PECHANGA INDIAN RESERVATION

General Counsel

Temecula Band of Luiseno Mission Indians Steve Bodmer

Deputy General Counsel

OFFICE OF THE GENERAL COUNSEL Michele iene ounse

Post Office Box 1477 * Temecula, CA 92593

Telephone (951) 770-6000 Fax (951) 695-7445 Associate General Counsel
Breann Nuuhiwa
Lindsey Fletcher
July 5, 2017

Of Counsel
Frank Lawrence

VIA US MAIL & ELECTRONIC MAIL
Vannice_Doulou@nigc.gov

Attention: Vannice Doulou

Chairman Jonodev Chaudhuri

Vice Chair Kathryn Isom-Clause

Associate Commissioner E. Sequoyah Simermeyer
National Indian Gaming Commission

1849 C Street NW

Mail Stop #1621

Washington, DC 20240

Re:  Pechanga Band of Luisenio Indians Comments on NIGC’s Draft Minimum Technical
Standards for Mobile Gaming Devices

Dear Chairman Chaudhuri, Vice Chair Isom-Clause, and Associate Commissioner Simermeyer:

The Pechanga Band of Luisefio Indians hereby submits its initial comments on the NIGC’s Draft
minimum technical standards for mobile gaming devices. We thank the NIGC for engaging in
consultations and requesting comments in advance of issuing guidance that will affect Indian
Tribes and the regulation their gaming operations. The NIGC’s initial draft of Section 547.18 is a
good first step in addressing issues raised by mobile gaming devices. However, the draft raises
concerns that should be resolved before this section is adopted.

First, Section 547.18 is vague as to the terms it uses and thus, subsequent drafts should include
definitions. Specifically, “wireless player interface” and “wireless gaming system” need to be
clearly defined. These terms are used numerous times throughout the draft and are subject to
misinterpretation without definitions. The term “wireless player interface” should also be defined
in a way to distinguish it from a “player interface” (547.2) and the obligations and requirements
associated therewith.

Second, there appears to be at least one provision which mistakenly refers to a “wireless player
interface,” when it should refer to a “wireless gaming system.” Section 547.18(b)(4) states “[a]
wireless player interface must employ encryption and strong user authentication methods.” The
obligation for encryption and authentication methods are more appropriately placed on the
wireless gaming system (ic., the software that is downloaded to the wireless player interface in
order to participate in the game).



Chairman Jonodev Chaudhuri
National Indian Gaming Commission
July 5, 2017

Third, Section 547.18 must be drafted to account for the fact that “wireless player interfaces” will
often be mobile devices owned by patrons. Thus, it may not be practical for the gaming system to
“disable all exposed network connectivity ports” on a patron-owned mobile device, or for a
patron-owned mobile device to “be designed or programmed such that it may only communicate
with authorized gaming systems”, as would be required by Sections 547.18(a)(2) and (b)(3).

Moreover, Section 547.18 should clarify the testing requirements applicable to patron-owned
mobile devices that are used to connect to a Class II wireless gaming system. As currently drafted,
and if the existing definition of “player interface” is interpreted to include patron-owed mobile
devices, such devices would be subject testing to confirm compliance with certain standards
which are impractical. For example, Section 547.7(d) would require the patron-owned mobile
device to display “a serial number and date of manufacture,” and 547.16(b) would require the
devices to continually display “malfunctions void all prices and plays” and “actual prices
determined by Bingo.” It may be more appropriate that certain display standards and testing
requirements are applicable to the gaming software, and not the patron device, that is downloaded
in order to participate in a game.

We appreciate the opportunity to raise these important issues for your consideration and look
forward to further discussions on this topic.

Lindsey Fletcher
Associate General Counsel

PECHANGA INDIAN RESERVATION

Temecula Band of Luiseno Mission Indians