May 7,2004 

Robert A. Luciano 

President, Sierra Design Group 

300 Sierra Manor Drive 

Reno, NV, 895 1 1 

Re: Sierra Design "Mystery Bingo7' Game Classification Opinion 

Dear Mr. Luciano: 

This responds to the letter of April 7,2004, from Joseph Webster, Esq., on behalf 

of Sierra Design, requesting our advice on whether certain specified changes to the 

manner of play of "Mystery Bingo" would affect our determination that the game 

qualifies as Class I1 gaming under the Indian Gaming Regulatory Act. Mr. Webster7s 

letter of April 29, 2004, provided additional information and justification for the 

proposed changes. We provided an advisory classification opinion letter regarding 

Mystery Bingo on September 26,2003. 

We agree that the first of two changes proffered in Mr. Webster's April 7,2004, 

letter would not affect our classification determination. This change returns a free space 

to the middle of the bingo card grid in place of a numbered space and provides for three 

numbered balls to be given to player in the first release rather than four. While this is not 

a significant change affecting the play of the game, it does eliminate the possibility that a 

player can win the four corner progressive prize after the first release of numbers. This 

feature of the game had been an exception to our view that the award of prizes should 

follow a minimum of two such draws andlor releases. 

We are continuing to review the second change proposed in Mr. Webster's letter 

of April 7,2004, that would allow all prizes in the game to be awarded following the 

second ball draw and release. 

For clarification, the version of Mystery Bingo covered by our Class I1 

determination is that version described in our letter of September 26,2003, with two 

modifications: the change to the prize structure approved in our letter of April 2,2004,' 

and the change described in the second paragraph above. We set out the current 

approved description of the game in the attachment to this letter. 

 h he letter of April 2, 2004, was based on a proposal set out in a letter from Mr. Webster dated January 7, 

2004, and further described in letters dated February 13, 2004, from Mr. Webster, and March 16, 2004, 

from Rob Miller of Sierra Design. 

NATIONAL HEADQUARTERS 1441 L St NW, Sulte 9100, Wash~ngton, DC 20005 Tel 202 632.7003 Fax 202.632 7066 WWW.NlGC.GOV 

REGIONAL OFFICES Portland, OR, Sacramento. CA; Phoenix. AZ, St Paul, MN Tulsa, OK 
Robert A. Luciano 

Re: Sierra Design "Mystery Bingo" Game Classification Opinion 

Page 2 of 2 

The report from GLI which will be validate the game description and provide a 

software signature should be based on the description in the September 26,2003, letter, 

as modified by our two subsequent ~etters.~ We again encourage Sierra Design to 

conclude its field test of this game and make it available to tribal gaming operations as 

soon as possible. 

Sincerely, 

Penny J. Coleman 

Acting General Counsel 

Copy to: 

Joseph Webster, Esq. (Hobbs Straus, Dean & Walker) 

Todd Elasser (GLI) 

GLI advised in a letter dated April 30,2004, that on April 26,2004, they received a second version (2.21) 

from Sierra Design and that an earlier version (2.20a) was withdrawn. The version that is "approved" as a 

Class I1 game is not version 2.21. That version contains the change that we still have under review. A new 

numbered version should be submitted to GLI that contains only the game described in the attachment. 

This is the version discussed in on our opinion letter of September 26,2003, with the changes discussed in 

our letter of April 2,2004 and this letter. 
MYSTERY BINGO 

May 7,2004 

Description of the Mystery Bingo System 

SDG offers "Mystery Bingo" as a linked bingo system using technological aids. 

The game can be provided to gaming facilities in various formats. The formats exist 

within common software and are distinguishable by the additional features programmed 

for the game. Use of specific features may be elected by the gaming facility and 

incorporated into game play. The format provided to the NIGC played the game at its 

most basic level. We observed other features in play at a tribal gaming facility that 

hosted a demonstration in connection with our review. 

Mystery Bingo is played electronically on a networked system of components. 

Participation at the player level is accomplished through player terminals that can 

be physically configured in a wide range of appearances. Regardless of the 

packaging, the player terminal includes a computer element with processor 

memory and input-output capabilities, an electronic display of a bingo card along 

with other graphics that are billed as entertainment features by SDG, touch screen 

andlor buttons to enable selection of bingo cards and other game options, 

communication mechanisms to allow communication with a "Bingo Game 

Controller," and a printer to enable dispensing of bar-coded vouchers representing 

player funds at conclusion of bingo play or after a large prize win. The player 

terminal also contains a currencyhar code voucher acceptor that facilitates the 

purchase of game-play credits, and an audio system. 

The "Bingo Game Controller" is a computer that coordinates and connects 

participants in the bingo game. It communicates with player terminals and with a 

"Bingo Game Managers" on a network. 

