Mr. Darin Willis 

Red-Five Gaming, LLC 

Suite 250 

103 N. Coast Hwy 10 1 

Encinitas, CA 92024 

Re: Game Opinion -- Un-Reel Slots 

Dear Mr. Willis: 

This responds to your request of December 1 1, 1998, for a game classification opinion for 

the card game entitled "Un-Reel Slots." Based on the materials submitted with your letter, we 

conclude that the game is Class 111. 

Gaming on Indian lands in the United States is subject to regulation under the Indian 

Gaming Regulatory Act (IGRA), 25 U. S.C. $270 1, et. seq., and regulations of the National 

Indian Gaming Commission, 25 C.F.R. $ 501, et. seq. The Act and regulatory scheme establish 

three broad types of gaming. Class I games are social games or traditional forms of Indian 

gaming played in connection with tribal celebrations. Class II and Class I11 games represent 

games which enjoy broad public play. Class I1 gaming includes bingo, games similar to bingo if 

played in the same location as bingo, and certain card games which are either expressly permitted 

in the state or are not explicitly prohibited by the laws of the state and are played in any location 

within the state. Specifically excluded by statute and regulation from Class II games are banked 

card games such as blackjack. If a particular game cannot come withm the definition of Class I or 

Class 11, the game is considered Class 111. See, generally, 25 U.S.C. 9 2703 and 25 C.F R. 502. 

The game of "Un-Reel Slots," as described in the materials submitted with your letter, is a 

non-traditional card game using a deck of 53 specially-designed cards with each card featuring 

one of seven figures similar to those found on a slot machine. A wild card is also added. After 

the participants place an initial bet, a hand of three cards is dealt to each player. The option for a 

draw card and a second bet is available. The cards are all dealt face up. In order to win a player 

must match two or more of the figures. Some matches of three or four figures pay more than do 

other matches. Players do not compete against each other but against the house, much as a slot 

machine player plays against the slot machine. The dealer does not take a hand but merely serves 

as the random generator in the distribution of cards. The dealer also collects the lost wagers and 

pays winners. In the theoretical sense, the house wins the bet if the individual player does not . 

obtain a match. The number of winners in a round is not limited to the high hand among the 

participants; any and all winning hands may be paid. The cards are shuffled after each hand 

resulting in a new random draw on the succeeding hand. 

1441 L STREET, N.W. 9TH FLOOR WASHINGTON. D.C. 20005 TEL.: 202-632-7003 FAX: 202-632-7066 
A key feature which precludes the game fiom being considered Class IT is the houseqlkrrrf banked nature of the game. The players do not compete against each other but only against the 

house much as in the play of a slot machine. This, of course, is exactly what the game intends to 

replicate. Under IGRA, as noted above, a house-banked card game may not be considered as 

Class 11. Because "Un-Reel Slots" cannot qualify as a Class I1 game, we conclude that it must be 

characterized as Class 111. 

If you have questions regarding this opinion please contact Bill Grant tiom our staff at 

(202) 632-7003. 

Barry W. Brandon 

General Counsel 

Copy to: 

Wanda Crowley 

lw Pueblo of Sandia Tribal Gaming Commission