# SBCGS Standards Committee - Session Minutes
Date: 2026-10-01
Board: skillgames-2026-10-T
Documents reviewed: SBCGS-T v1.3, Technical Standards
Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

---

## Mission

Strengthen the SBCGS family as published working drafts, by testing every
requirement against the five parties who have to live with it: the regulator
who would enforce it, the laboratory that would certify against it, the
organization whose name is on the operation, the operator who pays for it,
and the player standing at the device. The committee proposes specific,
section-level changes to the text of the standards. It does not decide
policy, and it does not take a position on whether these products should be
lawful anywhere. Before proposing that something be added, confirm the
standards do not already contain it.

In scope:
  - The text, definitions, thresholds and drafting of SBCGS-C, SBCGS-M and SBCGS-T.
  - The open questions the Institute already identified in the Appendix of each document. Treat these as the priority, because they are the provisions the Institute has itself marked as unevidenced, including the three thresholds in SBCGS-C section 106 and the charitable yield floor in SBCGS-M section 502.
  - Whether a requirement is enforceable by a regulator, testable by a laboratory, dischargeable by a licensed organization, affordable for an operator, and effective for a player.
  - Exposure the standards fail to reach, and provisions that can be satisfied in form while defeated in substance.
  - Consistency across the three documents. The skill measures are defined in SBCGS-C section 106, specified in SBCGS-T Part 810 and disclosed under SBCGS-M section 304. Charitable yield is defined in SBCGS-C section 107, floored in SBCGS-M section 502 and computed in SBCGS-T section 843. A suggestion that moves one of these must say what it does to the others.
  - Whether a suggestion that adds or changes a citation rests on a source already held in research/SOURCES.md. Where it does not, the suggestion must say so plainly rather than assert the citation. Three basis notes in version 1.0 cited the wrong provision because they were written from search results instead of source text.

Out of scope:
  - Whether skill-based products should be lawful in any jurisdiction. The Institute is jurisdiction-neutral and advocacy for or against the industry must not enter the drafting.
  - Publication, formatting, filenames, versioning and the site register. Those belong to the build and to the iegm-site session.
  - Commercial matters, including assessment pricing, certification fees, and business development for the Institute.
  - Drafting a new document or a new layer in the family. Recommending that one be considered is in scope, and SBCGS-C Appendix C already asks whether mobile delivery needs its own treatment, but writing it is a separate commission.

This board succeeds when:
  - A passed suggestion names the section it changes, correctly, and states what should change and why. A citation to a subsection that does not exist is a failed suggestion however good the idea.
  - The pass list can be applied to the markdown source by the standards session without further interpretation.
  - Suggestions differ by seat rather than converging, so that the record shows a genuine disagreement where one exists.
  - At least one passed suggestion engages a threshold the Institute flagged as unevidenced, rather than only the drafting that was easiest to improve.

---

## 1. Review Phase

### Suggestions by Member

**The Regulator** (ollama:qwen3:14b)
- S001: Amend SBCGS-T § 812(c) to reduce the number of simulated plays from ten million to one million, and adjust the confidence interval half width to one percentage point for configurations with a skill influence range of less than 10 percentage points, and to one-half of one percentage point for configurations with a skill influence range of 10 percentage points or greater.
  *Rationale: The current simulation requirements may be prohibitively expensive for small manufacturers, potentially limiting innovation and access to the market. A tiered approach based on the skill influence range would ensure accuracy while reducing costs.*
  *Evidence: Appendix B, Matter 1, which invites comment on whether the simulation requirements are attainable at reasonable cost for a small manufacturer. ---*
- S002: Clarify SBCGS-T § 815(b) to explicitly require that the rules of play for a skill-represented product must describe the skill element in a manner that is easily understood by an average player, using plain language and without technical jargon.
  *Rationale: The current text does not specify the level of clarity required for describing the skill element, which could lead to ambiguity in enforcement and allow poorly explained skill elements to pass certification.*
  *Evidence: Appendix B, Matter 2, which notes that the null strategy can be contested for products in which the player must act for the play to resolve at all, and the need for clearer definitions. ---*
- S003: Amend SBCGS-T § 818(g) to remove the prohibition on withdrawing a skill element from a player who has used it successfully, provided that the withdrawal is not based on the player's prior performance or the device's prior outcomes.
  *Rationale: The current prohibition may prevent legitimate design choices, such as limiting the availability of a skill element during certain times or under specific conditions, without unfairly disadvantaging players.*
  *Evidence: Appendix B, Matter 5, which invites comment on whether any of the prohibitions in § 818 would prohibit a design that is legitimate, in particular subsection (g).*

**The Test Laboratory** (ollama:qwen3:14b)
- S004: Amend SBCGS-T § 812(c) to allow for a tiered simulation requirement based on the skill influence range, such that configurations with a skill influence range below 5 percentage points require no simulation, and those above 5 percentage points require simulation of not fewer than five million plays per configuration, with a confidence interval half width not exceeding one tenth of one percentage point.
  *Rationale: The current requirement of ten million plays per configuration may be prohibitively expensive for small manufacturers, particularly for products with minimal skill influence. A tiered approach would reduce costs while maintaining statistical confidence for products where skill has a meaningful impact on outcomes.*
  *Evidence: SBCGS-T § 812(c); Appendix B, item 1, which invites comment on whether the current simulation requirements are attainable at reasonable cost for small manufacturers. ---*
- S005: Clarify in SBCGS-T § 813(b)(2) that the null strategy must not include any actions that are not explicitly presented on the device, and that the least effortful action must not involve prior knowledge or external instruction.
  *Rationale: The current wording may allow for actions that require knowledge or context not provided by the device, which could distort the measurement of the return at absent skill. A clear definition is necessary to ensure consistency across testing laboratories.*
  *Evidence: SBCGS-T § 813(b)(2); Note in § 813, which references a case where the null strategy did not actuate a prompt, leading to a return at absent skill that excluded the skill element entirely. ---*
- S006: Amend SBCGS-T § 815(e) to require the skill time cost ratio to be stated as value returned per unit of time, rather than as a ratio of median times.
  *Rationale: The current measure may not accurately reflect the player experience, as it focuses on time rather than the actual value gained per unit of time spent. A value-based measure would provide a clearer indication of the skill element's worth.*
  *Evidence: SBCGS-T § 815(e); Appendix B, item 3, which invites comment on whether the skill time cost ratio should instead be stated as value returned per unit of time.*

