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`Nevada Law Journal
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`Symposium: Cross-Border Issues in Gaming
`Sponsored by:
`The William S. Boyd School of Law and International Masters of Gaming Law
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`Anthony N. Cabot a1 Louis V. Csoka aa1
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`Copyright (c) 2004 Nevada Law Journal; Anthony N. Cabot; Louis V. Csoka
`
`“As some wise man doubtless said when Babylon was merely a country town, it is impossible to suppress the gambling instinct.
`It is not impossible, however, to put more sense into the laws affecting gambling . . . .” 1
`
`*198 I. Introduction
`
`People love games. We buy hamburgers to acquire game pieces for an opportunity to become millionaires. We watch game
`shows with the thought that some day we will have the opportunity to win a fortune before a nation-wide audience. We hold
`our children's birthdays at pizza arcades where kids play coin-operated games all day to win plastic trinkets. We log on to the
`growing number of game sites on the Internet to compete in both casual games like solitaire and more intense first-person shooter
`tournaments. And we love to gamble on everything from large jackpot state lotteries to slot machines and sporting events.
`
`Yet there is no consistency between legal and illegal prize gaming. With regard to illegal gambling, the criminal laws are
`even inconsistently enforced. Complicating matters further, the notion of “gambling” itself is being tested by the merging of
`sweepstakes, contests, and lotteries. Specifically, as long as the public has an unfulfilled demand for a gambling experience,
`entrepreneurs continue to test the boundaries of legal sweepstakes and contests to meet these demands. The variations of
`sweepstakes and contests are bound only by human imagination and unbound by tremendous leaps in technology. 2
`
`Anomalies have become the rule, as opposed to the exception. For example, many states have arcade-restaurants that cater
`primarily to children. These arcades, such as Chuck E. Cheese, Dave & Busters, and Jillian's feature prize-redemption games.
`Many of the games have some skill elements, but they are also designed to emulate, if not achieve, chance-based gambling. 3
`In some states, games unabashedly include “casino” in their names and incorporate spinning reels, typical of traditional slot
`machines, into their games. Despite this, an owner of a tavern that is restricted to adults may commit a crime by offering an
`actual slot machine for play in those states. 4
`
`This Article focuses on the various types of prize gaming. These categories include the following: (1) gambling games, including
`casino-gaming, pari-mutuel gaming, sports wagers, and lotteries; (2) promotional gaming, such as sweepstakes; and (3) the
`growing field of skill-based gaming.
`
`Part II of this Article provides general background and legal definitions. Part III explores the recent history of the various forms
`of prize gaming. Part IV describes anomalies and inherent contradictions that exist in prize gaming. Part V focuses on some
`policy concerns that can provide a theoretical foundation for a more harmonious approach. Lastly, in Part VI, we argue that
`modern gambling requires a new legal approach to prize gaming and we propose a basic structure for such an approach.
`GSN Ex. 1005
`GSN v. Bally Gaming
`U.S. Patent 5,816,918
`
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`“In the beginning, there was only chaos . . . .” 5
`
`II. What Is Prize Gaming?
`
`*199 A. Confusion Reigns Despite a Persistent Phenomenon
`
`Almost all countries of the world afford their citizens some form of legal prize gaming. 6 It could be, for example, betting on
`a hot stock rumor, buying a ticket in a state-run lottery, wagering on a horse, or checking the bottom of a soda can to see if
`you won a trip to the World Cup. 7
`
`There is an old saying that “[i]f you bet on a horse, that's gambling. If you bet you can make three spades, that's entertainment. If
`you bet cotton will go up three points, that's business. See the difference?” 8 Of course, given the analytical-similarity between
`the foregoing activities, it is difficult to justify why some activities are spurned, while others are legal.
`
`Prize gaming is any activity where the participant is attempting to win a prize. There are three basic forms of prize gaming:
`gambling, sweepstakes, and contests. 9 In general, court decisions typically analyze gambling offenses as financial schemes
`where (1) individuals pay consideration (usually money) (2) to participate in a game of chance (3) for the opportunity to win
`a prize (usually even more money). 10 A sweepstake is similar, but involves activities where the participant does not pay
`consideration. 11 Likewise, a contest differs from gambling only because the winner is determined primarily by skill as opposed
`to chance. 12
`
`Increasingly, prize gaming scenarios appear to defy classification under such simple analytical models. For example, why is it
`legal to risk your money (consideration) on the chance that cotton stock will go up three points (a chance event) in hopes of
`making a profit (prize), while risking your money on the finish of a horse at the track may be prohibited?
