From: Rita Homer <rita@xpertx.com> 

To: Reg Review 

Cc: Purohit, Nimish J. 

Sent: Thu Sep 15 16:35:02 2011 

Subject: Proposed MICS as Pertains to Keno 

Good Afternoon,

My name is Rita Homer.  Our company XpertX, Inc. is the leading manufacturer of live

action Keno Game System equipment and Keno Graphic Display systems.  

In August 2010 Naunie Gardner, our compliance chief, and I submitted our suggestions

regarding changes to your Keno MICS; your Revenue Audit MICS and your IT MICS as

they pertain to Keno.  Naunie spent several hours editing the comments into your

website. 

As a precaution, I forwarded these comments on 8‐12‐10 as Word documents to

'MICSComments@nigc.gov'.  I received automated responses from West, R. Rest

[Rod_West@nigc.gov]  and Curry, Michael L. [Michael_Curry@nigc.gov].

On March 22, 2011 I again contacted Michael Curry who explained about the

reorganization that occurred at NIGC.  Now, I see that you have made some changes to

the above mentioned MICS, but none of our comments are shown.   They have

apparently been deleted or never made it to review. Mr. Curry indicated that we would

receive a formal response to our suggestions and would be notified of the outcome of

those suggestions.  We were also informed that we will be given another opportunity

for our views to be considered prior to the rules being published as final regulations.

More recently, we were again invited and encouraged to offer any suggestions,

comments and observations to your new proposed MICS by Nimish J Purohit, Acting

Director of Training and Technical Assistance, National Indian Gaming Commission.

It is critical to the viability of the game of Keno that we be allowed input into your

decision making process.  Many of the changes to the Nevada Keno MICS were far

reaching and did not take into account vendor supported systems or closed systems

such as ours, thereby creating the necessity for Nevada Gaming to follow with issuance

of a Global Variance for all casinos running XpertX Keno Systems. We must be cautious

if NIGC is using the Nevada IT MICS as applied to Keno. Keno Systems are among a

group defined as “closed systems” which do not grant operating system access to any

casino level personnel.  We would rather have special dispensation written into the

approved IT MICS than have to handle each casino’s variance individually. Nevada

Gaming unfortunately failed to do this before closing comments to the Nevada IT MICS

(regrettable for them and us).  That necessitated issuance of the attached “Global

Gaming Variation” to the Nevada IT MICS. 
<<MICS #22 Gaming Variation.pdf>> 

Within the next few weeks, we will be sending our comments, questions, suggestions

and observations to your suggested Keno MICS and changes as apply to Keno for

propsed Revenue and Information Technology MICS.  All XpertX commentary will be

shown in red or as a comment.

We appreciate the opportunity to include our concerns into your discussions regarding

changes to your MICS.

If we can be of any help, please let don’t hesitate to communicate with us.  If you have

any suggestions about how we can forward our information to you, I appreciate your

input.  Additionally, if there are any other persons who should be included in our emails,

will you let me know?

Thank you for your time and consideration.

Rita Homer

Compliance Officer

XpertX, Inc.