**The Licensed Organization** (ollama:qwen3:14b)
- S007: Amend SBCGS-M § 502(b) to allow the licensed organization to rely on the operator to provide documentation confirming that the charitable yield floor of 25% has been met, provided the documentation includes a breakdown of deductions and their corresponding beneficiaries, and is verified by the monitoring system.
  *Rationale: This would reduce the administrative burden on small volunteer-run organizations by allowing them to rely on operator-provided documentation rather than requiring them to independently verify and compute the charitable yield floor.*
  *Evidence: SBCGS-M § 502(b)(4) requires the monitoring system to accept the deduction categories and compute charitable yield, and SBCGS-T § 843(b) states that the monitoring system must compute charitable yield and retain the computation and its inputs.*
- S008: Amend SBCGS-M § 202(d) to clarify that the duties of the licensed organization may be fulfilled by volunteers, provided that the duties are documented in writing and reviewed periodically by a responsible person within the organization, and that the documentation is made available for inspection by the regulator.
  *Rationale: This would make it clear that small volunteer-run organizations are not required to have dedicated compliance staff, but that they are still responsible for fulfilling their duties in a manner that can be verified by the regulator.*
  *Evidence: SBCGS-M § 202(d) outlines the duties of the licensed organization, but does not explicitly address the role of volunteers or the documentation requirements for volunteer fulfillment of these duties.*
- S009: Amend SBCGS-M § 502(b) to permit the licensed organization to use a simplified quarterly computation method for determining charitable yield, provided that the method is approved by the monitoring system and is consistent with the operator's reporting requirements.
  *Rationale: This would make the quarterly computation more manageable for small organizations with limited resources, while still ensuring that the computation is accurate and verifiable.*
  *Evidence: SBCGS-M § 502(b) requires the licensed organization to ensure that the charitable yield floor is met, and SBCGS-T § 843(a) states that the monitoring system must compute the actual return to player and other relevant metrics.*

**The Player Advocate** (ollama:qwen3.5:9b)
- S010: In SBCGS-T § 823(a), replace the requirement "reachable from the idle state by a single player action" with "reachable without any prerequisite player action beyond the act of presenting consideration," and add subsection (f): "If a skill disclosure view is not visible at the moment consideration is committed, the device shall automatically present it immediately."
  *Rationale: A player standing at a device with cash in hand may be anxious, impaired, or illiterate. Requiring them to navigate menus or wait for an idle state to find the return figures creates a barrier to information that vanishes the moment they are vulnerable. If a disclosure is technically reachable but buried behind a menu, it is practically useless to a person who does not read longer than a sentence and may be in difficulty. The current "single action" standard allows operators to design interfaces where the disclosure is hidden behind complex navigation, defeating the purpose of the mandate.*
  *Evidence: SBCGS-T § 823(a) currently mandates reachability from the idle state; NCPG Report (October 2024) states that on average, states met only 32 out of 82 player protection standards, highlighting gaps in real-world effectiveness; SBCGS-M § 304(c)(1) requires disclosure but relies on the technical standard to ensure it is actually seen.*
- S011: In SBCGS-T § 815(e), replace "The skill time cost ratio does not exceed twenty" with "The median elapsed time required to complete a base play shall be stated in seconds, and the skill element shall not require more than two times that duration," and add: "Where a skill element is omitted because of this limit, the device shall not refuse to accept consideration."
  *Rationale: A twenty-to-one ratio between a skill task and a base play allows for egregious exploitation. If a base play takes 1 second, a skill task could take 20 seconds, creating a massive friction point that discourages use by anyone who is tired, distracted, or struggling with cognitive load. The current standard permits designs where the "skill" is a tedious chore that effectively blocks play. Protecting the player requires capping the time cost relative to the base game, not an arbitrary high number like twenty.*
  *Evidence: SBCGS-T § 815(e) defines the "skill time cost ratio" limit of twenty; NCPG Report (January 2023) notes that regulations in Delaware, Michigan, Nevada, and West Virginia lack sufficient responsible gambling protections; Note under SBCGS-T § 815 explicitly cites devices where skill elements took twelve minutes against a base play of a few seconds as failing the standard.*
- S012: In SBCGS-T § 823(c), change "The device shall display the skill influence range in the same view" to "The device shall display the skill influence range in the same view, and shall not suppress either figure without displaying the other, even if the computed range is zero or negligible."
  *Rationale: The current standard allows a device to hide one of the two return figures if the range is zero. This creates a loophole where operators can claim "no skill element" by engineering a game where the skill does nothing, thereby suppressing the disclosure entirely. A player needs to know that their input has *no* effect on the outcome, not just a positive effect. Hiding the fact that skill contributes nothing (or very little) misrepresents the nature of the product and fails to inform the player that they are essentially playing a game of chance.*
  *Evidence: SBCGS-T § 823(b) prohibits displaying one figure without the other, but § 823(c) creates a contradictory exception by requiring the range display only when figures are shown; SBCGS-T § 814(c) states that if the range is zero, the product cannot be a skill product, yet § 823(e) allows nominal skill products to hide statements about skill dependence, creating an inconsistency in how information is presented to the player.*