`
`In many instances, historic reasons, based on politics rather than analytical reasoning, exist for such distinctions. 13 One
`argument is that those forms of prize gaming activities that were popular with the upper class tended to be legal (i.e., stock
`trading, horse racing, and golf contests for a prize), while those that were popular with the “lower classes” tended to remain
`illegal (i.e., numbers [lotteries], general sports wagering, and card games for a prize). 14 For now, however, we merely note
`that legislation and case law dealing with prize gaming often appears to be intellectually incongruous.
`
`*200 Even courts are sometimes confused as to what activity should be prohibited under criminal gambling laws. For example,
`a Washington court held that a newspaper's free football contest contained the element of consideration because it required
`effort to pick the teams each week. 15 In another equally perplexing case, the Supreme Court of Nebraska upheld a ruling that
`chess and checkers are games of chance. 16
`
`B. The Basic Framework
`
`[Historically,] [a]t common law . . . gambling . . . where practiced innocently and as a recreation, was not unlawful. Such games
`were unlawful, however, where they became an incitement to a breach of the peace, so as to constitute a nuisance, tended to
`immorality . . . or for any peculiar reason were against public policy, or were conducted by means of cheating or by fraud. . . .
`Thus, gambling essentially is a crime only when and to the extent that the legislature has so declared it. 17
`
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`As we prepare to examine the public policy choices and general historical background, a brief overview of the various categories
`of prize gaming is helpful. “Gambling” itself does not have a single definition; it is made up of three separate categories. 18 In the
`first category of gambling games are “lotteries” or chance games involving schemes where a person pays valuable consideration
`for the chance to win a prize based on a game of chance.
`
`“Casino-style gaming” is generally a subset of lotteries or chance gaming. This subset encompasses such well-known chance
`games as slot machines, roulette tables, craps, and the like. In these games, participants risk something for the chance to win
`something of greater value than that which was risked. 19
`
`The second category of gambling games is “bookmaking.” Bookmaking occurs when a person risks something of value on the
`outcome of an uncertain event, in which the bettor does not exercise any control, but has the opportunity to win something of
`greater value than that which was risked. 20 Whether sports wagering is an activity predominately determined by chance or skill
`can be the subject of much debate. Most states avoid this debate by enacting separate laws defining bookmaking as a criminal
`offense. The key difference between bookmaking and lottery laws is that a predominant element of chance, a prerequisite in
`many states to illegal gambling, is not a specific prerequisite to a bookmaking violation. 21 Bookmaking is typically associated
`with wagering on sporting events. 22
`
`Despite this, not all bookmaking is illegal. For instance, “trading commodity options” is a legal form of bookmaking. 23 Prior to
`federal legislation *201 that specifically authorized such trading, the great majority of courts held that a contract to speculate in
`the rise and fall of commodities is illegal gambling if there was no intent that the underlying commodities would be delivered. 24
`Specifically, this occurs if an actual stock or commodity purchase was never intended to take place.