The "Bingo Game Manager" is a computer that electronically determines numbers 

for use in the game. This device communicates with player terminals through the 

"Bingo Game Controller" via the network. It assigns bingo cards and enables the 

control of multiple simultaneous bingo games. The device acts primarily as a 

coordinator. It groups each game play request received from player terminals via 

the "Bingo Game Controller7' with a matching request from other player 

terminals. When the "Bingo Game Manager" first receives a game play request, 

it categorizes the request based on the number of participants required before a 

game can take place, the game theme, the denomination and the buy in level. 

The system contains two other components not directly related to game 

classification. The SDG Accounting systems contains multiple computers and network 

components that support the active game elements-the player terminals and "Bingo 
Game Controller." The SDG Cashless system allows the player terminals to issue 

voucher tickets. These tickets carry credits and can be re-inserted into other player 

terminals in the system or redeemed for cash at a cashier terminal. 

According to SDG materials, the Mystery Bingo System requires competition 

between players in the game of bingo accomplished through the player terminals 

connected to the network. The system would also allow for connection to other gaming 

facilities in an effort to broaden competition. Mystery Bingo has two layers of network. 

Bingo player terminals are connected to one another by use of RS-485 serial connections, 

or by Ethernet connections. In the case of serial connections, terminals are connected in 

a daisy chain fashion from terminal to terminal. The ultimate terminal in a series is 

directly connected to the "Bingo Game Controller." Each "Bingo Game Controller" is 

then connected via Etherernet connections to the "Bingo Game Manager" and central 

server. According to representations by SDG on which we rely, no component of the 

network (i.e. player terminal or "Bingo Game Controller") will function without the 

physical and logical connection to the network. 

Each "Bingo Game Controller" is connected to a sub-net of player terminals. 

Each "Bingo Game Controller" is connected to one or more "Bingo Game Managers." 

The "Bingo Game Manager" groups players into common games. Games may be played 

between player terminals on a single "Bingo Game Controller" or among player terminals 

connected to different "Bingo Game Controllers." The "Bingo Game Manager" will 

locate players for a game in the facility. The players are then combined into a single 

game across multiple "Bingo Game Controllers." 

Game play for the player is on a video screen at the player terminal. The Mystery 

Bingo System uses a standard size video screen at the player terminal measuring 19 

inches along the diagonal. The video screen contains the depiction of a bingo card-a 

grid bearing numbers. The game card provided in this review contained a grid of five 

horizontal rows and five vertical columns of numbers. The center box is a free space. 

The bingo card is located near the top of the screen along a center vertical line. The 

exterior of the bingo card measured 2 inches by 2 inches. The interior measurement is 1 

and 718 inches by 1 and 718 inches. When the game begins, the bingo card has a white 

background, red lines defining the grid, and black numbers in a 22-point font. 

The video screen also displays a spinning reel graphic of icons. Each column of 

icons appears to rotate when the game is played. The graphic presented for this review 

carried a 5-reel 9-line theme entitled "Pocket Change" and the icons conveyed that 

theme. According to the GLI report, there are presently 17 available game themes. 

The video screen also contained a box to display numbers that are drawn for game 

play, the total number of balls drawn for the game, the number of balls necessary to reach 

each space of the straight-line bingo pattern, the player's bingo score for the straight-line 

pattern covered, the value of the progressive prize, the game number, the credits available 

to the player, the number of credits to be bet in the game, the number of credits won if the 

player wins, and "buttons" to assist in play the game. 
Game Play 

Mystery Bingo games are played among players on a central system. They 

compete for prizes and for a progressive jackpot. A minimum of two players must 

request play for a game to begin. A new game will begin after a configurable period of 

time if the minimum number of players has requested admission. There is no maximum 

number of players in any game except as limited by the number of player terminals 

connected to the system. The players compete for a game-winning pattern that in 

Mystery Bingo is a straight-line bingo, obtained as a horizontal, vertical, or diagonal 

lineup of five numbers. The game is "won" when the first player obtains a winning bingo 

pattern defined as a straight line of five numbers on the bingo card and who then covers 

or "daubs" those numbers. 

A player may also win a progressive prize by obtaining a four-corner pattern with 

the first four balls drawn. Consolation prizes may also be awarded based on additional 

balls that are drawn after the first winning bingo pattern is obtained. A player must also 

obtain a straight-line bingo pattern to win a consolation prize. When a bingo tie occurs 

(two or more players achieve a bingo on the same number) each player will receive a 

portion of the prize they would have won if they had been a single winner. 

