GLI-11 and the Regulation of Persistent State Memory

GLI-11 is the technical standard governing electronic gaming machines, including video poker. Its provisions regarding persistent state memory directly impact how games like Ultimate X function—and what happens when players abandon valuable game states.

Understanding GLI-11

What Is GLI-11?

Gaming Laboratories International Standard 11:

Technical standards for gaming devices

Covers all aspects of machine operation

Adopted by most gaming jurisdictions

Updated periodically

Scope of Coverage

GLI-11 addresses:

AreaRequirementsRNGRandomness standardsGame logicFairness requirementsAccountingMeter accuracySecurityAccess controlsCommunicationProtocol standardsPersistent stateMemory handling

Persistent State Provisions

Definition in GLI-11

Persistent state refers to:

Game features that carry forward between plays

Accumulated bonuses or multipliers

Player-funded future equity

Non-resettable game conditions

Key Requirements

GLI-11 requires for persistent state features:

Preservation: State must survive power loss

Disclosure: Players must be informed of state

Equity protection: Cannot arbitrarily delete value

Auditability: State changes must be logged

The Equity Principle

Central to GLI-11 philosophy:

"Any feature funded by player wagers represents player equity and must be protected accordingly."

This means:

Multipliers earned are player property

Casinos cannot delete without cause

Regulatory violation for arbitrary removal

Player could claim theft

Application to Video Poker

Ultimate X Implications

For games like Ultimate X:

FeatureGLI-11 RequirementMultipliers earnedMust be preservedPower failureState recoveredPlayer departureState remainsMachine serviceState protected

What Happens When Players Leave

GLI-11 creates the vulturing opportunity:

Player earns multipliers (2× bet investment)

Player leaves machine

Multipliers remain (GLI-11 mandate)

Next player inherits multipliers

Casino cannot prevent this

Timeout Provisions

GLI-11 does allow for timeouts, but requires:

Clear disclosure on machine

Reasonable time period

Consistent application

Player notification

Most machines don't implement timeouts because:

Regulatory approval complexity

Player perception concerns

Competitive disadvantage

Jurisdictional Variations

Nevada Adoption

Nevada uses GLI-11 as baseline with modifications:

Regulation 14 for video poker specifics

Additional fair-deck requirements

State-specific interpretation

Other US Jurisdictions

StateGLI-11 StatusNew JerseyAdopted with modificationsPennsylvaniaAdopted with modificationsTribal (varies)Often GLI-11 basedMississippiGLI-11 basis

International

Global GLI-11 influence:

Canada: Adopted in most provinces

Caribbean: Common standard

Australia: State-based but GLI-influenced

Europe: MGA, UKGC incorporate GLI concepts

Testing Requirements

Persistent State Testing

Gaming labs verify:

State Preservation:

Power cycle during bonus

Communication interruption

Various failure modes

Recovery verification

State Accuracy:

Correct values preserved

No corruption over time

Proper restoration

Disclosure Verification:

Player can see state

Information is accurate

Accessible without play

The Manufacturer Response

Game Design Within GLI-11

Manufacturers design games knowing:

Persistent state creates vulturing opportunity

Regulations limit countermeasures

Balance required between features and liability

Evolution of Game Design

Response to vulturing concerns:

Earlier designs:

High multiplier values

Extended persistence

Clear visibility

Newer designs:

Lower multiplier values

UI obscuration (permitted)

Faster decay options

Alternative bonus structures

Regulatory Evolution

Current Debates

Gaming regulators are discussing:

Should persistent state rules be modified?

How to balance innovation and protection?

Are vulturing countermeasures appropriate?

What disclosure is sufficient?

Potential Future Changes

Possible GLI-11 revisions:

ChangeLikelihoodImpactMandatory timeoutMediumReduce vulturingEnhanced disclosureHighPlayer awarenessDecay provisionsMediumDesign flexibilityEquity definition changesLowFundamental shift

Practical Implications

For Players

GLI-11 provides:

Protection: Your earned features are protected

Transparency: Right to see game state

Fair play: Cannot be arbitrarily reset

Recourse: Regulatory complaint option

For Advantage Players

GLI-11 enables:

Vulturing viability: Persistent state protected

Legal certainty: Not gambling fraud

Regulatory backing: Standards support the play

Industry stability: Clear rules for all

For Casinos

GLI-11 requires:

Compliance: Cannot delete player equity

Creative solutions: UI changes, not state deletion

Game selection: Choose games with less exposure

Acceptance: Some vulturing is unavoidable

Case Studies

Dispute Resolution Examples

Scenario: Player claims multipliers were deleted

Resolution:

Machine logs reviewed

If deletion occurred: Regulatory violation

Player compensation required

Casino fined potentially

Scenario: Casino implements 5-minute timeout

Requirements:

Must be disclosed on machine

Must be consistently applied

Must be approved by regulators

Must allow reasonable play time

The Broader Context

Why Persistent State Exists

GLI-11 reflects regulatory philosophy:

Player protection: Central mission

Fair play: Fundamental requirement

Trust: Industry depends on it

Innovation balance: Allow new features while protecting players

The Unintended Consequence

Persistent state protection created vulturing:

Regulations meant to protect players

Created advantage play opportunity

Now debated as unintended outcome

Illustrates regulatory complexity

GLI-11's persistent state provisions exemplify the careful balance regulators must maintain between protecting player interests, enabling innovation, and managing the unintended consequences of well-intentioned rules.