Tools You Can Trust
A precise approach to online and real-time equipment testing is winning Gaming Laboratories International new friends and new customersTuesday, 26 January 2010
"When people ask me 'What does GLI do?' I answer, GLI works for regulators to ensure regulatory compliance."
So says Christie Eickelman, Senior Director, Worldwide Marketing, for Gaming Laboratories International (GLI). But suppliers and operators also play a role in GLI's everyday business.
"The regulator is the client, and we look at suppliers and operators as consumers of our service. However, we are careful to always protect our independence and keep firmly in mind that our mission is to independently test gaming hardware and software to evaluate compliance with standards established by government regulators," stresses Ms Eickelman.
"On our website for free download are all of our GLI Standards that will help suppliers in advance decide and know how they will need to build their platforms to be acceptable to regulators, and, by extension, to operators."
Contained in that well-balanced comment is not only a guiding principal of GLI as a business, but also a clue to what it regards as its competitive edge. This is the GLI Las Vegas Tools You Can Trust A precise approach to online and real-time equipment testing is winning Gaming Laboratories International new friends and new customers sophistication of its Internet Protocol-driven systems for device testing and its searchable database of information on machines already tested by GLI or in the process of being tested.
The famous maxim of the management consultancy company McKinsey is: 'What you can measure, you can manage'. GLI's maxim for the gaming industry, displayed on its website, is: "If they can invent it, we can test it." Moreover, not only can GLI test it, but the company can also give industry stakeholders access to that testing information at the click of a mouse button.
GLI Link brings the test lab to the gaming machine—GLI Verify brings the GLI database to the industry
Thanks to GLI's proprietary and Ethernetrouted GLI Link system, a gaming machine can be tested remotely in jurisdiction A against a set of predetermined criteria, including interoperability with other manufacturers' games and systems, while being physically located on the other side of the world in jurisdiction B, closer to the supplier R&D team.
In addition, all the organisations with a stake in running a legal and fair gaming industry—the regulators, the suppliers and the officially licensed casino operators—can access information from GLI via the Internet on the progress of that testing process and on compliance requirements for different types of devices, and they can also learn about the different testing services available from GLI. In addition, thanks to an IP tool called GLI Verify, regulators and other industry stakeholders can check on, download and print compliance certificates already issued on gaming machines by GLI.
"If you visit our website, the front end is marketing and where we're located, but the back end, the GLI Access portion, is all password protected, providing information for regulators and suppliers," says Ms Eickelman.
The gaming test lab that comes to you
When people hear the words 'Internet communication,' they tend also to think of the words 'commercial risk' because of universal concerns about data security. GLI points out, however, that its GLI Link is not only password protected but also encrypted to the same standard used by the US Department of Homeland Security for its communications.
"Every time a submission comes in to GLI, we have a very strict security process that it must go through," explains Ian Hughes, Managing Director, GLI Asia.
"The engineers can't touch the submission until we have signature-identified every piece of software that comes into the building. We use several algorithms from which signatures are generated, giving each piece of software a unique signature. That's a security process from when it comes in to submissions, right through to engineering, through to QA [quality assurance] and then the final certification out to the regulator."
Not only is the integrity and security of a supplier's proprietary hardware and software protected over the Internet by encryption— the integrity of the testing process itself is protected by the fact that even when testing of a device is done remotely via GLI Link, the company always has physical custody of the machine somewhere at one of its 13 laboratories around the world. Payout function and interoperability testing is followed up by field-testing of all the capabilities of the machine or system in a simulation of a casino floor at GLI Las Vegas.
The ability of authorised stakeholders to review the whole process in real time and to interrogate the GLI database of previously tested products adds a new level of transparency to the compliance testing process that benefits the industry and consumers, says GLI.
If a supplier approaches GLI with a brand new technological concept, not only is that concept kept strictly confidential between the manufacturer and GLI, but GLI can also guide the supplier on how to build compliance into the product at the design stage, before any capital intensive investment in production has taken place.
"We have a specialist technology group, so every time new technology comes in, these pretty senior guys from within GLI think about how to come up with standards for it," states Ian Hughes. "They think about what exists in the industry already, the industry standards, what exists on the Internet security side of things, and what should we be looking at. They'll come up with procedures for our engineers, and then they'll conduct training for our engineers actually to evaluate the technology."
The fact that Mr Hughes, a trained engineer and native of Australia with specific responsibility for the Asia Pacific market, was the person showing Inside Asian Gaming around GLI's Las Vegas facility, says something about the global nature of the company's business, and also something about the power of GLI Link.
"We have four machines in Macau hooked up to a system here in Las Vegas as we speak," explains Mr Hughes.
"We take a ticket, put money into a machine, cash out a ticket, the ticket comes through here [Las Vegas] and is processed back, so that machine [in Macau] is talking to the system as if it were on the same system. We have full connectivity. We have ticketing, advanced funds transfer, electronic funds transfer, progressives, standard accounting information, downloadable games and configuration [information]. Basically everything a gaming system can do.
A lot of preparatory work is needed by a supplier before a product gets anywhere near the official testing stage, states Ian Hughes.
"For new and advanced technology, we can be looking at stuff two years before its planned submission," he says.
"What manufacturers have found is they have to design compliance into their products from the early stages. There's no point going through all the R&D and having a beautiful bug free software coded perfectly, only to find that in regulatory terms it's not approvable because it doesn't have certain things the jurisdiction wants, or it's got some new technology in it and the jurisdiction wants some changes."
"In those circumstances, manufacturers would have to go back to the drawing board, re-do all that R&D, come back through us, and re-do all that testing," adds Christie Eickelman.
"So we say, 'Let's get involved early, let's see if we can identify the key issues and, if necessary, start talking to regulators ahead of time,'" she explains.