A short description of the prize structure for the game was provided to NIGC in 

connection with its review of the game. The amount won is based on the number of 

bingo balls necessary to achieve the bingo. Each straight-line pattern consists of five 

spaces. The first player to cover a straight-line bingo pattern wins the game. To 

determine the prize that the player has won, the total number of balls drawn for each 

numbered space making up the straight-line bingo are counted and then multiplied 

together, producing a bingo score. The bingo score is compared to a fixed prize table 

with established ranges of prizes. Players receive the prize associated with the range 

their score falls into. A player can view the prize table on the monitor at the player 

station. 

SDG offered an example of how this prize structure might operate. A game could 

have the first space covered on the second ball drawn, the second space covered on the 

third ball drawn, the third space covered on the seventh ball drawn, the fourth space 

covered on the eighth ball drawn, and the fifth space covered on the eleventh ball drawn. 

The winning player would obtain a bingo score of 3,696 (i.e., 2*3*7*8* 11=3,696). A 

bingo score in the range between 3,600 and 3,700 might entitle the player to a prize of 

100 credits. In this game, then, the winner could win 100 credits. 

In the base version of the game provided to NIGC, there is one buy-in level for 

each game. In this version, a player plays against other players at the one-buy-in level. 

In the multiple buy-in versions, players at different buy-in levels compete against each 

other in the same game with the same ball draw, although there are different prize awards 

possible based on the level of buy-in. Some games may also offer different card types 
that relate to different game themes. However, these cards are understood to retain the 

same grid discussed above. 

To begin play, a player inserts money or a ticket voucher at the player terminal 

and obtains game credits. The player then selects a buy-in amount. Different buy-in 

levels are selected by making a touch selection on the video screen. The players are 

given a bingo card, as described elsewhere in this opinion, on entry into the game. The 

player can use this card or change the card before entering a game. To select another 

card, the player touches the video screen at the card location and a new card with another 

grid of numbers will appear. Each card is different and duplicate cards will not be made 

available for play in any single game. The number of cards available is limited only by 

the mathematical possibilities in the distribution of numbers in the configuration 

described. 

To enter a game, the player presses the "play" button. A message appears on the 

video screen at the player terminal indicating the player must wait for additional players 

if enough players are not enrolled in the game. Two players were required for play to 

begin in the configuration presented to NIGC. Entry of additional players continues for a 

configurable period of time, discussed elsewhere in this opinion. The game begins after 

enrollment is complete. As play begins, bingo numbers are randomly drawn by the 

"Bingo Game Manager," meaning the computer electronically determines the numbers in 

a specific order. The first ball draw consists of three numbers. These numbers are 

displayed to the player. The ball-draw display will pause for a "daub" opportunity after 

the first three balls are drawn. The "ball draw" of numbers continues until the first 

potential winning bingo pattern is achieved. The "Bingo Game Manager" makes this 

determination by comparing the bingo cards in play to the numbers as they are drawn and 

stops the draw after one or more cards are known to contain a straight-line pattern. SDG 

provided its assurance that the assignment of player cards and the "ball draw" or random 

selection of numbers are independent events and that the software for the "ball draw" 

does not allow a deviation in the sequence of numbers drawn in the "ball draw" so as to 

eliminate or minimize a prize payout. 

Each player terminal will produce audible sound and a visual display on the 

screen when a potential bingo occurs. A visual display instructs each player to "daub" 

the bingo card. This is accomplished by the player touching either the on-screen card, an 

on-screen bbbutton," or a button on the console prescribed for this purpose. A player need 

not wait for the visual instruction but may "daub" at any time after the game begins to 

"cover" the numbers drawn that appear on the player's card by touching the card, the onscreen "button," or the console button. A winning player has a pre-established time to hit 

the "daub" button or touch the screen to "daub" the card and claim the prize. All players 

must "daub" to complete the game, although a winning player will not need to wait for 

other players to "daub" before obtaining a game result. 

A player who fails to "daub" a winning pattern within the time allotted will 

"sleep" the bingo, that is, forfeit the prize that was won. The "Bingo Game Manager" 

will draw additional balls until another winning straight-line pattern is obtained on a 
bingo card that is participating in the game. The player holding that card will win the 

same prize that was forfeited when the bingo was slept provided the player "daubs" 

within the time limit. The bingo score of the first winning player who slept the bingo will 

be used to determine the prize rather than the bingo score of a subsequent winner. If 

players again "sleep" a bingo, the game continues but the winning prize awarded will 

always be the prize that was forfeited when the first bingo was slept. A small "z" appears 

on the bingo card near the slept bingo as a sign to the player. 

The game ends when the last straight line bingo prize for that game is awarded. 

The last prize cannot be slept. There is unlimited time to daub and claim a prize after the 

seventy-fifth ball is drawn for the player with a winning card for the game-winning prize 

or for a consolation prize if the game-winning prize has been awarded previously. For 

the final player to exit the game, and participate in another game, the player must claim 

the prize. 