**The Operator** (ollama:qwen3:14b)
- S013: Amend SBCGS-T § 812(c) to permit a reduced number of simulated plays (e.g., five million) for configurations with a skill influence range below 5 percentage points, with a confidence interval half width not exceeding 0.15 percentage points.
  *Rationale: This would reduce the computational and operational burden on small manufacturers while maintaining sufficient statistical accuracy for products with minimal skill influence.*
  *Evidence: Appendix B, Item 1 invites comment on whether the current simulation requirements are attainable at reasonable cost for small manufacturers and whether tiered requirements might be preferable. ---*
- S014: Clarify in SBCGS-T § 815(d)(2) that the prompt for a skill element must remain visible for at least fifteen seconds or the duration of the commit period, whichever is longer, and that the prompt must not be obscured by other on-screen elements.
  *Rationale: Ambiguity in prompt visibility can lead to inconsistent enforcement and player confusion, particularly in configurations where the prompt appears briefly or is easily missed.*
  *Evidence: Appendix B, Item 3 notes that the skill time cost ratio is currently set at twenty, and there is a suggestion to reframe the measure as value returned per unit of time, which is closer to player experience. ---*
- S015: Add a new subsection to SBCGS-T § 816 requiring that skill event records be retained on the device for a minimum of thirty days, in addition to being transmitted to the monitoring system.
  *Rationale: This ensures that operators and regulators can access historical data for troubleshooting, auditing, or dispute resolution without relying solely on the monitoring system.*
  *Evidence: SBCGS-T § 861(a) requires that a covered device retain information sufficient to reconstruct recent plays and sessions, which supports the need for local retention of skill event records.*

---

## 2. Pool Phase

**Leader actions:**
- 15 suggestion(s) retained as submitted

**Final pool: 15 suggestions (from 15 submitted; 0 merged)**

- S001: Amend SBCGS-T § 812(c) to reduce the number of simulated plays from ten million to one million, and adjust the confidence interval half width to one percentage point for configurations with a skill influence range of less than 10 percentage points, and to one-half of one percentage point for configurations with a skill influence range of 10 percentage points or greater.
- S002: Clarify SBCGS-T § 815(b) to explicitly require that the rules of play for a skill-represented product must describe the skill element in a manner that is easily understood by an average player, using plain language and without technical jargon.
- S003: Amend SBCGS-T § 818(g) to remove the prohibition on withdrawing a skill element from a player who has used it successfully, provided that the withdrawal is not based on the player's prior performance or the device's prior outcomes.
- S004: Amend SBCGS-T § 812(c) to allow for a tiered simulation requirement based on the skill influence range, such that configurations with a skill influence range below 5 percentage points require no simulation, and those above 5 percentage points require simulation of not fewer than five million plays per configuration, with a confidence interval half width not exceeding one tenth of one percentage point.
- S005: Clarify in SBCGS-T § 813(b)(2) that the null strategy must not include any actions that are not explicitly presented on the device, and that the least effortful action must not involve prior knowledge or external instruction.
- S006: Amend SBCGS-T § 815(e) to require the skill time cost ratio to be stated as value returned per unit of time, rather than as a ratio of median times.
- S007: Amend SBCGS-M § 502(b) to allow the licensed organization to rely on the operator to provide documentation confirming that the charitable yield floor of 25% has been met, provided the documentation includes a breakdown of deductions and their corresponding beneficiaries, and is verified by the monitoring system.
- S008: Amend SBCGS-M § 202(d) to clarify that the duties of the licensed organization may be fulfilled by volunteers, provided that the duties are documented in writing and reviewed periodically by a responsible person within the organization, and that the documentation is made available for inspection by the regulator.
- S009: Amend SBCGS-M § 502(b) to permit the licensed organization to use a simplified quarterly computation method for determining charitable yield, provided that the method is approved by the monitoring system and is consistent with the operator's reporting requirements.
- S010: In SBCGS-T § 823(a), replace the requirement "reachable from the idle state by a single player action" with "reachable without any prerequisite player action beyond the act of presenting consideration," and add subsection (f): "If a skill disclosure view is not visible at the moment consideration is committed, the device shall automatically present it immediately."
- S011: In SBCGS-T § 815(e), replace "The skill time cost ratio does not exceed twenty" with "The median elapsed time required to complete a base play shall be stated in seconds, and the skill element shall not require more than two times that duration," and add: "Where a skill element is omitted because of this limit, the device shall not refuse to accept consideration."
- S012: In SBCGS-T § 823(c), change "The device shall display the skill influence range in the same view" to "The device shall display the skill influence range in the same view, and shall not suppress either figure without displaying the other, even if the computed range is zero or negligible."
- S013: Amend SBCGS-T § 812(c) to permit a reduced number of simulated plays (e.g., five million) for configurations with a skill influence range below 5 percentage points, with a confidence interval half width not exceeding 0.15 percentage points.
- S014: Clarify in SBCGS-T § 815(d)(2) that the prompt for a skill element must remain visible for at least fifteen seconds or the duration of the commit period, whichever is longer, and that the prompt must not be obscured by other on-screen elements.
- S015: Add a new subsection to SBCGS-T § 816 requiring that skill event records be retained on the device for a minimum of thirty days, in addition to being transmitted to the monitoring system.

---

## 3. Vote Phase


*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*

### Votes on S001: Amend SBCGS-T § 812(c) to reduce the number of simulated plays from ten million to one million, and adjust the confidence interval half width to one percentage point for configurations with a skill influence range of less than 10 percentage points, and to one-half of one percentage point for configurations with a skill influence range of 10 percentage points or greater.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Test Laboratory | Marcus Brennan, SA | YES | The tiered approach to simulation requirements aligns with the principle of testability and affordability, ensuring that the pass condition is both measurable and consistent across laboratories, while reducing unnecessary costs for manufacturers with minimal skill influence. |
| The Licensed Organization | Eileen Cortland, SA | YES | This amendment addresses a practical concern for small manufacturers by reducing the number of simulated plays and adjusting the confidence interval based on the skill influence range. It maintains the integrity of the standard while making it more affordable and feasible for smaller entities to comply. |
| The Player Advocate | Theodore Gilliam, SA | NO | Reducing simulations to one million plays for low-skill products creates a statistical loophole where operators can mathematically fake a "skill" element that vanishes instantly, leaving the player with cash in hand completely unprotected against pure chance. |
| The Operator | Danny Sokolov, SA | YES | Reducing the number of simulated plays based on the skill influence range aligns with the goal of making compliance more affordable for small manufacturers while still maintaining statistical confidence, which benefits operators like myself by reducing costs and increasing innovation. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 3 YES / 1 NO / 1 ABSTAIN → 75% (threshold: 51%) → PASSED**

