To: Region Chief. Region IV 

From : Acting General Counsel 

Subject: White Earth - Quick Shot BingoIPull-tab Operations 

We understand that Quick Shot Bingo is being played at several facilities within the 

exterior boundaries of the White Earth Reservation and that Quick Shot is being used as 

the basis for authorizing the sale of pull-tabs. I have determined that Quick Shot Bingo is 

not bingo pursuant to the Indian Gaming Regulatory (IGRA). Therefore, it cannot justify 

the sale of pull-tabs as Class 11. 

DESCRIPTION OF QUICK SHOT BINGO 

Quick Shot Bingo is played as follows: 

Once a week, a person at Gold Eagle Hall draws five "B" numbers, five "I" numbers, 

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five "N" numbers, five "G" numbers, and five "0" numbers from a bingo blower. The 

numbers are then posted on bingo number boards located at several individually owned 

facilities located on the reservation. To play the game, a customer purchases a Quick Shot 

Bingo card for $.50 each. The customer compares the numbers on the card to the 

numbers that have been drawn, covering those numbers on the card that correspond to the 

posted numbers. If the covered numbers form a previously designated arrangement of 

numbers, the customer receives a predetermined monetary prize. 

DESCRIPTION OF CLASS I1 GAMING UNDER IGRA 

The NIGC regulations, at 25 C.F.R. 8 502.3, define bingo as follows: 

Class I1 gaming means: 

(a) Bingo or lotto (whether or not electronic, computer, or other technologic aids are 

used) when players: 

(I) Play for prizes with cards bearing numbers or other designations; 

(2) Cover numbers or designaticns when objects similarly numbered or 

designated, are drawn or electronically determined; and 

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TI elf Letter to Region Chief, Region IV 

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(3) Win the game by being the first person to cover a designated 

pattern on such cards; 

(b) If played in the same location as bingo or lotto, pull-tabs, punchboards, 

tip jars, instant bingo, and other games similar to bingo; 

25 C.F.R. 4 502.3. 

ANALYSIS 

As described, the Quick Shot Bingo game does not meet the regulatory definition of 

bingo for several reasons. First, the players do not cover the numbers when objects 

similarly numbered are drawn. Instead, all the winning numbers are drawn and posted on 

the boards before the players buy their cards. The players then compare and cover the 

numbers on their cards with the posted numbers to see if they won. Also, as it is being 

played in some instances, the game is not won by the first person to cover a previously 

desipated arrangement. Rather the game may be played for a set period of time, such as 

a week. The possible impact of such variations is that in the first instance, no one would 

qdf win the game, and in the later instance, people could continue to play after someone else 

had already won the larger prize. Therefore, Quick Shot bingo is not bingo under 

25 C.F.R. tj 502.3. 

Moreover, pull-tabs, punchboards, tip jars, instant bingo, and other games similar to 

bingo can be played only where bingo is played. Because Quick Shot does not meet the 

definition of bingo, it cannot be used as a basis for playing the Class I1 pull-tabs. 

I apologize for the significant delay in responding to your request for our views on this 

matter. 

--=-% 

Penny J. Coleman 

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