances. Due to the same reason, betting on sports has been considered to be a risky task due to the sport's unpredictability. In gambling and poker specifically, the skill of prediction of the outcome matters to the extent that some gamblers can achieve better returns than others. Merriam Webster defines poker as a card game in which a player bets that he holds the cards which have a higher value than others. Subsequently, players may choose to raise the bet or drop out in continuation of the game. In the end, the player holding cards of the highest value wins the game. Draw Poker, Stud Poker, and Community Card poker are three popular types of poker which are played in casinos. Texas Hold ‘Em and Omaha Hold ‘Em are quite famous among poker fanatics worldwide.1 Poker has turned into an actual sport in few countries and poker tournaments often take place at impressive locations all around the world.2The central question surrounding the legality of sports has been the essential debate on “game of chance” vs. “game of skill.” The question which arises now is whether there exists some scope of application of skill in the game of poker or whether it is completely based on luck or chance. Proponents of poker have argued that the game involves the skills of players in terms of bluffing, memorizing the cards, etc. However, the opponents contend that in poker, the cards dealt with are downwards without any control of any player, which makes it unpredictable and, thus, is wholly based on chance.The authors argue that artificial intelligence (AI) holds the power to control that amount of money which will completely change the way gambling is done. With the advent of artificial intelligence, it is easy to derive a pattern by accumulating all the data and statistics which is available for any particular sport or game.3 Machine learning is a variant of artificial intelligence which has the ability to learn from the environment and use the same to predict the outcomes.4 It takes in countless factors such as previous matches, recent record, and strength and weakness of players before arriving at a conclusion.5 The purpose of this article is to examine whether AI can eliminate the “luck” factor from poker and gambling and betting in general or whether it is still a game dependent on the luck factor.2. Game of Skill vs. Game of Chance: The Fundamental DebateThe fate of poker and many other card games has been dependent upon the debate of skill and chance for a few years now.6 Countries have adopted different approaches to defining chance and skill and their laws are based upon the outcome of the tests. A majority of them follow the dominant factor test (also known as a predominant test). But in the U.S., other tests such as the “material element” test and “any chance” test have also been followed to determine the fate of a game.7 A game can be decided purely by luck, skill, or a mix of both chance and skill. Even cricket and football require some amount of luck to go your way for the desired result. The courts should analyze these by taking the game's context into account. In simple words, chance is defined as “the occurrence of events in the absence of any obvious intention,” and skill as “an ability to do an activity especially because you have practiced it.” The destiny of the games is heavily dependent on how legal analysis balances skill and chance against each other. The courts, while deciding a result, must look at the parameters and should not have a confined definition of skill or chance.8 For example, a lottery is something which is based on pure luck and no one has control of the numbers that will win in the end. But a game like poker, bridge, or rummy has participants who may be equally skilled but the outcome is sometimes decided by factors which relate to chance. The courts in different countries take this “chance” factor to determine the laws in their respective countries. That is the very reason why the law on gambling is not uniform everywhere. This article analyzes whether AI will help in making the law consistent in all states.In a landmark case in the New York Court of Appeals in 1904,9 the court concluded that the character of a game is determined by the dominating element out of skill or chance. So even if a game had a degree of chance to determine the outcome, it would still be legal if skill dominated the chance aspect in the game.10 This test became the principal test to determine whether a game came under gambling or not. Gambling came under the ambit of chance then. Later, in 1949, the Missouri Court of Appeals in the case of “State v. One “Jack and Jill” Pinball Machine” established that gambling consists of three major