### Votes on S002: Clarify SBCGS-T § 815(b) to explicitly require that the rules of play for a skill-represented product must describe the skill element in a manner that is easily understood by an average player, using plain language and without technical jargon.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Test Laboratory | Marcus Brennan, SA | YES | Requiring the use of plain language for describing the skill element provides a clear, observable pass condition that can be tested through review of the actual interface and documentation, ensuring consistency in enforcement and clarity for players. |
| The Licensed Organization | Eileen Cortland, SA | YES | Clarifying the language requirement for describing the skill element ensures that players receive clear and comprehensible information, which is essential for informed decision-making. This change improves enforceability and consistency across certification. |
| The Player Advocate | Theodore Gilliam, SA | YES | Requiring plain language descriptions ensures the person standing at the device actually understands what they are doing rather than reading a legal definition they will not read longer than a sentence. |
| The Operator | Danny Sokolov, SA | YES | Requiring plain language for describing the skill element ensures clarity and consistency in enforcement, which is critical for avoiding ambiguity that could lead to inconsistent interpretations by inspectors or laboratories. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S003: Amend SBCGS-T § 818(g) to remove the prohibition on withdrawing a skill element from a player who has used it successfully, provided that the withdrawal is not based on the player's prior performance or the device's prior outcomes.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | The suggestion raises a policy and design question that may not be fully testable or enforceable in practice. While the intent to allow certain design choices is understandable, the language does not clearly define what constitutes "legitimate design choices" or how to measure fairness in the withdrawal of a skill element, making it ambiguous for testing. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | While the suggestion raises a potentially valid point about design flexibility, the current prohibition is intended to prevent unfair disadvantage to players. The suggestion lacks sufficient detail on how the withdrawal of a skill element would be implemented without affecting player fairness, making it difficult to assess fully. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | Allowing withdrawal of skill elements based on time or conditions creates an arbitrary barrier that effectively punishes players who need to finish their play but cannot, undermining the core mandate of protecting those in difficulty. |
| The Operator | Danny Sokolov, SA | ABSTAIN | The suggestion raises a legitimate design concern, but the current prohibition is likely intended to prevent unfair discrimination based on performance history. Without clearer guidance on what constitutes a legitimate design choice, it’s difficult to assess whether this change would lead to unintended consequences or enforcement challenges. I remain neutral pending further clarification on the intent and scope of the prohibition. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 0 YES / 0 NO / 5 ABSTAIN → 0% (threshold: 51%) → FAILED**

### Votes on S004: Amend SBCGS-T § 812(c) to allow for a tiered simulation requirement based on the skill influence range, such that configurations with a skill influence range below 5 percentage points require no simulation, and those above 5 percentage points require simulation of not fewer than five million plays per configuration, with a confidence interval half width not exceeding one tenth of one percentage point.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | This suggestion provides a clear, enforceable tiered simulation requirement based on the skill influence range, which directly addresses the cost concerns for small manufacturers while maintaining statistical confidence. It allocates the obligation to the manufacturer and provides measurable criteria that can be verified by laboratories and regulators. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Licensed Organization | Eileen Cortland, SA | YES | This proposal offers a tiered simulation requirement that aligns with the skill influence range, which is a logical and scalable approach. It reduces the burden on small manufacturers while preserving the accuracy of testing for configurations with significant skill impact. |
| The Player Advocate | Theodore Gilliam, SA | YES | Permitting zero simulation for negligible skill influence acknowledges reality where the cost is prohibitive and the product is functionally a slot machine, preventing small manufacturers from being crushed by impossible math while keeping the player informed they are playing chance. |
| The Operator | Danny Sokolov, SA | NO | The proposal creates a more extreme tiered system that may be even more costly for some configurations and introduces new complexity without clear benefit. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 3 YES / 1 NO / 1 ABSTAIN → 75% (threshold: 51%) → PASSED**

### Votes on S005: Clarify in SBCGS-T § 813(b)(2) that the null strategy must not include any actions that are not explicitly presented on the device, and that the least effortful action must not involve prior knowledge or external instruction.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | This clarification ensures that the null strategy and least effortful action are defined in a way that can be consistently tested and enforced. It removes ambiguity and ensures that testing laboratories can determine compliance based on objective criteria, without relying on external knowledge or context. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Licensed Organization | Eileen Cortland, SA | YES | Clarifying that the null strategy must not include actions not presented on the device ensures that testing remains consistent and fair. This change strengthens the enforceability and reliability of return at absent skill measurements. |
| The Player Advocate | Theodore Gilliam, SA | YES | Explicitly banning actions requiring external knowledge closes the door on hidden mechanics that distort return measurements and trick players into believing they have skill where there is none. |
| The Operator | Danny Sokolov, SA | YES | Clarifying the null strategy and least effortful action ensures consistent testing and avoids distortion of return at absent skill measurements. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S006: Amend SBCGS-T § 815(e) to require the skill time cost ratio to be stated as value returned per unit of time, rather than as a ratio of median times.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Changing the skill time cost ratio to a value-based measure per unit of time aligns better with the player experience and provides a clearer, more meaningful metric for enforcement. This requirement can be measured and verified, making it enforceable and useful for both regulators and players. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Licensed Organization | Eileen Cortland, SA | YES | Expressing the skill time cost ratio as value returned per unit of time provides a more meaningful metric for players. It shifts the focus from abstract ratios to a tangible measure of player experience, enhancing clarity and effectiveness. S007: [Already authored - do not vote] S008: [Already authored - do not vote] S009: [Already authored - do not vote] |
| The Player Advocate | Theodore Gilliam, SA | NO | Changing the metric to "value per time" introduces too much subjectivity regarding what a player values, whereas a strict ratio cap is the only enforceable standard a regulator can test without needing to survey every player's feelings. |
| The Operator | Danny Sokolov, SA | YES | Expressing the skill time cost ratio as value returned per unit time aligns better with player experience and provides a clearer measure of skill element worth. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 3 YES / 1 NO / 1 ABSTAIN → 75% (threshold: 51%) → PASSED**

