Simulated Gambling

• Simulated Gambling Device

In the previous day at the races Colonel Failure beat out the best that Twitter, Fail Brigade and the stream chat could muster to finish dead last. Many of these simulated gaming titles offer IAP items up to US$99! I have two problems with 'simulated gambling' apps in the store. In reverse priority order: They might be violating numerous gaming laws around the world; They are preying upon people, including those dealing with real-world gambling addiction problems.

Simulated Gaming™ is a monetized, social casino experience custom designed for our operator partners and deployed across desktop and mobile devices. Unlike any other solution in the B2B Social Casino space, Simulated Gaming™ is deployed from GAN's proprietary turnkey platform, the GameSTACK™ IGS, and is purpose-built for casino operators.

Since your app includes features that simulate gambling, your ratings must reflect a 'Frequent/Intense' setting for 'Simulated Gambling'

In order to reduce fraudulent activity on the App Store and comply with government requests to address illegal online gambling activity, we are no longer allowing gambling apps submitted by individual developers. This includes both real money gambling apps as well as apps that simulate a gambling experience.
We found that you have submitted this app under an individual account and indicated in the Ratings section of App Store Connect that it contains Simulated Gambling. While you can no longer distribute gambling apps from this account, you may continue to submit and distribute other types of apps to the App Store.
..
Going forward only verified accounts from incorporated business entities may submit gambling apps for distribution on the App Store. Visit the Enrollment page to learn more about enrolling an organization in the Apple Developer Program. For information on transferring an app to another developer account, please review the App transfer overview page in App Store Connect Developer Help.

From the arrival of Apple's iPhone App Store, they've elected to keep the platform, shall we say, 'Family Friendly'.

While the guidelines for developers who elect to sell their software through the App Store are always evolving, they seem much more constant and consistent versus when the store first opened. In general, it's still about keeping it a warm fuzzy place, while allowing some evolution so the App Store can grow and thrive. Apps which which violate terms include those that offer pornography, violence (simulated or other), targeted defamatory or offensive content at a given race, ethnicity, or or culture, or include objectionable content. What's objectionable? Ask Apple, as they use the Potter Stewart school of content screening. Things like Metadata+ and Ephemeral+, which provide information unavailable anywhere else, but which could be found 'unpleasant' by some, are not available on Apple's platforms. Personally, the justification of that is ridiculous, but that's a matter for another day.

Instead, I want to talk about 'simulated gambling' games. This week, I found myself on the App Store search page, and noticed among the Trending Searches, the string '777'. As someone who flies regularly (but doesn't gamble), I was curious what this even was. I clicked, and I couldn't have been more disappointed. I clicked the link, and discovered an endless parade of 'simulated' slot machine games.

What's really both fascinating and terrifying to me is how much the Trending Searches space seems to include 'simulated gambling' titles at night, and how many of the Top Grossing apps in the App Store are simulated gambling.

I really dislike that much of the iOS ecosystem has become overgrown by free-to-play (F2P) apps and games. I've started referring to these as free-to-p(l)ay instead, as because they generally require you to pay if you want to actually get to the most desirable content or levels in the title. Online casinos. I've only ever interacted with a handful of F2P games, and as a general rule, they are basically a Skinner box that conditions the user into paying for content in order to receive gratification.

Here's where the problems begin, though. I believe there are basically two ways to classify titles in the App Store that offer in-app purchase (IAP):

1. À la carte IAP
2. Bottomless IAP.

À la carte IAP apps offer one price for entry (either free or some base currency), and then a set menu of items that can enable a set collection of functionality within or interconnected to the app. For example, a drawing app could offer a set of pens or brushes, or a range of colors. The point is, a given amount of currency will buy you a set piece of functionality. One could argue that you can IAP subscribe to services and that can be ongoing, but I contend that is still a set currency over time.

Bottomless IAP apps, on the other hand, have an almost endless supply of offers to exchange currency for downloadable content, 'lives', 'coins' or other virtual (but financially worthless) tchotchkes to help you progress within the app (game). While the apps may have a cap on how much can be spent over time, many offer ridiculously expensive IAP items that can be repeatedly purchased, ideal for targeting and manipulating impressionable individuals. These are the IAP titles that we've all heard about, where people of all ages get duped into paying real dollars, without realizing how big the financial hole is that they've created for themselves. Many of these simulated gaming titles offer IAP items up to US$99!