`
`“Pari-mutuel wagering” is a unique form of sports wagering. Unlike other forms of sports wagering, pari-mutuel horse wagering
`is legal in most states. Pari-mutuel wagering is important to the success of wagering on horse races. 25 The popularity of
`pari-mutuel wagering assures that horse track operators have the gross profits necessary to maintain horse track facilities and
`compensate the horse owners and others involved in the industry. Gross profit is assured because the track or off-track betting
`(“OTB”) operator takes a commission from each wager and places the remaining amounts into pools to be divided among
`winning bettors. The commission retained by the operator is called the “takeout.” Takeouts vary between states and tracks and
`are often set by law or regulation. Typically the takeout on win, place, and show bets is about fifteen percent and is slightly higher
`on “exotic” bets, such as exactas and trifectas. Pari-mutuel wagering is most commonly used for events such as horseracing,
`dog racing, and motor sports. 26
`
`The final category of “gambling” involves activities that are predominantly skill-based “contests,” but because state legislatures
`want to eradicate *202 these types of activities, they have grouped them with illegal gambling. The best example of this type
`of activity is poker. 27
`
`Besides poker and some other more traditional casino games, where any of the three elements of a chance game or lottery are
`missing, the activity is usually not treated as a prohibited lottery. 28 For example, because sweepstakes lack “consideration” (i.e.,
`an entry fee), they are generally deemed to fall outside lottery prohibitions. 29 More specifically, a “sweepstake” is a giveaway
`based on chance. 30 Among other things, sweepstakes may include sending in a postcard to enter, receiving a game piece, or
`obtaining a free game card at a business. 31 Examples of this type of promotion include “Publisher's Clearinghouse” sweepstakes
`or the various McDonald's promotions. 32 While in many states private lotteries are illegal, correctly structured sweepstakes
`are legal. 33
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`Moreover, true “skill games” lacking the lottery element of “chance” are legal in most states. 34 “Skill games” are games
`where participants' skill, and not chance, predominantly determine the outcome of the game. 35 A traditional slot machine,
`for example, is a game of chance because winning is determined purely by chance. 36 Another game, such as chess, which
`contains virtually no chance, is a game of skill. 37 Between the extremes of chess and slots are many games, however, that
`contain both chance and skill. 38
`
`To assess the legality of such games, most states have adopted the “predominance test.” Under that test, if the winner is
`determined predominantly by chance, then the activity is gambling. 39 If, however, the winner is determined predominantly by
`skill, then the activity is a contest. 40 Two more traditional activities within the “grey area” are poker 41 and backgammon, 42
`both of which have elements of skill and chance. To date, these two games have been held to *203 be predominantly skill-
`based by some courts and predominately chance-based by others.
`
`III. The Recent History of Prize Gaming
`
`“Jacta alea est” (“the die is cast”). 43
`
`A. Lotteries and Numbers
`
`Since the founding of our nation, many forms of prize gaming have existed in this country with periods of prohibition following
`periods of permissiveness. 44 Lotteries are one of the best and earliest examples of a gambling activity that became sanctioned
`or legalized to help support socially important causes.
`[Specifically,] [l]otteries in the United States date to early colonial times. A lottery was conducted in 1612 to support the
`Jamestown settlement. In the 1740s, Benjamin Franklin organized a lottery to raise money for the strengthening of Philadelphia's
`defenses. George Washington's Continental Army was the beneficiary of a lottery authorized by the Continental Congress in
`1776. [Furthermore,] [s]tate-authorized lotteries funded much of the westward expansion of the nation throughout the first half
`of the nineteenth century. 45
`
`Several institutions of higher learning, including Yale and Harvard, were, in part, financed by lotteries. 46 The proliferation of
`state-run lotteries began in the mid-1960s to address state budget deficits. As one commentator noted:
`[More recently,] [g]rowing opposition to tax increases was a leading factor in establishing [legalized] state-
`run lotteries in the 20th century. In 1964 New Hampshire was the first state to sponsor a lottery, followed
`by New York in 1967. New Jersey launched the first financially successful modern lottery in 1971. . . .
`There were also various attempts to legalize a national lottery, but they failed to be passed by Congress. 47
`
`The illegal “numbers” game was another prominent form of lottery. Often, for as little as a penny, residents of usually the
`poorest neighborhoods of major United States cities could pick either a three or four digit number with *204 the hopes that it
`would match the number drawn by the operator. Tens of thousands of low-income individuals have purchased tickets in these
`underground lotteries. 48
`
`Numbers was quite popular, even though the game is illegal. One author claimed, “the amount wagered on numbers was $5
`billion in 1960. Another estimate shows that the numbers game was grossing $20 million annually in Chicago alone during the
`early 1970s and the total handle was $1.1 billion.” 49
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`B. Sweepstakes
`
`Sweepstakes have been around for a long time. McDonald's and Pepsi, among others, have been operating sweepstakes with
`great success. 50 Most states permit sweepstakes, provided that several conditions are present. 51 Specifically, the promoter
`may not require participants in the promotion to stake anything that may be deemed “consideration.” Under the majority rule,
`incidental expenses or inconveniences undertaken to enter a contest promotion are not consideration. 52 For example, the cost
`of a postage stamp or the need to go to a store to obtain a contest entry form is not consideration under the “any effort or
`expense” test. 53
`
`Perhaps the most popular are sweepstakes that are tied to the sale of particular retail products. For example, persons buying a
`certain brand of soda or hamburger may have the chance to win a prize. These sweepstakes are designed to promote legitimate
`business objectives: increased sales. 54 There are costs associated with these benefits. These costs are born by the promoter and
`competitor. For example, when Pepsi holds a sweepstakes promotion, both Coke (in lost product sales) and Pepsi (in the cost
`of purchasing the prizes), and not the general public (in entry fees paid), pay the costs. 55
`
`When tying sweepstakes with products, a company promoting the product will typically incorporate into the product's packaging
`either a game piece or information about whether the patron won the prize. Thus, by virtue of the purchase itself, the patron
`may obtain a game piece or determine if he or she won the prize.