### Votes on S007: Amend SBCGS-M § 502(b) to allow the licensed organization to rely on the operator to provide documentation confirming that the charitable yield floor of 25% has been met, provided the documentation includes a breakdown of deductions and their corresponding beneficiaries, and is verified by the monitoring system.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | This amendment allows the licensed organization to rely on operator-provided documentation, which is verifiable by the monitoring system. It reduces administrative burden while ensuring that the regulator can still inspect and verify compliance through existing systems and records. |
| The Test Laboratory | Marcus Brennan, SA | YES | Allowing reliance on operator-provided documentation reduces administrative burdens for small organizations while maintaining accountability through verification by the monitoring system. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Player Advocate | Theodore Gilliam, SA | YES | Allowing reliance on operator documentation reduces the administrative burden on volunteer organizations so they can focus on their mission rather than getting bogged down in impossible verification tasks. |
| The Operator | Danny Sokolov, SA | YES | Relying on operator documentation reduces administrative burden on small organizations without compromising verification. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S008: Amend SBCGS-M § 202(d) to clarify that the duties of the licensed organization may be fulfilled by volunteers, provided that the duties are documented in writing and reviewed periodically by a responsible person within the organization, and that the documentation is made available for inspection by the regulator.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | This clarification ensures that small volunteer-run organizations are not unfairly burdened by the requirement to have dedicated compliance staff. It allows for volunteer fulfillment of duties, provided that documentation is maintained and available for inspection, which is enforceable and verifiable. |
| The Test Laboratory | Marcus Brennan, SA | YES | Clarifying that volunteers can fulfill duties with proper documentation supports small organizations without compromising regulatory oversight or accountability. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Player Advocate | Theodore Gilliam, SA | NO | While documenting duties is good, explicitly authorizing volunteers to fulfill them invites ambiguity about training and liability that a regulator cannot enforce consistently across different jurisdictions without creating a mess of conflicting interpretations. |
| The Operator | Danny Sokolov, SA | YES | Allowing volunteers to fulfill duties with proper documentation supports small organizations while maintaining regulatory oversight. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 3 YES / 1 NO / 1 ABSTAIN → 75% (threshold: 51%) → PASSED**

### Votes on S009: Amend SBCGS-M § 502(b) to permit the licensed organization to use a simplified quarterly computation method for determining charitable yield, provided that the method is approved by the monitoring system and is consistent with the operator's reporting requirements.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Allowing a simplified quarterly computation method, provided it is approved by the monitoring system, reduces the burden on small organizations while ensuring that the method remains consistent with operator reporting requirements. This can be enforced and verified through the monitoring system. |
| The Test Laboratory | Marcus Brennan, SA | YES | A simplified quarterly computation method, if approved by the monitoring system, can ease the administrative load on small organizations without sacrificing accuracy or verifiability. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Player Advocate | Theodore Gilliam, SA | YES | Approving simplified quarterly computation methods makes the charitable yield requirement actually achievable for small groups, ensuring the floor is met in practice rather than just on paper through impossible bookkeeping. S010: [You authored this] S011: [You authored this] |
| The Operator | Danny Sokolov, SA | YES | A simplified quarterly computation method makes compliance more manageable for small organizations without sacrificing accuracy. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S010: In SBCGS-T § 823(a), replace the requirement "reachable from the idle state by a single player action" with "reachable without any prerequisite player action beyond the act of presenting consideration," and add subsection (f): "If a skill disclosure view is not visible at the moment consideration is committed, the device shall automatically present it immediately."

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | This amendment strengthens player access to critical information by ensuring that skill disclosure is presented immediately when consideration is committed, regardless of the device's state. It eliminates the possibility of hiding disclosures behind menus or requiring navigation, making the requirement enforceable and meaningful for players. |
| The Test Laboratory | Marcus Brennan, SA | YES | Requiring immediate disclosure of skill information upon consideration commitment ensures players receive critical information without unnecessary barriers, aligning with the intent of the standard. |
| The Licensed Organization | Eileen Cortland, SA | YES | This change directly addresses a critical usability issue for players who may be under stress or cognitive load. Requiring the skill disclosure to be immediately visible when consideration is committed ensures that players receive the information they need at the moment it matters most. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Operator | Danny Sokolov, SA | YES | The revised requirement ensures that skill disclosures are immediately visible when consideration is committed, preventing practical barriers to information access. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S011: In SBCGS-T § 815(e), replace "The skill time cost ratio does not exceed twenty" with "The median elapsed time required to complete a base play shall be stated in seconds, and the skill element shall not require more than two times that duration," and add: "Where a skill element is omitted because of this limit, the device shall not refuse to accept consideration."

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Replacing the arbitrary ratio with a cap on the time cost relative to the base play ensures that the skill element does not become a barrier to participation. This standard is enforceable, measurable, and aligned with protecting player interests. |
| The Test Laboratory | Marcus Brennan, SA | YES | Capping the skill time cost relative to the base play prevents excessive friction and ensures the skill element does not become a hindrance to play, protecting player experience. |
| The Licensed Organization | Eileen Cortland, SA | YES | Capping the skill time cost ratio relative to the base play duration prevents exploitative design choices that could unfairly burden players. This change better protects player interests and aligns the standard with the intent of skill-based gaming. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Operator | Danny Sokolov, SA | YES | Capping the skill time cost relative to the base play duration prevents exploitative design and protects players from excessive friction. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S012: In SBCGS-T § 823(c), change "The device shall display the skill influence range in the same view" to "The device shall display the skill influence range in the same view, and shall not suppress either figure without displaying the other, even if the computed range is zero or negligible."