elements: (1) risk or consideration, (2) a degree of chance, and (3) a prize or reward associated with it.11The UK seems to follow the “any chance” test where it defines “gaming” as a chance-based activity to win a prize in Section 6 of the Gambling Act 2005.12 A game is considered a chance even if the skill factor supersedes the chance factor associated with the game.13 In addition to it, Section 52 of the Gaming Act 1968 defined a game of chance as something which does not include any athletic game or sport.14 Generally, card and dice games fall under the ambit of “gaming” in the UK. It emphasizes more the prize aspect of a game due to which social gaming or “free play” also fall under “gaming,” and is considered illegal if there is a monetary value attached to it. The new Gambling Act has complicated things rather than simplifying them.15 As it stands now, a game which has merely an element of chance will be considered a game of chance. It is even argued that under the new law, a game of chess can be considered a game of chance as players play with different colors and one may have a greater advantage than the other if he gets his desired color.India, on the other hand, has followed the footsteps of the U.S. with regards to the “dominant factor” test. The “skill versus chance” question was first addressed in the Satyanarayana case16 and the Lakshmanan case.17 The courts were of the opinion that no game exists which can have skill as the individual factor to determine the result. Every game involves an element of chance though the degree may be very small. In another Supreme Court decision in State of Bombay v. R.M.D. Chamarbaugwala,18 the court propounded that if a game contains both elements, i.e., skill and chance, it would be considered a game of skill.19 The current Indian stance is “whether a game is of chance or skill is a question of fact to be decided on the facts and circumstances of each case.”203. Assessing the Legality of Poker in Various JurisdictionsOver the years, the worldwide popularity of poker as a game has increased overwhelmingly. Since 1970, the growth of poker has accelerated, making it one of the most popular card games in the world with billions of dollars being staked on it every year.21 However, there still exists an ambiguity over the legality of poker in different jurisdictions with lack of any conclusive decision on the same. Certain jurisdictions consider poker to be illegal, while others treat it as legal and regulate the same, which have been analyzed hereunder.A. Legality of poker in United States of AmericaPoker has been one of the most popular card games in the United States of America. Poker became exponentially popular only after 1970 when poker tournaments were started under the banner of the World Series of Poker.22 Gambling is regulated in the United States via federal and state laws, with most of the substantive laws defining gambling being state laws.23 Some states like Nevada allow different types of gambling,24 and other states like Utah and Hawaii have decided against legalizing any type of gambling, be it live or online.25 Moreover, certain federal gambling statutes, like the Illegal Gambling Business Act (IGBA)26 and the Wire Act of 196127 have failed to make any mention of “poker,” leaving the job of interpretation to the courts and enforcement authorities.28 Thus, the passing of certain statutes and judgments have cast an aspersion upon the legality of poker in the country.American jurisprudence has made a clear distinction between offline and online poker. With regards to legality of offline poker, the courts have dealt with the fundamental question of “game of skill” vs. “game of chance” as has been discussed above. The District Court of Nevada in Baxter v. United States29 dealt with the question of legality of poker. The court found that the plaintiff won a certain amount of money in poker based on his skills, and thereby declared that poker can be categorized as a game of skill.30 Similarly, in Gallatin County v. D & R Music & Vending, Inc.,31 the court held that a considerable amount of skill is involved while playing poker. However, the North Carolina Court of Appeals in Joker Club, LLC v. Hardin32 held poker to predominantly be a game of chance. Similarly, a federal appeals court, in the landmark case of United States v. DiCristina,33 overturned the decision of the district court34 and held that poker violated the rules laid down under the IGBA. Moreover, the court in United States v. Gotti35 held that the outcome in poker depends on chance to a material degree. Even though the courts have specified a distinction between skill and chance, the states have the final call in