`
`The cost of the product itself is consideration in most states. 56 To avoid classification as an illegal lottery based on this,
`promoters must provide a free *205 alternative method of entry (“AMOE”). Games like this are generally legal because the
`participant is not required to purchase the product as a prerequisite for entering the sweepstake. 57
`
`Recently, sweepstakes have come under increased state scrutiny, not because they too closely resemble lotteries, but due to
`misleading promotions. Specifically, a few years ago, the attorneys general of twenty-six states made a joint announcement
`in which they explained that Publishers Clearing House (“PCH”) was to pay $34 million - “including immediate restitution
`to thousands of consumers” - and “make significant and permanent reforms in the way it conducts its future contests.” 58 In
`particular, according to that announcement:
`The $34 million settlement and permanent injunction will resolve state lawsuits that alleged consumers often were misled by
`PCH mailings into believing they had won contests, or that making purchases would enhance their chances of winning. “No
`longer will Publishers Clearing House be able to use false statements, fictional characters and deceptive personalized letters to
`prey upon the elderly citizens of our state,” said Wisconsin Attorney General Jim Doyle. Texas Attorney General John Cornyn
`added, “At last, Texas consumers can rest assured that this settlement will hold PCH accountable in the way the company does
`business. . . .” In addition to the changes in its future business practices, PCH must pay immediate restitution totaling $19
`million for customers who were deceived by its past practices. PCH also will pay civil penalties totaling $1 million, as well
`as $14 million to cover the costs associated with the states' litigation and the costs of administering the restitution payments.
`“This injunction requires PCH to make the restitution money available for distribution right away, and not wait two or three
`years,” Missouri Attorney General Jay Nixon said. “This is especially important when our investigation shows that most of the
`consumers who have been injured by PCH's past practices were elderly, and time is a big factor.” 59
`
`C. Skill Games, Contests, and Game Shows
`
`Like sweepstakes, most states exempted skill games from criminal gambling prohibitions. 60 Many reasons exist for these
`exemptions. Historically, such contests were used to motivate the citizenry to increase its combat skills. As experts noted: “The
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`value of martial games was recognized as far back as the days of Sparta and Rome, when youths engaged in mock battle to
`build skills that would later serve them in their duties as a soldier.” 61
`
`*206 Moreover, contests are historically intertwined in American culture, from the rodeo to bowling, and even golf
`tournaments. As the Arizona Supreme Court noted:
`Paying an entrance fee in order to participate in a game of skill . . . in the hope of winning prize money
`guaranteed by some sponsor to successful participants, is a traditional part of American social life. [W]e are
`reluctant to adopt a statutory interpretation which would turn sponsors of golf, tennis or bridge tournaments,
`rodeos, livestock, poultry, and produce exhibitions, track meets, spelling bees, beauty contests, and the like
`into class 6 felons . . . [Furthermore, where the legislature specifically created a state-sponsored lottery,] it
`is difficult . . . to find any moral imperative for a sweeping interpretation of a gambling statute in order to
`make the sponsor of a crossword puzzle contest a criminal while his next door neighbor, betting a dollar
`with the state to win a million in the state lottery, is a virtuous citizen. 62
`
`Perhaps another way to justify the distinction between skill games and games of chance is their relative popularity. For example,
`slot machines do not require training and anyone can play and potentially win thousands or even millions. As a result, given
`such broad appeal and “accessibility,” the potential audience to be invited to play and to invest its discretionary income is much
`larger. On the other hand, given the level of skill required, skill-based games do not normally enjoy such mass participation. This
`distinction normally concerns those in the business of providing traditional forms of gambling, such as casino-style gambling
`or sports wagering, because of the paternalistic nature of gambling laws, which is normally a bar to these forms of gambling. 63
`What is generally overlooked is that there is an element of chance even in skill-based games, and vise versa. For example,
`only a few hundred chess players have a realistic chance of winning major chess tournaments. Judge Williams perceptively
`commented on the skill necessary to win pool tournaments: “[b]illiards and pool are not games of chance. If any one [sic] thinks
`they are, let him go and play them for a stake, and he will promptly discover his error.” 64
`
`Carnival games are an early example of skill games, where, for example, contestants could win a prize by successfully shooting
`a water pistol at an object six feet away. Later arrivals of skill games include certain radio events and television shows in which
`contestants were intellectually challenged for prizes. 65
`
`*207 In the 1980s, promoters began challenging the limited mass appeal of skill games by using pyramid methods to entice
`persons to enter skill-based contests. The pyramid contest had several rounds, each round requiring both additional consideration
`and a higher degree of skill. 66 As one commentator noted, “Prospective contestants are solicited through the mail in all fifty
`states . . . [Specifically,] [w]ord puzzle games, mathematical problems and trivia questions are the forms the contest promoters
`most commonly use.” 67
`
`Lastly, the Internet has spawned a new era of skill-based gaming, both in the form of “hardcore” gamers and casual gamers.