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | This amendment prevents operators from suppressing one return figure while displaying the other, which would mislead players. It ensures that both figures are visible, even if the computed range is zero or negligible, making the requirement enforceable and transparent. |
| The Test Laboratory | Marcus Brennan, SA | YES | Requiring both figures to be displayed, even if the skill influence range is zero, prevents misleading disclosures and ensures players are fully informed about the nature of the product. |
| The Licensed Organization | Eileen Cortland, SA | YES | This amendment closes a loophole that allows operators to suppress skill influence disclosures when the range is zero or negligible. Ensuring both figures are displayed, regardless of the range, enhances transparency and player understanding. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Operator | Danny Sokolov, SA | YES | Requiring both figures to be displayed even when the skill influence range is zero ensures transparency and prevents misleading suppression of information. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S013: Amend SBCGS-T § 812(c) to permit a reduced number of simulated plays (e.g., five million) for configurations with a skill influence range below 5 percentage points, with a confidence interval half width not exceeding 0.15 percentage points.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | This suggestion proposes a reduced number of simulated plays for configurations with a low skill influence range, which is cost-effective and maintains statistical accuracy. It provides measurable criteria that can be enforced and tested by laboratories. |
| The Test Laboratory | Marcus Brennan, SA | YES | Reducing the number of simulated plays for low-skill configurations lowers costs while maintaining acceptable statistical accuracy, supporting smaller manufacturers. |
| The Licensed Organization | Eileen Cortland, SA | YES | This proposal is similar to S001 and S004, and it offers a practical adjustment that reduces the computational burden on small manufacturers without compromising the standard’s effectiveness. |
| The Player Advocate | Theodore Gilliam, SA | YES | Reducing simulations to five million for minimal skill influence balances the need for statistical rigor with the economic reality of small manufacturers, ensuring they can innovate without being driven out of business by impossible computational costs. |
| The Operator | Danny Sokolov, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S014: Clarify in SBCGS-T § 815(d)(2) that the prompt for a skill element must remain visible for at least fifteen seconds or the duration of the commit period, whichever is longer, and that the prompt must not be obscured by other on-screen elements.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Requiring the prompt for a skill element to remain visible for a minimum duration ensures that players are adequately informed and reduces the risk of missed prompts. This is enforceable and can be measured through device logs and testing. |
| The Test Laboratory | Marcus Brennan, SA | YES | Ensuring prompt visibility for a minimum duration improves player awareness and prevents prompts from being missed or obscured, enhancing transparency. |
| The Licensed Organization | Eileen Cortland, SA | YES | Clarifying the visibility duration and placement of skill prompts ensures that players are not disadvantaged by fleeting or obscured information. This change improves usability and enforceability of the standard. |
| The Player Advocate | Theodore Gilliam, SA | NO | Specifying a fifteen-second duration is technically specific but practically evadable if the interface refreshes or overlays change; it is better to require continuous visibility that cannot be obscured rather than setting an arbitrary timer that can be bypassed by poor design. |
| The Operator | Danny Sokolov, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 3 YES / 1 NO / 1 ABSTAIN → 75% (threshold: 51%) → PASSED**

### Votes on S015: Add a new subsection to SBCGS-T § 816 requiring that skill event records be retained on the device for a minimum of thirty days, in addition to being transmitted to the monitoring system.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Requiring the retention of skill event records on the device for thirty days ensures that historical data is available for auditing, troubleshooting, and dispute resolution. This requirement is enforceable and can be verified through device logs and monitoring systems. |
| The Test Laboratory | Marcus Brennan, SA | YES | Retaining skill event records on the device for thirty days provides a reliable backup for auditing, troubleshooting, and dispute resolution without relying solely on external systems. |
| The Licensed Organization | Eileen Cortland, SA | YES | Requiring skill event records to be retained on the device for a minimum of thirty days supports transparency, auditing, and dispute resolution. It adds an important layer of accountability and ensures data availability even when the monitoring system is inaccessible. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | Requiring device-side retention of records for thirty days creates a significant security risk and storage cost burden on operators, which may lead them to disable the feature entirely or store it insecurely, failing the test of whether a protection actually reaches the player safely. |
| The Operator | Danny Sokolov, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 3 YES / 0 NO / 2 ABSTAIN → 100% (threshold: 51%) → PASSED**

## 4. Pass List

| ID | Suggestion | Yes | No | Abstain | % | Result |
|----|-----------|-----|----|---------|---|--------|
| S001 | Amend SBCGS-T § 812(c) to reduce the number of simulated plays from ten million to one million, and adjust the confidence interval half width to one percentage point for configurations with a skill influence range of less than 10 percentage points, and to one-half of one percentage point for configurations with a skill influence range of 10 percentage points or greater. | 3 | 1 | 1 | 75% | ✓ PASSED |
| S002 | Clarify SBCGS-T § 815(b) to explicitly require that the rules of play for a skill-represented product must describe the skill element in a manner that is easily understood by an average player, using plain language and without technical jargon. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S003 | Amend SBCGS-T § 818(g) to remove the prohibition on withdrawing a skill element from a player who has used it successfully, provided that the withdrawal is not based on the player's prior performance or the device's prior outcomes. | 0 | 0 | 5 | 0% | ✗ FAILED |
| S004 | Amend SBCGS-T § 812(c) to allow for a tiered simulation requirement based on the skill influence range, such that configurations with a skill influence range below 5 percentage points require no simulation, and those above 5 percentage points require simulation of not fewer than five million plays per configuration, with a confidence interval half width not exceeding one tenth of one percentage point. | 3 | 1 | 1 | 75% | ✓ PASSED |
| S005 | Clarify in SBCGS-T § 813(b)(2) that the null strategy must not include any actions that are not explicitly presented on the device, and that the least effortful action must not involve prior knowledge or external instruction. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S006 | Amend SBCGS-T § 815(e) to require the skill time cost ratio to be stated as value returned per unit of time, rather than as a ratio of median times. | 3 | 1 | 1 | 75% | ✓ PASSED |
| S007 | Amend SBCGS-M § 502(b) to allow the licensed organization to rely on the operator to provide documentation confirming that the charitable yield floor of 25% has been met, provided the documentation includes a breakdown of deductions and their corresponding beneficiaries, and is verified by the monitoring system. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S008 | Amend SBCGS-M § 202(d) to clarify that the duties of the licensed organization may be fulfilled by volunteers, provided that the duties are documented in writing and reviewed periodically by a responsible person within the organization, and that the documentation is made available for inspection by the regulator. | 3 | 1 | 1 | 75% | ✓ PASSED |
| S009 | Amend SBCGS-M § 502(b) to permit the licensed organization to use a simplified quarterly computation method for determining charitable yield, provided that the method is approved by the monitoring system and is consistent with the operator's reporting requirements. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S010 | In SBCGS-T § 823(a), replace the requirement "reachable from the idle state by a single player action" with "reachable without any prerequisite player action beyond the act of presenting consideration," and add subsection (f): "If a skill disclosure view is not visible at the moment consideration is committed, the device shall automatically present it immediately." | 4 | 0 | 1 | 100% | ✓ PASSED |
| S011 | In SBCGS-T § 815(e), replace "The skill time cost ratio does not exceed twenty" with "The median elapsed time required to complete a base play shall be stated in seconds, and the skill element shall not require more than two times that duration," and add: "Where a skill element is omitted because of this limit, the device shall not refuse to accept consideration." | 4 | 0 | 1 | 100% | ✓ PASSED |
| S012 | In SBCGS-T § 823(c), change "The device shall display the skill influence range in the same view" to "The device shall display the skill influence range in the same view, and shall not suppress either figure without displaying the other, even if the computed range is zero or negligible." | 4 | 0 | 1 | 100% | ✓ PASSED |
| S013 | Amend SBCGS-T § 812(c) to permit a reduced number of simulated plays (e.g., five million) for configurations with a skill influence range below 5 percentage points, with a confidence interval half width not exceeding 0.15 percentage points. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S014 | Clarify in SBCGS-T § 815(d)(2) that the prompt for a skill element must remain visible for at least fifteen seconds or the duration of the commit period, whichever is longer, and that the prompt must not be obscured by other on-screen elements. | 3 | 1 | 1 | 75% | ✓ PASSED |
| S015 | Add a new subsection to SBCGS-T § 816 requiring that skill event records be retained on the device for a minimum of thirty days, in addition to being transmitted to the monitoring system. | 3 | 0 | 2 | 100% | ✓ PASSED |

