A.O.P.J.N.R. gets involved in establishing more unitary position of its members and the whole slot-machine in connection with the development of standards related to monitoring systems

On December 14, 2016, at the O.N.J.N. headquarters, a conference between representatives of the institution and technical representatives of some of the manufacturers of gaming equipment and monitoring systems in Romania took place after they were convened by O.N.J.N. for discussions on how to implement monitoring systems.

At the end of this meeting, during which the participants approached multiple issues, without establishing a consensus about the topics under discussion, an invitation to submit oppinions, suggestions and view-points on the subject was launched by ONJN representatives, both for participants at the meeting, and – through professional associations -to all members of the industry, involved in manufacturing and supplying various types of equipment specific for monitoring systems.

A.O.P.J.N.R., represented at this meeting by the executive president Cristian Pascu, but also by other members of the association attending the meeting as producers – individually invited by O.N.J.N. – tried to obtain information from its members and transmit to the authorities various detailed viewpoints which may cover this topic more broadly. The general interest of the industry demands the establishment of the legal frame as soon as possible, in order to have all gaming equipment that are currently exploited functioning accordingly. Moreover, their interconnection with the monitoring system must also be regulted, especially since there is little time left until February 24th 2017, the date from which slot-machines can no longer be exploited if they are not connected to the serial communication protocol monitoring system, according to rules and terms provided by HG (government ordinance) 111/2016.

In this regard, to contribute in a larger measure to avoiding a blockage from this perspective, A.O.P.J.N.R. tried and managed to mediate the view-points of some of its members, leading suppliers of monitoring systems operating in Romania and which together are handling the monitoring of about 40% of the total number of slot machines in operation today.
It is all the more remarkable that representatives of these companies, which are in effective competition on the market, manufacturers of technical systems and monitoring fundamentally different between them, were able, through mediation and harmonization of their views by the management of AOPJNR, to agree on a document written and assumed jointly, and then transmitted as such to ONJN, a detailed document covering most of the topics discussed at the meeting on December 14th. The material was sent to O.N.J.N. and equally to members of AOPJNR for information, but also with hope that other members of the association will come with various other complementary points of view so that after the discussions, the position of the associationwill be assumed by the majority of its members.
On this occasion, we are launching the invitation to dialogue to other industry associations, and any other interested companies – be it equipment manufacturer or supplier or monitoring systems, or even beneficiaries of systems, slot – machine operators- to develop a position as relevant as possible regarding this urgent matter. In what follows, we present the position already drafted by the group of companies that had availability until now to be a part of mediation in this regard, noting that this is not the final position of the AOPJNR association, but can be considered a starting point in finding a broad consensus.
Opinions on rules regarding monitoring systems
Following the hearing organized by O.N.J.N. on December 14, 2016, we convey these issues, on topics that were discussed during the said hearing.

Preliminarily, we bring to your attention that, in principle, in our point of view, it is a formidable challenge to try to develop technical rules generally available, that could cover gaming equipment manufactured between 2000-2016.

Also, an exhaustive approach will be difficult to the extent that transmitted data can not be interpreted easily. If the set of rules will be one which will require transmission of a large number of events, the human factor could constitute the limit to impose the efficiency of these rules. In this respect, we would suggest that this new set of rules be closely related to the utility they bring to the monitoring service.

In what follows, we will refer to these issues discussed in the said meeting, issues which we consulted about and we send to you the following oppinions:

1. The possibility of introducing of an acquisition interface (SMIB) inside the compartment of the game board. Related to this we have the following comments:
a. The manufacturer has built means of playing without having in view such a goal. Both for equipment manufactured in 2004, for example, and those manufactured in 2016, the serial connector SAS, – data retrieval machine- is located outside the partition of the board .
b. In most cases, the manufacturer has not provided a physical space in order to introduce a SMIB in compartment of the game board and even if it could be introduced in some machines, it can not be integrated without the risk of electromagnetic interference generating potential faults or errors either in the functioning of the game board, or in transferring and interpreting data. Location of SMIB is irrelevant as long as the reception and transmission of data accuracy is accomplished regardless of its position inside the machine.
c. We do not think there is an essential risk about non-introduction of the SMIB interface in the game board compartment because it instantly communicates any change in the value of monitored parameters to acquistion servers and data is constantly updated at an interval of less than one second.

2. Regarding the two serial communication protocols used mainly for gaming equipment used in Romania, other than protocol IGT – SAS, following comments are necessary:

a. AGI – GSP Protocol
This protocol is integrated by manufacturer A.G.I. – Novomatic on all motherboards they produce, including currently, but also on the game board with ASIC platform, which has installed exclusively the gaming software Hotspot Admiral. In the case of this particular board,AGI – GSP communication protocol is the only one implemented by the manufacturer. This protocol is similar to SAS protocol in what the level of functionality and data security are concerned, that means it is a standard communication and that data can not be altered through manipulation. This protocol communicates all technical and accounting parameters permanently resulting from the current exploitation of the machine, parameters that are interpreted by the monitoring system in the same way as those transmitted by SAS protocol.
The only difference between AGI – GSP and SAS is that the data query mode is somewhat different, technically speaking, this without generating errors or inconsistencies in data acquisition and interpretation.

b. The acquisition of game platforms which are not natively featured with serial protoco( for instance DGL – Club Master)

By the means of unidirectional aquisition from the communication thoroughfare of the game board, it is envisaged to monitor all monitoring parameters of internal memory of the game board and works identical to retrieving data in GSP or SAS format, by permanently reading the data from the internal memory of the game board.
As far as the good faith of the aquisition module manufacturer exists, there is no manipulation of its program or data read from the internal memory of the game board. In the following, at the proposal section, we present the way through which we consider that good functioning of this kind of system can be certified, in terms of maximum accuracy data transmission with the data collected by serial protocol.

