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'Thumb drives' could replace VGM impact printers

Pub Date: 11/1/2008
When a discussion group spawned by the Gaming Advisory Council (GAC) subcommittee charged with developing policy regarding technology changes coming to gaming machines met in Billings October 3, it seemed many were resigned to a long day of complex talks.

Instead, within an hour and 15 minutes, business was concluded. Those present arrived on the same page quickly. Just because the technology is complex, apparently the discussion doesn't have to be.

Representatives of gaming machine manufacturers Fleetwood, U-1, Spielo and Summit, route operators Century and Amusement Services, industry trade groups the Gaming Industry Association and Montana Coin Machine Operators and several staff from the Gambling Control Division (GCD) comprised the discussion group.

Some background:

Only two U.S. gaming jurisdictions Montana and South Dakota now rely on impact printers to produce video Gaming machine (VGM) data records. The printers use rolls of duplicating paper to create the audit trails.

As use of the impact printers declines, there is a danger the one or two companies who manufacture the devices could abandon the market, leaving Montana operators and regulators in a lurch, scrambling for more devices and parts to keep them operating. In the worst case, Montana could lose It's ability to make records of machine activity for tax and compliance verification purposes.

In addition, the bulky devices dictate special machine doors and cabinet designs for a Montana-only market, adding considerably to manufacturing costs and making it impractical to ever export these machines to other jurisdictions.

But the impact printers also produce the "win tickets" players exchange for their cash winnings. However, that function in other jurisdictions is handled by industry-standard, smaller, less expensive, more widely available thermal printers using single sheets of paper.

The problem then becomes more one of record keeping than ticket or audit roll printing.

It was quickly agreed the most practical route to solving the printer dilemma is to adopt compact computer memory devices that could be easily, cheaply and securely installed in machines for data verification.

The devices would store the same information now printed to audit rolls and would be accessible to be read by operators or regulators. Further, they would be incorporated into machines of new manufacture or could be retro-fitted in existing machines if owners determined the additional expense warranted it, though those present said retro-fitting would mostly be impractical.

Gambling Control Division Administrator Gene Huntington and GCD staff developed a paper that summarized the discussion and direction to be pursued by the GAC and GCD. It follows.

Utilizing a Portable Data Storage Device
in Place of an Audit Roll


Background

At the public meeting of the Subcommittee on Video Gambling Machine (VGM) Technology, manufacturers suggested that the answer to the difficulty of continuing to provide impact printers may be to utilize portable data storage devices.

In general these devices would be like the "thumb drives" that can be inserted into the USB (computer) port (USB devices).

Manufacturers have indicated that impact printers are becoming more difficult to provide as they are not required in other jurisdictions and new cabinet designs make using impact printers more difficult.  

The Gambling Control Division (GCD) relies on the copies of the tapes produced by the impact printers as a permanent record of VGM activity for audit and investigation purposes.  

The alternative to impact printers is thermal printers which do not produce the duplicate audit tapes.
Proposal

Portable data storage devices (USB devices) would be used to store data now recorded by impact printers on audit rolls.

The Gambling Control Division would amend rules regarding the generation and retention of audit tapes to provide an alternative for VGMs that do not produce an impact printer audit tape.  The GCD would adopt rules providing general requirements for the data storage devices, data definition, operation and security.
How the USB Device Would Work

Discussions with VGM manufacturers and other gaming industry representatives have provided a general consensus on how the USB device alternative would work:

Which VGMs?

Any VGM that does not provide a printed audit ticket copy would need to support and require the use of a USB device.  While initially envisioned for future VGM models with thermal printers, the USB device could be utilized in existing VGMs that have been modified to utilize the devices and has been tested by the Gambling Control Division.

Information to Be Recorded

The USB device would record all (currently) printed data and would maintain current electronic meter readings.
     
Managing the USB Devices[b]

The USB device would reside in the VGM and maintain records for the required period'; obsolete records could be removed.  The dropping of records beyond the retention period would eliminate the need to manage the USB devices in terms of memory capacity. When a VGM is removed from service or re-licensed the USB device would be removed and stored for the required record retention period.
Accessing the Records

The records would be stored in a standard file format that could be viewed using any standard Windows application.

[b]Controls Built into the VGM


The VGM would be programmed to shut down if the USB device is removed, is out of memory or is incorrect for that VGM.

Security

Each record would be hashed and the hash value would be encrypted using a manufacturer-specific private key (RAS Standard)'; the encrypted hash value would be stored as part of that record.  When desired a utility would verify the authenticity of each record using a manufacturer specific public key to decrypt the stored hash value and compare it to the present hash value.  Private keys would be maintained by the VGM manufacturer and corresponding public keys would be maintained by GCD.

Next Steps

The GCD plans to circulate this document to representatives of the gambling industry and state information technology agencies for comment.  Any issues that develop out of the comments would be taken up with the Gaming Advisory Council Subcommittee on VGM Technology.  

Amendments to rules would be proposed in late November and adopted in early January.

Source: The Montana Tavern Times, November, 2008, published monthly by Continental Communications, 125 W. Granite St., Suite 102, Butte, MT 59701.