considering a particular gambling game legal or illegal. The state governments are generally concerned about the outcomes in making a gambling game legal. They act upon their discretion and they define gambling in their own words. This means that two different states may have non-identical definitions for gambling.With regard to online poker, similar contradictions and paradoxes exist in American law. the Wire Act of 1961 prohibited and restricted betting or gambling which was done through telecommunications.36 However, the Department of Justice (DOJ), in response to a query, held that the act was inapplicable to online lotteries and similar games,37 which enabled the states to authorize online games including poker. The Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA) is another U.S. law which regulates online gambling. The UIGEA prohibits a “person engaged in the business of betting or wagering” from knowingly accepting most forms of payment “in connection with the participation of another person in unlawful Internet gambling.38 The UIGEA does not directly ban or prohibit internet gambling, but it seeks to restrict the acceptance by certain people of certain kinds of payments connected to Internet gambling.39 Thus, if a state deems poker to be legal, the provisions of the UIGEA will become inapplicable to that particular state.40 Thus, the legality of both offline and online poker lacks uniformity in state action and finality in court decisions.B. Legality of poker in EuropeThe law concerning poker in Europe is quite unclear and vague41 because European countries have taken different approaches in dealing with the question of legality of poker. Some countries have declared poker to be legal, while others treat it as illegal. In the UK, the threshold for a card game to qualify as legal is very high, as it follows the “any factor test,” which has been analyzed above. Under the Gaming Act of 1845 and, subsequently, the Gaming Act, 1968, poker has been held to be classified as a “game of chance.”42 Moreover, with the passing of the Gambling Act, 2005, games involving an element of skill are also considered to be “games of chance”43 and, therefore, poker or any card games are to be deemed as “games of chance.” Moreover, the Court of Appeal in Rex v. Tompson44 held that for a card game to qualify as legal, it must be proved that it involves pure skill.The French law on gambling makes a clear distinction between “game of skill” and “game of chance.”45 On deciding the legality of games which mix skill and chance, the French law has evolved certain criteria. The first condition is determining whether skill dominates chance or vice-versa through a mathematical way, by properly analyzing the rules of the game. The second criterion is the social risk or the social consequences involved with a particular game. With regard to poker, the French Supreme Court held poker is a game of chance when played for money.46 In Germany, poker is considered to be a game of chance and is regulated by the state through state-owned casinos where it is legal.47 Moreover, the law in the majority of states does not permit online poker.48 Similarly, in Norway, poker is considered a game of chance rather than a game of skill.49C. Legality of poker in IndiaIn India, the Constitution enables the states to make laws on the subject of betting and gambling.50 However, there is an absence of clear, common, and comprehensive legislation clarifying the status and legality of poker which has led to uncertainty and vagueness.51 There exist diametrically opposite judgments of various High Courts on the question of legality of poker. On one hand, poker has been held to be a game of skill and therefore legal. Whereas on the other hand, some decisions have regarded poker to be a game of chance and therefore illegal.52The Karnataka High Court, in Indian Poker Association v. State of Karnataka,53 dealt with the question of legality of poker. Absent a comment on its legality, the court held that poker does not require a license and cannot be interrupted by the authorities. The courts based their reasoning on various precedents54 where it was propounded that card games involve a limited element of chance based on the dealing and playing of cards which is not a threshold high enough to qualify the same as a “game of chance.” However, the Gujarat High Court, in Dominance Games Pvt. Ltd. v. State of Gujarat and Ors,55 held that poker (Texas variation) is a game of chance and thus, illegal. The court based its reasoning on past court decisions56 where card games have been held to be a “game of chance” on the fact that there is no control over how the cards are dealt, which makes it