APR 7 1999 

Mr. D.K. Thomas, Director 

Eurotek Designs USA, Inc. 

522 N. 14th Street #I57 

Ponca City, OK 74601 

Dear Mr. Thomas: 

In response to your recent letter, I should note that the determination that Crazy Reels 

was a class 111 machine was made at the enforcement level, and did not constitute a decision of 

the Commission. The advice that the machine was class III was provided to the tribes which were 

operating those machines to give them an opportunity to avoid likely enforcement action. 

Although I have no reason to believe that the Commission would reach a different conclusion, so 

long as you understand that a formal classification decision was not made, I do not mind 

providing the requested written explanation as to why the machine appears to be a class 111 

device. 

The question of whether Crazy Reels is class 111 depends on whether it is a "gambling 

device" within the meaning of the Johnson Act, 15. U. S.C. 5 1 17 1, which defines "gambling ' ll~ il devicen as: 

[Alny other machine [other than a slot machine] or 

mechanical device (including, but not limited to, 

roulette wheels and similar devices) designed and 

manufactured primarily for use in connection with 

gambling, and (A) which when operated may deliver, as 

the result of an application of an element of chance, 

any money or property, or (B) by the operation of which 

a person may become entitled to receive, as the result 

of the application of an element of chance, any money or 

property. . . . 

15 U.S.C. 5 1171 (a)(2). 

Therefore, to constitute a Johnson Act device, a device must be designed primarily for 

gambling, and must meet the elements of either (A) or (B). These elements are commonly 

referred to as consideration, chance, and reward. 

The Crazy Reels machine easily meets the consideration and reward elements, since the 

players must pay to use the machine and, if successfbl, will win a prize or reward. Apparently, the 

q(i,ltb I' theory on which the tribes have offered Crazy Reels is that a player can influence the outcome of 

the game by acquiring skill and that the element of chance is therefore absent. 

1441 L STREET, N.W. BTH ROOR WASHtNQTON, D.C. MOOS TEL: 202-632-7003 FAX. 202-632-7066 
QW In looking at the skilVchance issue, the first point to consider is the Johnson Act's actual 

language, that is, "an element of chance." It may be possible that exceptional individuals with a 

certain level of hand-eye coordination might, through training or practice, become highly skilled in 

the play of Crazy Reels; however, our review of the game indicates play is so difficult that there 

would be a substantial element of chance in determining the game's outcome for the vast majority 

of customers at the tribal gaming facilities. 

As previously indicated, this discussion of Crazy Reels is an enforcement level analysis, 

which we are sharing as a courtesy to you and to help you understand the issues. You should also 

understand that the Department of Justice and the United States Attorneys have enforcement 

responsibility over Johnson Act gambling devices, and, even if we were to be convinced that a 

machine was not a Johnson Act device, we cannot speak for those agencies. 

I trust we have answered the questions which you might have had about our view of 

Crazy Reels. 

Sincerely, 

icL&.;"Ly 

Richard B. Schiff 

Senior Attorney