A player claims the credits won in a game at the same time the player daubs the 

winning bingo pattern. All players will have the opportunity to enter a new game after 

their "daub." A separate action is required to exit a game and request participation in a 

new game. 

From a system perspective, if the minimum enrollment for a game to begin has 

been met, the ball draw begins when the last player is entered. The bingo numbers are 

determined by the "Bingo Game Manager" in randomly drawn sets from a pool of bingo 

numbers from 1-75. The initial set contains three numbers. The next set contains the 

bingo numbers necessary to allow a potential bingo in that game, based on the cards in 

play. Once determined, the initial set of numbers is transmitted instantly for display to 

the player stations in use for that game. The operation of the bingo system is configured 

to prompt all participating players to press the "daub" button after each set of bingo 

numbers is displayed. In addition, a player may not enter a new game until the player has 

daubed at the conclusion of the ball draw for the game in progress. 

An animated sequence displays an array of spinning reels and symbols that stop 

on the appropriate pattern for the value of the prize won (if any) in the bingo game. The 

animated sequence begins at the same time that the bingo game begins. In either version, 

the animated sequence never shows the game outcome before the bingo game results are 

shown on the bingo card. The bingo results remain displayed on a bingo card in the 

upper middle of the screen until a player selects a new card for the next game or until the 

next game begins. 

According to our best information, including a specific assurance from SDG and 

as indicated in the report from GLI, the animated sequence of spinning reels has no effect 

on the game of bingo and is there for player entertainment. The symbols on the reels are 

chosen from the pay table combination to correspond with the winning bingo previously 

determined from the bingo game. In other words, a prize is given for a winning straightline bingo. The prize has a numeric value. Relying on that numeric value, a 
corresponding arrangement of icons is presented on the visual reel display as a winning 

combination. 

The credits won by a player in the game are awarded and shown on the video 

screen by an increase in the total credits available to the player. The "total credits 

available amount" is updated when the player buys into another bingo game. A player 

with credits remaining may discontinue play at a player terminal by pressing the "Cash 

out" button. A printer within the player station will produce a ticket voucher for the 

remaining credits that is presented to the player. Ticket vouchers can be inserted into 

another player terminal for additional play or may be redeemed at the cashier's station for 

cash. 

The bingo card remains visible to the player at all times during the game. The 

card is royal blue and is distinguishable from other surface areas on the screen. The 

bingo grid on the card contains a white background and a red grid outline with black 

numbers in each box. The background changes colors during game play for the numbers 

that are called. First the background color for the numbers selected changes from white 

to orange when the numbers are determined. After a player "daubs" the card by pressing 

the daub button or touching the "daub screen now" message on the video screen, the 

numbers on the card matching the numbers drawn change colors from black on a white 

background to white on a red background. Finally, if the player successfully "covers" the 

numbers making up the winning pattern, the colors change from white on a red 

background to black on yellow background, flashing every .25 seconds to highlight a 

bingo win. 

Following the "ball draw" and the appearance of the numbers on the video screen, 

as an alternative to the visual animation, a player may obtain the results of play by hitting 

the "print" button instead of the "daub" button or the on-screen "daub" message. The 

player receives a "bingo ticket" with a bar code and a listing of the numbers drawn. The 

player may redeem the ticket with a cashier or insert it into a player terminal for hrther 

play. 

Changes made to the game 

The game as evaluated reflects these features, summarized briefly, as follows: 

Although Mystery Bingo requires a minimum of two players for entry into a 

game, in the version presented to MGC, the configurable time interval available 

to enter any particular game was limited from the time the second player obtained 

entry until the entry opportunity closed and the game began. In an effort to 

"broaden participation," we requested the configurable time interval available for 

player entry into any particular game be expanded. SDG responded by including 

a mathematical algorithm that varies the enrollment period based on the number 

of active terminals in play on the system. With fewer terminals active, the 

algorithm lengthens the enrollment period to accommodate more players and thus 

broaden the participation. 
At least two ball draws, or two releases from a single draw, occur before the 

winning bingo pattern can be obtained. Only the first three balls will be selected 

in the initial ball draw. All players will have a "daub" opportunity at that point in 

the game. The remaining balls will be selected in a second or subsequent ball 

draw. 

An adjustment added a "daub7' requirement for all players when a potential bingo 

occurs for any player. Following the change, each player now "daubs" the card to 

determine whether he or she is a winner. 

The animated sequence of spinning reels at the time the bingo game begins rather 

than at the time the bingo game ends. The animated sequence will not end until 

after the bingo game ends and a player has daubed the bingo card. The animated 

sequence will not show the game outcome before the bingo game results are 

shown on the bingo card. 

END