unpredictable. Similarly, the Supreme Court in M. J. Sivani v. State of Karnataka57 held that games like online/video-game poker double up to have little or zero scope of using one's skill, and categorized them as games of chance. Therefore, there exist arguments from both the sides, however, there is no finality on the question of legality of poker under Indian law.4. Role of Artificial Intelligence in PredictionWith the intersection of sports and technology, the ability to accurately predict the results of a sport has increased exponentially. With the emergence of AI and advanced technology like sensor tools and RFID chips,58 the prospects of correct prediction of results are enhanced. One of the many applications of this has been WinnerOdds, an AI model which assists people in betting by predicting the results in tennis.59 Similarly, in football, an AI system called Strategem, built by an UK-based betting company, predicted the scores of football games.60 The mere fact that AI models can precisely predict the outcomes of sports reflects the fact that there is an application of skill involved while playing these games. Specifically, with regard to gambling and betting, the advantage that AI brings to the game is that it doesn't need to be correct all the time. A bettor or a gambler is just wanting that extra edge over their competitors which the AI duly provides as has been argued herein.With regards to poker, a multitude of studies has been undertaken to analyze the application of the “skill factor” in poker. Israeli mathematician and professor at Tel Aviv University, Noga Alon, undertook a detailed and mathematical analysis of the use of skill or chance in poker. The hypothesis which Noga Alon reaches at is that in a game of poker, a player will be able to win each hand contingent on the fact that he has properly analyzed the odds and probabilities based on the cards dealt.61 Moreover, with the knowledge of betting patterns of the opponents and their reactions, the probability of winning every hand becomes very high.62 Alon concludes that skill is a predominant and substantial element of poker and that the game of poker involves an in-depth study of quantum mechanics, statistical physics, game theory, and human psychology.63 Similarly, Sklansky, in his book The Theory of Poker, describes how the game of poker involves skill, and the luck factor can be reduced to a bare minimum with knowledge of statistics and gaming patterns.64 Therefore, a professional player has a better chance to calculate the available possibilities easily. After making the perfect calculation, the professional player can use it to further calculate and evaluate the chances of winning. Professional players adjust their games according to their opponents because the same strategy may not work against another opponent even though that player may be weak.65 Thus, it can be concluded that there exists the use of skill in games of poker, however, whether it is possible to achieve it or not, is a question which remains unanswered.Lately, AI systems have been successful in defeating top poker players around the world reflecting the application of skill in the game. Pluribus, which is an AI model developed by the Carnegie Mellon University (CMU) and Facebook, beat two poker professionals, playing 5,000 rounds separately with each of the two. 66 Moreover, Pluribus beat five poker professionals for a total of 10,000 hands.67 The developers contend that the reason behind this extraordinary performance is its ability to effectively use mixed strategies and modes of computation.68 Similarly, Libratus, another AI model developed by a professor and PhD student of CMU, beat four professional poker players over 120,000 hands.69 Interestingly, the developers mentioned that the model does not use expert domain knowledge and can be replicated by humans.70In 2015, DeepStack became the first AI-based model to beat professional poker players.71 Deepstack combined deep machine learning and algorithms to consistently win the games of poker.72 The three examples of AI models beating up to five professional poker players in a considerable number of hands has a lot to say about poker being a game of skill. The fact that AI models beat the players reflects the presence of skill in the game, because if poker was dominated by chance, such results would not have been achieved. It would be safe to say that these AI technologies could identify each player's skill individually and modify their game accordingly. This is revolutionary because the long-lasting debate of poker being a game of chance or skill stands on the verge of getting settled.5. ConclusionA sport is unique due to its unpredictability. In