**Total: 15 suggestions reviewed. 14 passed. 1 failed.**

**S001** key rationales:
- The Test Laboratory: The tiered approach to simulation requirements aligns with the principle of testability and affordability, ensuring that the pass condition is both measurable and consistent across laboratories, while reducing unnecessary costs for manufacturers with minimal skill influence.
- The Licensed Organization: This amendment addresses a practical concern for small manufacturers by reducing the number of simulated plays and adjusting the confidence interval based on the skill influence range. It maintains the integrity of the standard while making it more affordable and feasible for smaller entities to comply.
- The Operator: Reducing the number of simulated plays based on the skill influence range aligns with the goal of making compliance more affordable for small manufacturers while still maintaining statistical confidence, which benefits operators like myself by reducing costs and increasing innovation.

**S002** key rationales:
- The Test Laboratory: Requiring the use of plain language for describing the skill element provides a clear, observable pass condition that can be tested through review of the actual interface and documentation, ensuring consistency in enforcement and clarity for players.
- The Licensed Organization: Clarifying the language requirement for describing the skill element ensures that players receive clear and comprehensible information, which is essential for informed decision-making. This change improves enforceability and consistency across certification.
- The Player Advocate: Requiring plain language descriptions ensures the person standing at the device actually understands what they are doing rather than reading a legal definition they will not read longer than a sentence.
- The Operator: Requiring plain language for describing the skill element ensures clarity and consistency in enforcement, which is critical for avoiding ambiguity that could lead to inconsistent interpretations by inspectors or laboratories.

**S004** key rationales:
- The Regulator: This suggestion provides a clear, enforceable tiered simulation requirement based on the skill influence range, which directly addresses the cost concerns for small manufacturers while maintaining statistical confidence. It allocates the obligation to the manufacturer and provides measurable criteria that can be verified by laboratories and regulators.
- The Licensed Organization: This proposal offers a tiered simulation requirement that aligns with the skill influence range, which is a logical and scalable approach. It reduces the burden on small manufacturers while preserving the accuracy of testing for configurations with significant skill impact.
- The Player Advocate: Permitting zero simulation for negligible skill influence acknowledges reality where the cost is prohibitive and the product is functionally a slot machine, preventing small manufacturers from being crushed by impossible math while keeping the player informed they are playing chance.

**S005** key rationales:
- The Regulator: This clarification ensures that the null strategy and least effortful action are defined in a way that can be consistently tested and enforced. It removes ambiguity and ensures that testing laboratories can determine compliance based on objective criteria, without relying on external knowledge or context.
- The Licensed Organization: Clarifying that the null strategy must not include actions not presented on the device ensures that testing remains consistent and fair. This change strengthens the enforceability and reliability of return at absent skill measurements.
- The Player Advocate: Explicitly banning actions requiring external knowledge closes the door on hidden mechanics that distort return measurements and trick players into believing they have skill where there is none.
- The Operator: Clarifying the null strategy and least effortful action ensures consistent testing and avoids distortion of return at absent skill measurements.

**S006** key rationales:
- The Regulator: Changing the skill time cost ratio to a value-based measure per unit of time aligns better with the player experience and provides a clearer, more meaningful metric for enforcement. This requirement can be measured and verified, making it enforceable and useful for both regulators and players.
- The Licensed Organization: Expressing the skill time cost ratio as value returned per unit of time provides a more meaningful metric for players. It shifts the focus from abstract ratios to a tangible measure of player experience, enhancing clarity and effectiveness. S007: [Already authored - do not vote] S008: [Already authored - do not vote] S009: [Already authored - do not vote]
- The Operator: Expressing the skill time cost ratio as value returned per unit time aligns better with player experience and provides a clearer measure of skill element worth.

**S007** key rationales:
- The Regulator: This amendment allows the licensed organization to rely on operator-provided documentation, which is verifiable by the monitoring system. It reduces administrative burden while ensuring that the regulator can still inspect and verify compliance through existing systems and records.
- The Test Laboratory: Allowing reliance on operator-provided documentation reduces administrative burdens for small organizations while maintaining accountability through verification by the monitoring system.
- The Player Advocate: Allowing reliance on operator documentation reduces the administrative burden on volunteer organizations so they can focus on their mission rather than getting bogged down in impossible verification tasks.
- The Operator: Relying on operator documentation reduces administrative burden on small organizations without compromising verification.