`Hardcore gaming includes those games requiring intense graphic and audio capabilities to create virtual worlds where
`participants compete to achieve objectives against other participants or the computer program. These games include role playing
`games, first-person shooters, real time strategy games (typically war games), racing and sports games, and the like. 68 Players
`often compete in a computer world along with other players. This is called a multi-user domain (“MUD”). Casual gaming
`typically involves simple puzzle or logic games, like checkers or Tetris. 69
`
`D. Sports Wagering
`
`1. Classic Sports Wagers
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`Sports betting is probably as old as spectator sports themselves. Ancient Romans, for example, enjoyed betting on gladiatorial
`fights and chariot races. 70 Sports wagering is popular and legal in most international countries; however, the United States
`does not permit it. Virtually all states except Nevada have statutes prohibiting sports wagers and bookmaking. 71
`
`Sports wagering has a colorful history in the United States. Most scandals have involved a regrettable relationship between
`sports personnel and illegal gamblers. The most infamous scandal surfaced in the 1920s, when the Chicago White Sox team
`was accused of intentionally losing the World Series. A more recent scandal involved Pete Rose, baseball's all-time leader in
`total career *208 base-hits, who was suspended for life for allegedly betting on games in which he was involved. 72
`
`In an attempt to protect the integrity of sports, most professional sports leagues have adopted comprehensive rules against
`associating with gamblers and gambling. Such rules typically include a ban on sports bets by owners, players, and other
`personnel. Moreover, dual ownership of sport clubs and gambling operations, as well as advertising and other associations with
`gambling enterprises, is prohibited. 73
`
`Despite these rules and state laws, the federal government prohibits sports wagering because it is allegedly in the best interest
`of the nation. This was a radical departure from the historic policy that gambling laws were a state decision. This is the only
`time in the history of the United States that the federal government has taken the lead on gambling policy. Specifically, the
`issue of the integrity of athletics led to the Professional and Amateur Sports Protection Act in 1991, which effectively made
`sports wagering a federal offense. 74
`
`The sponsor of the federal legislation was then-United States Senator Dennis DeConcini of Arizona. Those that supported the
`bill cited sports fixing as justification for the legislation. Other reasons noted were the fan perception of sports integrity and a
`fanciful assumption that legalization would teach young persons to gamble. However, Senator DeConcini was aware that some
`thirteen states were considering some form of state-sponsored sports wagering and that no prior incident of sports fixing could
`be tied to legal sports wagering. 75 Fortunately for Nevada, the state was able to obtain an exemption from the ban on sports
`wagering; however, that exemption is currently under attack. 76
`
`Following a decade of the federal ban, law enforcement efforts have not resulted in the eradication of illegal bookmaking.
`Instead, lax enforcement endeavors, and often the lack thereof, has resulted in the proliferation of illegal sports wagering. 77 For
`example, in 1960 there were 123,000 gambling arrests. 78 The number of arrests for illegal gambling decreased to 15,000 by
`1975. 79 Despite the decrease in illegal gambling, the number of illegally wagered dollars has increased from $8 billion in 1983
`to between $80 and $380 billion in 1997. 80 In 1998, only $2.3 billion was estimated to have been legally bet in Nevada. 81
`In 1983, the number of illegally wagered dollars increased *209 dramatically, by a multiple of about 200 (far outstripping
`inflation), presumably not because of a lack of potential law-enforcement targets. 82
`
`Despite this immense growth, law enforcement has reallocated its resources so that more is given to deal with serious crimes,
`rather than illegal gambling. Some of this reallocation may be attributed to the fact that illegal sports gambling is hard to
`detect and prosecute, in part due to cyber-sportsbooks. The overwhelming reality, however, is that illegal gambling is no longer
`perceived as a serious crime even though it is still a federal offense. For example, virtually everyone knows of an office sports
`pool.