I have two problems with 'simulated gambling' apps in the store. In reverse priority order:

1. They might be violating numerous gaming laws around the world
2. They are preying upon people, including those dealing with real-world gambling addiction problems.

As a general rule, Apple's guidelines on apps that include gambling state:

'Apps that offer real money gaming (e.g. sports betting, poker, casino games, horse racing) or lotteries must have necessary licensing and permissions in the locations where the App is used, must be restricted to those locations, and must be free on the App Store.'

and

'Apps that use IAP to purchase credit or currency to use in conjunction with real money gaming will be rejected'

So 'gaming' apps like simulated slot machines are in an interesting wedge. They ride a fine line, seemingly all following the first guideline, and making themselves free for download, but with the opportunity for the consumer to bleed out significant cash through bottomless IAP. They can't ever convert any winnings in the app to actual real-world winnings, or arguably they'd violate the second term.

Now here's where things get interesting. Let's take a look at that first term more closely. These apps are supposed to be licensed according to the location where they are used. This is a distinct problem to me. Though these are 'simulated gaming', I believe that since they are simulated slot machines (among other categories of gambling available in the App Store), they should follow the jurisdiction where they are used.

Thing is, there are very specific rules in many jurisdictions on what the payout must be for a given device used for a given category of game. For example, on the Las Vegas strip on the percentage of cash that must be paid out to gamblers, which ranges from 88.06% (penny slots) to 93.69% (US$1 slots). Arguably, the old line that 'the house always wins' isn't completely true. But statistically, it isn't going to be you, either.

In order to reduce fraudulent activity on the App Store and comply with government requests to address illegal online gambling activity, we are no longer allowing gambling apps submitted by individual developers. This includes both real money gambling apps as well as apps that simulate a gambling experience.
We found that you have submitted this app under an individual account and indicated in the Ratings section of App Store Connect that it contains Simulated Gambling. While you can no longer distribute gambling apps from this account, you may continue to submit and distribute other types of apps to the App Store.
..
Going forward only verified accounts from incorporated business entities may submit gambling apps for distribution on the App Store. Visit the Enrollment page to learn more about enrolling an organization in the Apple Developer Program. For information on transferring an app to another developer account, please review the App transfer overview page in App Store Connect Developer Help.

From the arrival of Apple's iPhone App Store, they've elected to keep the platform, shall we say, 'Family Friendly'.

While the guidelines for developers who elect to sell their software through the App Store are always evolving, they seem much more constant and consistent versus when the store first opened. In general, it's still about keeping it a warm fuzzy place, while allowing some evolution so the App Store can grow and thrive. Apps which which violate terms include those that offer pornography, violence (simulated or other), targeted defamatory or offensive content at a given race, ethnicity, or or culture, or include objectionable content. What's objectionable? Ask Apple, as they use the Potter Stewart school of content screening. Things like Metadata+ and Ephemeral+, which provide information unavailable anywhere else, but which could be found 'unpleasant' by some, are not available on Apple's platforms. Personally, the justification of that is ridiculous, but that's a matter for another day.

Instead, I want to talk about 'simulated gambling' games. This week, I found myself on the App Store search page, and noticed among the Trending Searches, the string '777'. As someone who flies regularly (but doesn't gamble), I was curious what this even was. I clicked, and I couldn't have been more disappointed. I clicked the link, and discovered an endless parade of 'simulated' slot machine games.

What's really both fascinating and terrifying to me is how much the Trending Searches space seems to include 'simulated gambling' titles at night, and how many of the Top Grossing apps in the App Store are simulated gambling.

I really dislike that much of the iOS ecosystem has become overgrown by free-to-play (F2P) apps and games. I've started referring to these as free-to-p(l)ay instead, as because they generally require you to pay if you want to actually get to the most desirable content or levels in the title. Online casinos. I've only ever interacted with a handful of F2P games, and as a general rule, they are basically a Skinner box that conditions the user into paying for content in order to receive gratification.

Here's where the problems begin, though. I believe there are basically two ways to classify titles in the App Store that offer in-app purchase (IAP):

1. À la carte IAP
2. Bottomless IAP.

À la carte IAP apps offer one price for entry (either free or some base currency), and then a set menu of items that can enable a set collection of functionality within or interconnected to the app. For example, a drawing app could offer a set of pens or brushes, or a range of colors. The point is, a given amount of currency will buy you a set piece of functionality. One could argue that you can IAP subscribe to services and that can be ongoing, but I contend that is still a set currency over time.