**S008** key rationales:
- The Regulator: This clarification ensures that small volunteer-run organizations are not unfairly burdened by the requirement to have dedicated compliance staff. It allows for volunteer fulfillment of duties, provided that documentation is maintained and available for inspection, which is enforceable and verifiable.
- The Test Laboratory: Clarifying that volunteers can fulfill duties with proper documentation supports small organizations without compromising regulatory oversight or accountability.
- The Operator: Allowing volunteers to fulfill duties with proper documentation supports small organizations while maintaining regulatory oversight.

**S009** key rationales:
- The Regulator: Allowing a simplified quarterly computation method, provided it is approved by the monitoring system, reduces the burden on small organizations while ensuring that the method remains consistent with operator reporting requirements. This can be enforced and verified through the monitoring system.
- The Test Laboratory: A simplified quarterly computation method, if approved by the monitoring system, can ease the administrative load on small organizations without sacrificing accuracy or verifiability.
- The Player Advocate: Approving simplified quarterly computation methods makes the charitable yield requirement actually achievable for small groups, ensuring the floor is met in practice rather than just on paper through impossible bookkeeping. S010: [You authored this] S011: [You authored this]
- The Operator: A simplified quarterly computation method makes compliance more manageable for small organizations without sacrificing accuracy.

**S010** key rationales:
- The Regulator: This amendment strengthens player access to critical information by ensuring that skill disclosure is presented immediately when consideration is committed, regardless of the device's state. It eliminates the possibility of hiding disclosures behind menus or requiring navigation, making the requirement enforceable and meaningful for players.
- The Test Laboratory: Requiring immediate disclosure of skill information upon consideration commitment ensures players receive critical information without unnecessary barriers, aligning with the intent of the standard.
- The Licensed Organization: This change directly addresses a critical usability issue for players who may be under stress or cognitive load. Requiring the skill disclosure to be immediately visible when consideration is committed ensures that players receive the information they need at the moment it matters most.
- The Operator: The revised requirement ensures that skill disclosures are immediately visible when consideration is committed, preventing practical barriers to information access.

**S011** key rationales:
- The Regulator: Replacing the arbitrary ratio with a cap on the time cost relative to the base play ensures that the skill element does not become a barrier to participation. This standard is enforceable, measurable, and aligned with protecting player interests.
- The Test Laboratory: Capping the skill time cost relative to the base play prevents excessive friction and ensures the skill element does not become a hindrance to play, protecting player experience.
- The Licensed Organization: Capping the skill time cost ratio relative to the base play duration prevents exploitative design choices that could unfairly burden players. This change better protects player interests and aligns the standard with the intent of skill-based gaming.
- The Operator: Capping the skill time cost relative to the base play duration prevents exploitative design and protects players from excessive friction.

**S012** key rationales:
- The Regulator: This amendment prevents operators from suppressing one return figure while displaying the other, which would mislead players. It ensures that both figures are visible, even if the computed range is zero or negligible, making the requirement enforceable and transparent.
- The Test Laboratory: Requiring both figures to be displayed, even if the skill influence range is zero, prevents misleading disclosures and ensures players are fully informed about the nature of the product.
- The Licensed Organization: This amendment closes a loophole that allows operators to suppress skill influence disclosures when the range is zero or negligible. Ensuring both figures are displayed, regardless of the range, enhances transparency and player understanding.
- The Operator: Requiring both figures to be displayed even when the skill influence range is zero ensures transparency and prevents misleading suppression of information.

**S013** key rationales:
- The Regulator: This suggestion proposes a reduced number of simulated plays for configurations with a low skill influence range, which is cost-effective and maintains statistical accuracy. It provides measurable criteria that can be enforced and tested by laboratories.
- The Test Laboratory: Reducing the number of simulated plays for low-skill configurations lowers costs while maintaining acceptable statistical accuracy, supporting smaller manufacturers.
- The Licensed Organization: This proposal is similar to S001 and S004, and it offers a practical adjustment that reduces the computational burden on small manufacturers without compromising the standard’s effectiveness.
- The Player Advocate: Reducing simulations to five million for minimal skill influence balances the need for statistical rigor with the economic reality of small manufacturers, ensuring they can innovate without being driven out of business by impossible computational costs.

**S014** key rationales:
- The Regulator: Requiring the prompt for a skill element to remain visible for a minimum duration ensures that players are adequately informed and reduces the risk of missed prompts. This is enforceable and can be measured through device logs and testing.
- The Test Laboratory: Ensuring prompt visibility for a minimum duration improves player awareness and prevents prompts from being missed or obscured, enhancing transparency.
- The Licensed Organization: Clarifying the visibility duration and placement of skill prompts ensures that players are not disadvantaged by fleeting or obscured information. This change improves usability and enforceability of the standard.

**S015** key rationales:
- The Regulator: Requiring the retention of skill event records on the device for thirty days ensures that historical data is available for auditing, troubleshooting, and dispute resolution. This requirement is enforceable and can be verified through device logs and monitoring systems.
- The Test Laboratory: Retaining skill event records on the device for thirty days provides a reliable backup for auditing, troubleshooting, and dispute resolution without relying solely on external systems.
- The Licensed Organization: Requiring skill event records to be retained on the device for a minimum of thirty days supports transparency, auditing, and dispute resolution. It adds an important layer of accountability and ensures data availability even when the monitoring system is inaccessible.

---

## 5. Completion

Timestamp: 2026-10-02T04:20:06+00:00
Configured actions: report, publish

- **report** OK: report present and current at /mnt/d/tools/apps/skillgames/logs/2026-10/T/report.md
- **publish** OK: pass list published to /mnt/d/tools/apps/skillgames/logs/2026-10/T/published/latest.json (and skillgames-2026-10-T-2026-10-01.json)