`
`Sports wagering is estimated to be a $380 billion industry. 83 Less than one percent of this amount is bet legally in Nevada
`sports books; the other ninety-nine percent is controlled by persons who are assuredly criminals because, by the very act of
`accepting sports wagers, they are breaking the law. 84 To the great detriment of states, substantial profits from illegal gambling
`
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`go untaxed. In fact, the profits (ninety-nine percent) go to the criminals, some of whom can use it to support more problematic
`criminal activity. Some profits go to pay police to “look the other way.” 85
`
`2. Pari-Mutuel Wagering
`
`The United States is inconsistent in the legal treatment of general sports wagers as illegal and wagers on horse races as legal.
`Most other countries do not treat the two differently. Several reasons exist for this anomaly in the United States. First, the
`American legal system has borrowed heavily from English jurisprudence, and horseracing had a long and proud tradition in
`England. 86 Second, the horseracing industry, providing a forum for the “Sport of Kings,” was probably also influential on
`lawmakers. Lastly, as commentators have noted, by legalizing wagering on horse races, states were “encouraging agriculture
`and the breeding of horses . . ., generating public revenue, . . . [and] providing for maximum expansion of horse racing
`opportunities . . . .” 87
`
`Despite this long history, the horse racing industry may not exist today without off-track betting (“OTB”) facilities. An OTB is a
`licensed facility where a person can place wagers on the outcome of horse races held at racetracks throughout the country. From
`the 1940s through the early 1980s, horse racing experienced its golden era. 88 In 1972, nearly 72 million persons attended on-
`track races; this is nearly twice that of baseball, which is known as America's favorite pastime. However, after 1972 the walls
`began tumbling. *210 This tumble occurred when horse racing became the victim of fickle American consumer preference,
`as the American gambling dollar flowed from the track window to the slot machine.
`
`Despite the shift in popularity, horse race wagering has actually increased. In 1982, Americans legally wagered about $11.7
`billion on horse races. In the ensuing eighteen years, this total increased a modest 35.5% to about $15.9 billion. 89 But these
`figures tell only half of the story. On-track wagering decreased by about 72% during approximately the same period, dropping
`from about $9.9 billion to $2.8 billion. 90
`
`Today, the tracks acknowledge the importance of OTB facilities. This, however, was not always the case. Racetracks and horse
`owners initially saw OTB facilities and their potential national growth as a threat. Specifically, the tracks and horse owners
`were concerned that the consumer appeal of OTBs in major cities would harm the on-track attendance and jeopardize racetrack
`employment. Proponents of off-track betting, on the other hand, argued that the developing off-track market would increase -
`not redistribute the market - and that the increased market would benefit the overall health of the industry. Proponents of OTBs
`claimed that much of this market could come from persons who previously gambled with illegal bookies. Besides cutting the
`flow of funds to criminals, the government could receive tax revenues from an additional source.
`
`After several years of debate in the late 1970s, these track owner concerns resulted in federal legislation. The Interstate
`Horseracing Act (“IHRA”) now governs the relationship between the OTB operators, the tracks, horse owners and trainers, and
`the state racing commissions; this Act applies to wagers placed in one state on the outcome of races held in another state. 91
`All other aspects of horse racing, such as licensing and policing, are left to the discretion of the various state racing or gaming
`commissions. 92
`
`E. Casino Gaming
`
`1. General History
`
`To understand modern casino-style gaming, it is important to understand the backdrop from which it grew. The following is a
`brief history of the State of Nevada, and specifically Las Vegas.
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` © 2015 Thomson Reuters. No claim to original U.S. Government Works.
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`THE GAMES PEOPLE PLAY: IS IT TIME FOR A NEW LEGAL..., 4 Nev. L.J. 197
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`The city of Las Vegas was not an overnight sensation. 93 How a tiny desert town that served as a railroad watering stop became
`the most novel and imaginative city in the world is attributable to perseverance, vision, capitalism, and luck, in equal parts. 94
`Gaming law and regulations played a significant *211 role in the growth of Las Vegas, providing both the substance and the
`perception of integrity that today allows Nevada casino operators