all these years we have seen many upsets in games which has kept the sports industry going strong. Meanwhile, the gambling and betting industry has reached unprecedented heights. As we have seen, the journey of poker has been quite a fascinating one, and still, there is some ambiguity about its legal position in many countries. The debate of skill and chance has always seen new arguments as time has progressed. The courts have applied various tests to make a final call regarding poker and other card-based games. The U.S., Europe, and India have had their history over this question, which has kept the fans of the game at constant skepticism regarding the future of the game. Maybe the courts will change their stance with the evolution of artificial intelligence. The technology holds the power to change the entire gambling scenario in a short period. As we have seen, many studies have inferred about poker being a skill-based game which, coupled with the use of AI, makes things interesting. We have seen recent examples of AI technologies beating top poker players with ease, which reassures the fact that poker is a game of skill. It would be difficult for any technology to win every time in a game of chance. The AI can actually study the player's behavior and the player's psychology due to which it improvises the opponent's next moves. We have seen previous instances of AI defeating players in chess, which is now replicated in a game of poker. Thus, the use of AI can now be a valid argument in proving poker is a game of skill. With so much money involved, it will be finally encouraging for poker fans all around the world.1 G. Meyer, T. Brosowski, and T. Hayer, Is Poker a Game of Skill or Chance? A Quasi-Experimental Study, 29 J. Gambling Stud. 535 (2013).2 Global Gaming Market Revenues projected To Exceed $525 Billion by 2023, Prnewswire (Apr. 25, 2019), https://www.prnewswire.com/news-releases/global-gaming-market-revenues-projected-to-exceed-525-billion-by-2023-300838290.html.3 Andrew Tarantola, AI Is Better at Bluffing Than Professional Gamblers, Engadget (Jan. 17, 2019), https://www.engadget.com/2019/01/17/ai-is-better-at-bluffing-than-professional-gamblers/.4 Sumbo Bello, How AI Takes the “Luck” Out of Gambling, Edgy (Jan. 21, 2019, 1:15 PM), https://edgy.app/ai-gambling.5 Brian O'Connell, Artificial Intelligence Is Changing the Sports Betting Game, Science101 (June 21, 2019), https://www.science101.com/artificial-Intelligence-is-changing-the-sports-betting-game/.6 Ryan Mindell, Context Matters: Luck and the Paradox of Skill, 22(5) Gaming L. Rev. 270 (2018).7 Id.8 David O. Klein, Games of Skill v. Games of Chance—The Legal Analysis, Mondaq (Aug. 23, 2018), https://www.mondaq.com/unitedstates/Media-Telecoms-IT-Entertainment/730092/Games-Of-Skill-V-Games-Of-Chance-The-Legal-Analysis.9 People v. Lavin, 179 N.Y. 164 (N.Y. 1904).10 Bennett Liebman, Chance v. Skill in New York's Law of Gambling: Has the Game Changed?, 13(6) Gaming L. Rev. 461 (2009).11 State v. One “Jack and Jill” Pinball, 224 S.W.2d 854 (Mo. Ct. App. 1949).12 Gambling Act 2005 § 6(2). [hereinafter Gambling Act].13 Joseph M. Kelly, Zeeshan Dhar, And Thibault Verbiest, Poker and the Law: Is It a Game of Skill or Chance and Legally Does It Matter?, 11(3) Gaming L. Rev. 190 (2007) [hereinafter Kelly].14 Gaming Act 1968 § 52.15 Gambling Act 2005 § 6(2).16 State of Andhra Pradesh v. K. Satyanarayana, AIR 1968 SC 825 [hereinafter Satyanarayan].17 Dr. K.R. Lakshmanan v. State of Tamil Nadu, AIR 1996 SC 1153.18 State of Bombay v. R.M.D. Chamarbaugwala, AIR 1957 SC 699.19 Gowree Gokhale and Rishabh Sharma, The ‘Skill’ Element in Fantasy Sports Games, inLaws Relating to Fantasy Sports Games in India 9 (2018).20 Manoranjithan Manamyil Mandram v. State of Tamil Nadu, AIR 2005 Mad 261.21 Jay Satya, Legality of Poker and Other Games of Skill: A Critical Analysis of India's Gaming Laws, 5(1) NUJS L. Rev. 93 (2012).22 See official website of the World Series of Poker, https://www.wsop.com/ (last visited Mar. 26, 2020, 06:34 PM).23 J. Gatto and M. Patrick, How the Evolution of Games Has Led to a Rise in Gambling Concerns: All Bets Are On! Gambling and Video Games, Nat'l L. Rev. (Sept. 16, 2018), https://www.natlawreview.com/article/how-evolution-games-has-led-to-rise-gambling-concerns-all-bets-are-gambling-and.24 A. Renfro, All In with Jack High: DiCristina as the Final Surge to Federally Legalize Online Texas Hold ‘Em Poker, 1(3) Texas A&M L. Rev. 751 (2014).25 Emily Roberts, Gambling Laws Across the United States Explained, LA Progressive (June 7, 2019), https://www.laprogressive.com/gambling-laws/.26 18 U.S.C. § 1955.27 18 U.S.C. § 1084.28 Haley, Inside the U.S. v. Dichristina