Is it definitely clear that it would be legal for a startup based in the U.S. and with American founders to use Betable? It wasn't until "Black Friday" (http://en.wikipedia.org/wiki/Black_Friday_(2011)) that it became clear the U.S. government viewed NLH poker as a game of chance, and Googling I've done in the past suggests that certain aspects of the government's intrepretation of online poker's legality remain vague. So is it a definite that what the U.S. government viewed as criminal money laundering was not that Americans were taking income from running online casinos but rather that those three casinos were allowing Americans to gamble? Or was it that those casinos made money off of their American customers? I.e. would a gambling site that didn't take a rake and just ran on ad revenue be allowed to have American customers? (I assume not, but then I'm unclear what the alleged money laundering charges were.)

So to make a medium-length post short, I'm an American citizen. Would I definitely be allowed to use Betable? If so, this is great news for me.

"is it a definite that what the U.S. government viewed as criminal money laundering was not that Americans were taking income from running online casinos but rather that those three casinos were allowing Americans to gamble?"

It is definitely that they were allowing Americans to gamble.

"would a gambling site that didn't take a rake and just ran on ad revenue be allowed to have American customers?"

This definitely would not be allowed.

You mentioned the money laundering charges a couple of times. Those were ancillary charges. The primary charge was that they were operating an illegal online gambling business i.e. letting Americans gamble on the internet.

"I'm an American citizen. Would I definitely be allowed to use Betable?"

It is not illegal for an American company to offer real money online gambling to citizens of other countries where it is legal and regulated. So Zynga could get a UK gambling license and offer online gambling to UK citizens. It is a long, slow, difficult and expensive process - Betable has already done it and is allowing others to leverage their infrastructure (legal and technical).

Thanks! Would companies using Betable need to get licenses from the same countries that Betable already has licenses from (which so far means the UK) or would Betable's licenses mean that users of Betable would be covered as well.

Edit: Just discovered the 50/50 revenue share. That's going to turn away a lot of potential customers.

Also don't just jump into this shit unless, you know, you have legal counsel that specializes in gaming. It's still a huge risk. E.g. U.S. customers could circumvent and bet on your site. Guess what, you're on the hook for that!

That's incorrect cellis. Betable is handling all gambling, so any gambling-related legal risk (such as US customers gambling) is strictly our problem. This is why we have advanced geolocation, IP and identity checks.

Incorrect that U.S. developers of a game implementing Betable could be targets of legal action? Or incorrect that your software is circumventable?

Here's another question. Is Betable willing / able to provide legal counsel to U.S. developers who get squeezed by the FBI?

Betable handles all of the gambling, so game companies working with us do not need licenses. This is a key piece of our value proposition: licenses cost millions of dollars and take years to acquire.

As for the revenue share, given the cost of licenses (mentioned above), and the significant increase in revenue that could come from real-money gambling, we think this is appropriate. Remember that we employ and manage the legal, fraud and compliance aspects of gambling that make it so expensive and time consuming. Also, this revenue share only applies to gambling revenue. Your IAP and ad revenue remains your own.

Doesn't Americas Cardroom, among others, allow U.S. based players to play poker?

That is part of the Yatahay network. They are operating illegally, as PokerStars, FullTilt etc were for years.

Can anybody explain to me how much value I can give the user in a "gamified" app before it is considered gambling?

These are the three criteria, all of which must be met to be considered gambling:

-prize (they have to get paid money or something of value)

-consideration (they have to pay to participate)

-chance (so skill games are exempted i.e. chess)

If any of those is missing, it is not gambling.

Zynga Poker does not have a prize but they have consideration and chance, thus it is not gambling. There are legal subscription poker sites (i.e. clubwpt.com) that do not require people to pay, so no consideration - but they have chance and a prize. Not gambling.

We ran a leaderboard contest last month to get some more alpha testers and gave $500 to the top 10. It was free to participate (no consideration) and our game is (we think) a game of skill, not chance. So we were confident it wasn't gambling and thus was legal.

Consult your attorney before making any business decisions, but thats the gist of it.

> -chance (so skill games are exempted i.e. chess)

What about games that have an element of chance which can be greatly reduced with a high skill level?

The Dominant Factor Test is what most U.S. states use in determining what is and is not a game of skill. The Dominant Factor Test was defined in the 1973 Alaskan case Morrow v. State. The four qualifications as defined by the court in Morroware:

- Participants must have a distinct possibility of exercising skill and must have sufficient data upon which to calculate an informed judgment.

- Participants must have the opportunity to exercise the skill, and the general class of participants must possess the skill.

- Skill or the competitors efforts must sufficiently govern the results.

- The standard of skill must be known to the participants, and this standard must govern the results.

I think the idea is that Betable lets you do real gambling, but for games of chance. Not sure how it works with their platform to make it legal, but that's what the article claims their service is

Only players in places where gambling is legal can participate. So a US developer could make a game using Betable's API, but it won't be US players gambling.

That is correct dminor :)

Great answer. Thanks.

Have you guys been evaluated/certified by an independent testing lab?

We're audited multiple times a year. Our UK Gambling Commission license compels us to be audited against their codes of practice and additionally we have the correctness and security of our systems audited independently.

Can you put your audit results and/or certifications on your web site?

We would like to use you but having been in the cash gaming business in Europe and to an extent in the US, we won't touch a vendor unless we know they are some way to GLI-19 compliant.

Betable's license number from the UK Gambling Commission http://www.gamblingcommission.gov.uk is 000-023328-R-307313-003. We're audited (by GLI, incidentally) against their codes of practice.

Was surprised not to see this on the front page. This is pretty big news:

"Today, the company has received an undisclosed amount of money from 25 investors including Greylock Discovery Fund, FF Angel LLC, True Ventures, Dave Morin (ex-Facebook employee and current founder of Path) and Yuri Milner, the Russian investor who took big stakes in Facebook and Zynga. Those are big-name supporters who believe that Betable has a shot at raising the average revenue per user and average customer lifetime value for social games.

Among the other investors are CrunchFund (Michael Arrington’s fund), Marc Abramowitz (first investor in Palantir), Scott Belsky (founder of Behance), Auren Hoffman (founder of Rapleaf), Sean Knapp (founder of Ooyala), Howard Lindzon (founder of Stocktwits), Matt Ocko (angel investor in Zynga), Joshua Schacter (founder of delicious), and Arjun Sethi (former CEO of Lolapps)."

misspelled my name again. damnit.

D'oh! We're sorry :(

The angel investor in Zynga especially

If there are any Android game devs that are interested in being alpha integraters for a similar (but better?) gaming layer, please email: [email protected]