What GLI can't do, stresses Ian Hughes, is speak on behalf of regulators.
"Because we work for regulators, we can't make decisions on a policy matter," he points out. "We can represent and reinforce their position, but final decisions always rest with the regulators."
"We can't say: 'Yes, you can have that, it's definitely a table game'. The decision about whether, for example, it's a table game or a slot machine is for the individual regulatory body. Some jurisdictions will classify a product differently if it's in a casino, rather than if it's in a hotel or club.
"The regulators are very happy for us to work with manufacturers. The regulators know we have a very strict code of conduct. We are very strict with our engineers about what we can and can't do. We can't, for example, get involved in tangential design.
"I, as the compliance testing body, can tell you, the supplier, if your product is compliant or not. What I can then say is what needs to be modified to gain compliance, but I can't tell you how to modify your product. That's a line that we just can't cross," adds Mr Hughes.
A priceless industry tool
"GLI Verify is a tool that we are rolling out in a new version this month," says Christie Eickelman.
"It provides certification letters for whatever we've approved for any given jurisdiction. Each jurisdiction has its own user name and password. For example, in California there are approximately 68 Native American tribes that have gaming, and each regulator at each operation has his or her own username and password. They can see what's been approved for their area and can verify what games are supposed to be on their floor. If something's happened to a game in the field, that's where the compliance department posts all of those notifications. So all their critical data is there. Also, users' manuals for the tools we provide are there. There's information if something's been certified, or if it's not been certified. If a product has an update or a version change, etc., all that data is right on the back end of the website, all over the world. And there's no charge to suppliers and regulators for that."
Thanks to GLI Verify, regulators are able to interrogate any single machine that GLI have certified using a plug in tool that can be stored on a USB stick.
"They click a button and it downloads a certification report," explains Ian Hughes.
"If I were a regulatory inspector in the field, and I didn't know if a particular game was approved or not, I would simply remove the media and plug it into a GLI Verify tool. That will then interrogate the database, and it will tell me the name of the game, when it was approved, the date, and the signature—everything about the software. It will then ask if I want to download a letter. If I Select 'yes,' it will go to the GLI submissions database and download the actual PDF report. Now I've got the actual certification that GLI issued for that product. It's something that regulators find immensely useful.
"It means the regulators can interrogate and verify a machine for compliance in a short amount of time," says Mr Hughes.
"They don't have to fill in a lot of paperwork, they don't have to fill in lot of documentation. If they've got a query—for example, if the GLI Verify tool shows the product's software is not approved, it will show straight away and the regulator can start talking to someone about it rather than waiting until he or she gets back to the office, looks it up on the regulator's in house database, and then is required to come back to the casino floor. Before GLI Access and GLI Verify, a regulator would have needed to ask a casino for its slot floor log then spend hours and hours going through the database, researching what software a particular machine should have. It just eliminates all that effort."
"Suppliers can also log into the GLI Access site and apply for transfers for products that have been tested in another jurisdiction, so they don't have to go through the whole checklist once again," adds Christie Eickelman.
The ability to interrogate GLI's database means suppliers and regulators can operate a 'pull' system where they actively seek out the information they want, rather than having to wade through the data provided by a 'push' system that sends out information to the industry on a blanket basis, regardless of its relevance to the individual regulator or supplier.
"Before they used to get it all in the mail. They would get boxes full of letters," says Christie Eickelman.
"A letter would come in regarding a particular game certification in that jurisdiction. But the operators in that jurisdiction might not have bought that game and the regulators might not therefore have any need for oversight on the certification. Why do they need all that correspondence? Now they can go online and obtain the certification letters relevant to their market.
GLI in Asia
The company is looking to build its business in the region
In December 2008 GLI announced what it described as the first-ever fully operational independent testing and interoperability centre in Asia. As well as launching the new 3,000 square foot facility located in China Civil Plaza in Macau, GLI also formed a partnership with a local educational institution– Macao Polytechnic Institute. The GLI Asia Interoperability and Testing Center was officially opened in February 2009, with Larry Xiao as its General Manager. It serves as the company's regional base to serve markets including Macau, Mainland China, Japan, Malaysia, the Philippines, Singapore, South Korea, Taiwan and other emerging Asian gaming and lottery markets.
"A lot of those jurisdictions either have regulators in place, are putting regulation in place, or are moving toward that," says Christie Eickelman.
"In that sense, we [at GLI] are getting in on the ground floor. In Macau, for example, the operators are very keenly aware that they need secure games. They have too much to lose if the game has not been tested by a recognised testing lab.
"We're aggressively developing our business in Macau and elsewhere and working to form relationships with regulators. Some jurisdictions are more mature than others. Some have the staff to handle it. If not, we can assist with that as well," she adds.
"Macau will be our central hub for all of Asia. But even if we're testing for something in Asia, it can also be tested in any other office in our 13 offices worldwide. We have the same checklist, the same protocols, the same type of engineers—in Australia we have three offices. We have a senior director of engineering in each location to manage the workload.
"We can also move engineers around to get training in whatever type of situation we need to be involved in. For example, we have an engineer from the Las Vegas office who's currently in Macau. We have the flexibility whereby we have enough engineers so that if we supply one somewhere else, the work doesn't stop at the lab where the engineer was previously based.
"GLI has been doing this sort of work for 20 years," states Christie Eickelman.
"The regulators have confidence when they see our investment and see how committed we are to the markets we're in. It's pretty easy to put up information about a test lab on a Website and say 'We're a test lab'. The proof of a testing company's commitment is when a regulator makes a lab visit and sees all the equipment, effort and experience that we at GLI can offer the market. That's the difference that really counts.