Ruling: Separating Fact from Fluff, Pokerfuse (Aug. 29, 2012), https://pokerfuse.com/features/editorial-opinion/inside-the-us-v-dicristina-ruling-separating-fact-from-fluff/.29 Baxter v. United States, 633 F.Supp. 912 (D. Nev. 1986).30 Aaron Duncan, Gambling with the Myth of the American Dream (1st ed. Routledge 2015).31 Gallatin County v. D & R Music & Vending, Inc., 208 Mont. 138 (Mont. 1984).32 Joker Club, LLC v. Hardin, 643 S.E.2d 626, 591 (N.C. App. 2007).33 United States v. DiCristina, 726 F.3d 92 (2d Cir. 2013).34 886 F. Supp. 2d 164 (E.D.N.Y. 2012).35 United States v. Gotti, 459 F.3d 296, 342 (2d Cir. 2006).36 Greenberg Traurig Government Contracts and Projects Practice, DOJ's Reversal on the Wire Act—What It Means for Internet Gaming, Nat'l L. Rev. (Jan. 3, 2012), https://www.natlawreview.com/article/doj-s-reversal-wire-act-what-it-means-internet-gaming.37 Id.38 Unlawful Internet Gambling Enforcement Act, 31 U.S.C. § 5363 (2006).39 T. Miles, S. Levitt, and A. Rosenfield, Is Texas Hold ‘Em a Game of Chance? A Legal and Economic Analysis, 101 Georgetown L. J. 581 (2013).40 M. Tselnik, Check, Raise, or Fold: Poker and the Unlawful Internet Gambling Enforcement Act, 35 Hofstra L. Rev. 1617 (2007).41 Arne M. Ottosen, Taxation of Online Poker in Denmark, 10(4) Gaming L. Rev. 358 (2006).42 Kelly, supra note 13.43 Gambling Act 2005 § 6(2).44 Rex v. Tompson, [1943] KB 650.45 D. Veaux and S. Durand, Gaming Contracts—Gambling (in French), JurisClasseur Contracts—Distribution Fasc. 3320, spéc. n°11.46 Cass. crim., 20 avr. 1945, S. 1945, 1, p.126.47 Speech of Dr. Wulf Hambach, Can Europe Fuel the Next Online Poker Boom? (speech at the World Poker Congress, Stockholm, June 28, 2006).48 Fifteen out the 16 states in Germany do not permit online poker.49 Concord Card Club case [Supreme Court of the Netherlands], 3 Mar. 1998, N.J. 1999, 59 (Neth).50 Indian Const. § 751 Abhishek Saxena and Aashna Kothiyal, Poker in India—Left Poker Faced by Regulations,Mondaq (Nov. 20, 2019), https://www.mondaq.com/india/Media-Telecoms-IT-Entertainment/866462/Poker-In-India--Left-Poker-Faced-By-Regulations.52 Id.53 Indian Poker Association v. State of Karnataka, (2013) SCC Online KAR 8536.54 Satyanarayan, supra note 16.55 Dominance Games Pvt. Ltd. v. State of Gujarat and Ors, (2018) 1 GLR 801.56 Nasir Salim Patel v. State of Maharashtra & Ors., WP (Criminal) 427 of 2017.57 M. J. Sivani v. State of Karnataka, AIR 1995 SC1770.58 William Synrem, Influence of Technology on Sports: A Policy-Based Perspective, 13 NUALS L. J. 51 (2019).59 B. Roy, AI Augmented Sports Revolution, Towards Data Science (Nov. 7, 2019), https://towardsdatascience.com/ai-augmented-sports-revolution-5c0727ba7004.60 M. Jha, Artificial Intelligence Can Win Football Matches, Great Learning (blog) (Dec. 4, 2019), https://www.mygreatlearning.com/blog/artificial-intelligence-can-win-football-matches/.61 Noga Alon, Poker, Chance and Skill (2007) (unpublished manuscript, Tel Aviv University), http://www.cs.tau.ac.il/~nogaa/PDFS/skill4.pdf [hereinafter Alon].62 Id.63 Id.64 David Sklansky, The Theory of Poker (4th ed., Two Plus Two Publishing 2005).65 Alon, supra note 61.66 James Vincent, Facebook and CMU's ‘Superhuman’ Poker AI Beats Human Pros, The Verge (July 11, 2019, 2:00 PM), https://www.theverge.com/2019/7/11/20690078/ai-poker-pluribus-facebook-cmu-texas-hold-em-six-player-no-limit.67 Carnegie Mellon University, AI Beats Professionals in Six-Player Poker, Science Daily (July 11, 2019), https://www.sciencedaily.com/releases/2019/07/190711141343.htm.68 Noam Brown and Tuomas Sandholm, Superhuman AI for Multiplayer Poker, 365 Science 885, 887 (2019).69 Byron Spice, How Card-Playing AI Beat Top Poker Pros, Futurity (Dec. 19, 2017), https://www.futurity.org/libratus-poker-artificial-intelligence-1635242/.70 Id.71 Katyana Quach, AI Shoves All In: DeepStack, Libratus Poker Bots Battle Texas Hold ‘Em Pros Heads Up,The Register (Jan. 14, 2017, 08:53 AM), https://www.theregister.co.uk/2017/01/14/deepstack/.72 Bernard Marr, Artificial Intelligence Masters the Game of Poker—What Does That Mean for Humans?Forbes (Sept. 13, 2019, 12:43 AM), https://www.forbes.com/sites/bernardmarr/2019/09/13/artificial-intelligence-masters-the-game-of-poker--what-does-that-mean-for-humans/#77654bee5f9e.FiguresReferencesRelatedDetails Volume 24Issue 5Jun 2020 InformationCopyright 2020, Mary Ann Liebert, Inc., publishersTo cite this article:Amogh Mittal and Sidheswar Sahoo.Gaming Law Review.Jun 2020.331-336.http://doi.org/10.1089/glr2.2020.0003Published in Volume: 24 Issue 5: June 16, 2020Online Ahead of Print:May 19, 2020Keywordsbettinggamblingartificial intelligencepokermachine learninggame of skill v. game of chancePDF download