Bottomless IAP apps, on the other hand, have an almost endless supply of offers to exchange currency for downloadable content, 'lives', 'coins' or other virtual (but financially worthless) tchotchkes to help you progress within the app (game). While the apps may have a cap on how much can be spent over time, many offer ridiculously expensive IAP items that can be repeatedly purchased, ideal for targeting and manipulating impressionable individuals. These are the IAP titles that we've all heard about, where people of all ages get duped into paying real dollars, without realizing how big the financial hole is that they've created for themselves. Many of these simulated gaming titles offer IAP items up to US$99!

I have two problems with 'simulated gambling' apps in the store. In reverse priority order:

1. They might be violating numerous gaming laws around the world
2. They are preying upon people, including those dealing with real-world gambling addiction problems.

As a general rule, Apple's guidelines on apps that include gambling state:

'Apps that offer real money gaming (e.g. sports betting, poker, casino games, horse racing) or lotteries must have necessary licensing and permissions in the locations where the App is used, must be restricted to those locations, and must be free on the App Store.'

and

'Apps that use IAP to purchase credit or currency to use in conjunction with real money gaming will be rejected'

So 'gaming' apps like simulated slot machines are in an interesting wedge. They ride a fine line, seemingly all following the first guideline, and making themselves free for download, but with the opportunity for the consumer to bleed out significant cash through bottomless IAP. They can't ever convert any winnings in the app to actual real-world winnings, or arguably they'd violate the second term.

Now here's where things get interesting. Let's take a look at that first term more closely. These apps are supposed to be licensed according to the location where they are used. This is a distinct problem to me. Though these are 'simulated gaming', I believe that since they are simulated slot machines (among other categories of gambling available in the App Store), they should follow the jurisdiction where they are used.

Thing is, there are very specific rules in many jurisdictions on what the payout must be for a given device used for a given category of game. For example, on the Las Vegas strip on the percentage of cash that must be paid out to gamblers, which ranges from 88.06% (penny slots) to 93.69% (US$1 slots). Arguably, the old line that 'the house always wins' isn't completely true. But statistically, it isn't going to be you, either.

But these games are all 'simulated'. There is literally no opportunity for payout. Any winnings are generally returned as an opportunity to play again. There are no winnings. None. Arguably, by being a 'simulation', these titles do not need to abide by payout terms within the locales they are being used. But as they aren't real gaming, I personally feel Apple should reconsider having this category of title in the store at all.

Gambling addiction is a real thing. People get sucked in by the lure of easy money, and can quickly lose more than they had to begin with. The National Council on Problem Gambling has an interesting survey, the 2013 National Survey of Problem Gambling Services discusses how much money is spent on gambling addiction services across the U.S. The App Store lets consumers link credit cards to IAP. By offering bottomless IAP, these titles are effectively allowed to shake out the wallets of vulnerable consumers to an extent they cannot financially bear.

The problem with these 'games', is that they play upon the same emotions as real slot machines, luring the consumer into wasting untold dollars on a game that is completely unwinnable, financially. To quote the movie WarGames, 'The only winning move is not to play.'

My contention is that if games offering simulated gambling must be allowed on the App Store at all, they should not be allowed to offer bottomless IAP, or perhaps even offer IAP at all. Take a look at this game review from a user of top-tier 'simulated slot' game Slotomania from Playtika Games (A division of Caesars Interactive Entertainment):

That makes me so sad. These games offer no redeeming value (literally). From Playtika's own Terms of Service (linked incorrectly within their App Store entry, by the way):

'The Service may include an opportunity to purchase virtual, in-game currency ('Coins') that may require you to pay a fee using real money to obtain the Coins. Coins can never be redeemed for real money, goods, or any other item of monetary value from Playtika or any other party. You understand that you have no right or title in the virtual in-game items, spins or Coins.'

These titles are all about killing time while burning your wallet at the same time. They're all about taking money from the easily impressionable – youth, adults, retirees… across the board. When I posted on Twitter about simulated gambling, a follower of mine replied back with the following:

'grandma uses her iPad 2 almost exclusively for slot apps. :*('

Simulated Gambling Device

If Apple is going to hold up the App Store as a family friendly place for commerce, with reasonable consumer protections, I think they need to re-examine what role, if any, simulated gambling apps with IAP are allowed to play there.