In both cases above, as well as with any other mode of data collection, there is the factor of good faith, to be covered by the certification of the entire chain of data transmission. To the extent that an audit of the system is required, this audit should include all parts of data transmission, including the audit to provide serial communication types that the system can take over.

Another mention that is required in this case is addressing speculation according to which the manufacturer of game boards would not have submitted the right to use protocol by third parties. Compared to this, we particularly should mention that AGI – GSP protocol constantly communicates data even if there is no active connection to monitor this data, basically it “listens” the transmission. In addition, the transfer of ownership on the game board sold to a buyer includes by default, under any condition and in any jurisdiction, all rights of use of all functions and systems the game board contains (buttons, lamps, video signal, audio signal, GPS signal ). The fact that a producer subsequently decides that it does not have an economic interest to provide further support to a particular hardware platform should not prevail against the interest of a market that bought the game board, without having any restrictions, other than copying it . We reiterate equally that this protocol, AGI – GSP is currently preinstalled by A.G.I. (Novomatic) on all game platforms that they market, as one of communication protocols available and selectable by the organizer from the game board menu.

For example, on a game board produced by A.G.I. – Austria in 2015, it has preinstalled 10 serial communication protocols, which can be selected either (only one) by the organizer, during the initial configuration of the game board : AGI – GEP, AGI – GSP, BACTA, BACTA pentru Novegia, BALLY 906 912, BELGIUM Online, Telelink, Zonk, IGT – SAS (AFT), IGT – SAS (EFT). The example is relevant, the situation is representative for any of the boards and game programs which we have referred to. It follows implicitly that the AGI – GSP protocol is not a particular csse of protocol and that it is not out of operation even currently, and it can be selected and chosen as serial protocol through which the machine communicates with the monitoring system on any of the products marketed by said producer.

3. Parameters required for monitoring and reporting to O.N.J.N. currently, such as IN, OUT, On / Off, etc., and the remaining parameters of play equipment that transmit them via serial communication protocol, including BET, WIN, GAMES, etc. are memorised/stored in the SMIB interface in case of failure of the internet connection with the server. Also, events such as RAM Clear are detected and in the case of this happening, data is stored in the same way, wirhout being altered, no matter the number of resets of the data in the memory of the game board and without that reset of data affecting the data stored and reported by the monitoring system. Storage/ saving is made for a working period of at least 48 hours and in case of exceeding this period, it already exists obligation to turn off the machine to restore the connection and data transmission.

4. Technically, all the parameters that the monitoring systems monitor, store and transmit are recorded in the monitoring system by the procedure of permanent Increment, that means by adding each amount corresponding to that dimension to its preceding value, as new events occur during the game. The reported value of each parameter is represented by a total accumulation of amounts of this parameter, from the point of reference selected, respectively at most by the time the monitoring system was installed in the means of the game. Ever since the initial installation SMIB interface of the monitoring system, all data for each parameter are stored cumulatively, having as unique possibility their incrementation, by constantly adding new financial operations, as they occur.

Example: In the case of parameter CREDIT IN (inputs), for example, the system indicates that at some point total accumulated value thereof is 21.460 lei, from the date of installation of the monitoring system. For every ammount introduced in credit, its value will be added to the previous accumulated amount, along with adding them to the memory of the game board, as well as on the electro-mechanical CREDIT IN meter. Thus, the consecutive introduction of 10 lei + 50 lei + 50 lei + 100 lei ( 210 RON in total) the total value accumulated of the credit in parameter will become 21.670 lei.

Obviously, no amount of money can not be introduced in the credit of the machine without the machine being functional, by default without this amount being recorded to the memory of the game board, on the electro-mechanical inputs controls as well as on the SMIB interface of the monitoring system. Similarly, all parameters monitored by the monitoring system are in the same situation.
For example, the differences between credit entered and credit out (OUT – IN)which the monitoring system additionally reports to the organizer are obtained from continuous comparison between the total value accumulated of the two parameters, not only from “reading” this parameter from the internal memory (volatile) of the game board. Similarly in the case of the BET and WIN parameters.
In particular, both electro-mechanical counters of the machine and the SMIB interface of the monitoring system collect and store data cumulatively, by adding constantly increasing value added to the previous total value of this parameter, regardless of the memory of the game board. So, in the event of loss of data stored in the memory game board, whether as a result of a malfunction, whether as a result of the RAM Clear procedure, data stored both on the electro-mechanical counters (metrologically checked and sealed, based on which amounts registered in the special regime related activity are highlighted) as well as on the SMIB memory interface and by default of the monitoring system (which reports these parameters to ONJN) will not be affected in any significant extent.

In the matter of the exploitation operations, the RAM Clear procedure is shared. It must be carried out voluntarily by the organizer for the configuration of options and the functions of the board and game program, in case of change of certain components or sub-assemblies of the machine( which have to be installed and configured software, and replaced after the failure of the previously installed).
Also, this procedure must be mandatory tun thorugh, involuntarily, in the usual case of occurrence of errors in the operation of the game program, mostly generated by disturbances in electricity supply.
Operating data errors involving the need to perform RAM Clear procedure can occur when battery which supplies the volatile RAM memory of the gme board is consumed; every 1-3 years this situation will inevitably occur, depending on the type and quality of the battery installed on the motherboard. Precisely for this reason the relevant accounting data, related to the operation of the machine, are highlighted on non-resetting electro-mechanical meters, manufacturer-installed on every machine, which can monitor between 2 and 8 accountanting parameters, depending on how the manufacturer provided.
And the fact that the monitoring system constantly and cumulatively retrieves data for each monitored parameter is an additional element of safety for the organizer, except the data highlighted by electro-mechanical counters.

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