ACGC Alternate Standards to 25 C.F.R. Part 547
April 24, 2018
Page 3 of 3

Part 547 Minimum Technical Standard

ACGC Alternate Standard

25 C.F.R. § 547.16(b)

Disclaimers. The Player Interface must
continually display:
(1) "Malfunctions void all prizes and
plays" or equivalent; and
(2) "Actual Prizes Determined by Bingo
(or other applicable Class II game)
Play. Other Displays for Entertainment
Only" or equivalent

Disclaimers.

(1) Except for Class II Mobile Devices, the
Player Interface must continually
display:

(i) "Malfunctions void all prizes and
plays" or equivalent; and

(ii) "Actual Prizes Determined by
Bingo (or applicable Class II
game) Play. Other Displays for
Entertainment Only" or equivalent.

(2) For Class II Mobile Devices, the
information
in subsection (b)(1)(i)-(ii), must be
displayed prior to
initiating a session.

25 C.F.R. § 547.16(c)

Odds notification. If the odds of winning any
advertised top prize exceeds 100 million to
one, the Player Interface must display: "Odds
of winning the advertised top prize exceeds
100 million to one" or equivalent.

Odds Notification.

(1) If the odds of winning any advertised
top prize exceeds 100 million to one,
the Player Interface (excluding any
Class II Mobile Device) must display:
"Odds of winning the advertised top
prize exceeds 100 million to one" or
equivalent.

(2) For Class II Mobile Devices, the
information required by subsection
(c)(1) must be displayed to the player
prior to the start of game play.



ACGC Alternate Standards to 25 C.F.R. Part 547
April 24, 2018
Page 2 of 3

Part 547 Minimum Technical Standard

ACGC Alternate Standard

25 C.F.R. § 547.5(b)(1)(iv)

The testing laboratory's written report confirms
that the operation of a player interface
prototype has been certified that it will not be
compromised or affected by electrostatic
discharge, liquid spills, electromagnetic
interference, or any other tests required by the
TGRA;

The testing laboratory's written report confirms
that the operation of a player interface
prototype, other than a Class II Mobile Device,
has been certified that it will not be
compromised or affected by electrostatic
discharge, liquid spills, electromagnetic
interference, radio frequency interference, or
any other tests required by the TGRA. Any
Class II Mobile Device must comply with the
applicable requirements for such device set by
the Federal Communications Commission;

25 C.F.R. § 547.7(d)

Player interface. The player interface must
exhibit a serial number and date of
manufacture and include a method or means to:
(1) Display information to a player; and
(2) Allow the player to interact with the
Class II gaming system.

Player Interface.

(1) Any player interface, except for a
Class IIT Mobile Device, must exhibit a sd
number and date of date of manufacture;
(2) At the time of Class II Mobile Gaming
software installation, a Class II Mobile
Device shall be issued a unique
identification number that shall be
recorded by the operation. The Class II
Mobile Device identification number
shall not be transferable to a different
Class II Mobile Device;
(3) Any player interface must include a
method to:
(i) Display information to a player;
and
(ii) Allow the player to interact with
the Class II gaming system.
(4) Any player interface is restricted to one
active log in per session.



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April 24, 2018

Michael J. Prieto, Chairman

Agua Caliente Gaming Commission
3700 Tachevah Drive, Bld. A, Ste. 102
Palm Springs, CA 92262

Re: Submission of alternate standards to 25 C.F.R. Part 547
Dear Chairman Prieto:

Iam writing with respect to your request on behalf of the Agua Caliente Gaming
Commission (ACGC) for review and approval of Alternative Standards Adopted for Class II
Games Played Using Mobile Devices. The alternate standards were approved by the ACGC on
February 20, 2018, and your request was received by the National Indian Gaming Commission
(NIGC) on February 26, 2018. Pursuant to 25 C.F.R § 547.17(b), the Chair of the NIGC may
approve or object to alternate standards approved by a tribal gaming regulatory authority.

Thank you for providing the alternate standards for my review. In addition to the
alternate standards, your detailed submission provided documentation of several ACGC
regulatory initiatives related to Class II gaming using mobile devices which, while not requiring
my approval, were helpful in assessing the role of the alternate standards within the overall
regulatory framework. For purposes of this letter, however, the attached chart titled “ACGC
Alternate Standards to 25 C.F.R. Part 547” enumerates only the 25 C.F.R Part 547 minimum
technical standards and the proposed alternate standards.

The attached ACGC Alternate Standards to 25 C.F.R. Part 547 are hereby approved as
the alternate standards appear to achieve a level of security and integrity sufficient to accomplish
the purpose of the standards they are to replace. If you have any questions concerning this letter,
please contact Director of Technology Travis Waldo or Staff Attorey Austin Badger at (202)
632-7003.

incerely,

nodev O. Chaudhuri
hairman

NEW MAILING ADDRESS: NIGC/DEPARTMENT OF THE INTERIOR 1849 C Street NW, Mail Stop # 1621 Washington, DC 20240 Tel: 202.632.7003 Fax: 202.632.7066

REGIONAL OFFICES Portland, OR; Sacramento, CA; Phoenix, AZ; St. Paul, MN; Tulsa OK; Oklahoma City, OK
www.nicc.cov


Chairman Michael J. Prieto, Agua Caliente Gaming Commission
Re: Submission of alternate standards to 25 C.F.R. Part 547
April 24, 2018

Page 2 of 2

ce: John T. Plata, General Counsel, Agua Caliente Band of Cahuilla Indians
Joseph H. Webster, Hobbs Straus Dean & Walker, LLP

Enclosure


ACGC Alternate Standards to
25 C.F.R. Part 547

Part 547 Minimum Technical Standard

ACGC Alternate Standard

25 C.F.R. § 547.2

Class II gaming system. All components,
whether or not technologic aids in electronic,
computer, mechanical, or other technologic
form, that function together to aid the play of
one or more Class II games, including
accounting functions mandated by these
regulations.

Player interface. Any component(s) of a Class
II gaming system, including an electronic or
technologic aid (not limited to terminals,
player stations, handhelds, fixed units, etc.),
that directly enables player interaction in a
Class II game.

Class II Gaming System. All components,
whether or not technologic aids in electronic,
computer, mechanical, or other technologic
form, such as a Class II Mobile Gaming
System, that function together to aid the play
of one or more Class II games, including
accounting functions mandated by these
regulations.

Player Interface. Any component(s) of a
Class II gaming system, including an electronic
or technologic aid (not limited to terminals,
player stations, handhelds such as a Class II
Mobile Device, fixed units, etc.), that directly
enables player interaction in a Class II game.

25 C.F.R. § 547.4(b)

Approved gaming equipment and software
only. All gaming equipment and software used
with Class II gaming systems must be identical
in all respects to a prototype reviewed and
tested by a testing laboratory and approved for
use by the TGRA pursuant to §547.5(a) and

(b).

Approved gaming equipment and software
only. All gaming equipment, except for any
Class II Mobile Device, and software used
with Class II gaming systems must be identical
in all respects to a prototype reviewed and
tested by a testing laboratory and approved for
use by the TGRA pursuant to §547.5(a) and
(b). Any Class II Mobile Device used with a
Class II Mobile Gaming System must comply
with the applicable requirements for such
device set by the Federal Communications
Commission. The operation shall ensure that
any Class II Mobile Gaming occurs only on a
Class II Mobile Device utilizing an operating
system that has been reviewed and approved
for use by the TGRA