Commercial-In-Confidence. Report to Football1x2.com. Football Frenzy

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1 Gambling Commission approved Test House Accredited to ISO/IEC 17025:2005 NMi Metrology & Gaming Ltd Intec Ffordd y Parc Parc Menai Bangor Gwynedd LL57 4FG United Kingdom Tel: +44 (0) Report to Football1x2.com Football Frenzy Report Reference ID Jurisdiction Issue Date NMI/049/003/UK/UKGC/01 United Kingdom 28/04/2011 Executive Summary Football Frenzy is a football league simulation game comprising 20 teams playing out a 38 round season over the course of 1 hour. The game offers the opportunity to bet at fixed odds on each match in the league individually, multiple matches in the same round, or the ultimate winner of the league before any round. The game uses random numbers drawn from the previously tested Football 1x2 Random Number Generator. The game has been assessed in relation to sections 7B & 7C of the following document: Remote gambling and software technical standards, August 2009 The scope of testing has been advised by the following document: Testing strategy for compliance with remote gambling and software technical standards, August 2009 The game offers a large number of betting opportunities and some issues with the display of returns on all bet types are identified: The game as tested publishes a minimum RTP of 80.00% for individual bets and 82% for bets on the top teams to win the league. It qualifies this with the statement that the chances of some teams winning the league approaches zero. Testing has confirmed these figures to be an accurate representation of the expected returns for individual bets which have RTPs of between 80% and 100%. The published figure is accurate for the 4 teams with the best chance of winning the league. Average returns for bets on the other 16 teams range from 81% to zero. Returns for all teams are listed in the Mathematical Treatise section of this report. Bets on multiple games offer returns that are multiples of those offered for the individual games. The game provides all information necessary to calculate returns to the player and no other compliance issues are noted in respect to sections 7B & 7C of the standard. Authorised by: Dr. Rich Edwards Director, NMi Metrology and Gaming Ltd. Disclaimer This test report and accompanying documents are provided as is with no warranties whatsoever. All software and hardware includes defects and nothing in this document is intended to represent or warrant that testing was complete and without error. The gaming system manufacturer remains solely responsible for the design, sale and functionality of their product(s), including any liability arising from legal infringement or product warranty. Page 1 of 15

2 Contents Introduction... 3 Caveats...3 Quality Control...3 Submissions...4 Software...4 Game Description...5 Implementation Details... 6 Testing Overview... 7 Customer Contacts...7 Lab Staff...7 Dates... 7 Applicable Standards... 7 Test Methods...7 Mathematical Treatise...8 Code Review...10 Potential Issues...13 Appendix A: Requirements Met Appendix B: Requirements Not Applicable Page 2 of 15

3 Introduction The NMi group is approved to provide testing services relating to online gaming by the UK Gambling Commission, the Alderney Gambling Control Commission, the Isle of Man Gambling Supervision Commission, the Malta Lotteries and Gaming Authority, AAMS Italia, and the Kahnawake Gaming Commission. For a full list of NMi s accreditations (including details of all land-based and i-gaming regulatory approvals), please see Caveats The results presented in this document are a summary of the testing work undertaken, and this report is subject to a number of caveats, including: All items provided for inspection and/or testing are declared by the customer to be configured identically to those in commercial use. Game software and source code provided for empirical testing and/or code review is declared by the customer to behave identically to the software and code in commercial use. Decisions taken by the supplied software in automatic test modes / simulators are reasonable emulations of those that would be expected to be taken by real players. All efforts have been taken to ensure that the testing undertaken has been as exhaustive as necessary to demonstrate compliance or non-compliance. NMi UK takes on trust that all test items (including all hardware and software), all documentation and all communications are accurate, truthful, and that there is no intention to deceive or subvert the assessment of compliance. Quality Control The monitoring of this testing project was the responsibility of NMi's Quality Manager and every effort has been made to ensure the accuracy of the information contained in this report. If errors or omissions are discovered, please contact us with details as soon as possible. NMi reserves the right to revise and reissue this Test Report if additional information is presented or discovered. Page 3 of 15

4 Submissions Software The following electronic submissions were received: Version File name MD5 checksum Date F1X2_DATAMySQL_ODDS 57c4bd f6dce18ffdfb5b2c6e7 19 Apr 2011 MultipleCalculator.java 00ccbb223e5174d265f311aeed6b73ce 19 Apr 2011 PlayMatches.java d225bcdbb987c64f039f7966c7b750d9 19 Apr 2011 SettleBets.java a208f178069bcabdbe33583a9140d Apr 2011 processbet_real.jsp b4e35bc349b75a20c2201f9e4dcbbd70 19 Apr 2011 All results and observations in this report relate to version Page 4 of 15

5 Game Description Football Frenzy is a virtual football betting game. Each league consists of 20 teams and the season lasts an imaginary 38 weeks. Every 90 seconds all fixtures for an imaginary week are played, meaning that a league is played in just under an hour of real time. Each team has a strength weighting, which is used to determine the outcome of individual fixtures; the number of goals scored by each team is based on the strength weighting. It is possible to bet on the outcome of individual games, on the outcome of multiple games, and on the winner of the league. An each-way bet may be placed during the first three weeks of the league. The odds offered for individual fixtures are fixed. The odds offered for the winner of the league are updated each imaginary week from a set of fixed figures which take into acount the points difference and current position. The game uses random numbers drawn from the previously tested Football 1x2 Random Number Generator. Page 5 of 15

6 Implementation Details URL of test item. URL of game launch page. URL of published returns. 1&lang=en Page 6 of 15

7 Testing Overview Customer Contacts The customer liaisons were Luke Jobling and James Randall Doughty. Lab Staff The assessors were Tamsin Slinn, Ryan Brooks, Rich Edwards and Andrew Rosewarne. Dates Testing has been undertaken during the following periods: 20/04/ /04/2011 Applicable Standards The test items have been assessed for conformance with the following technical standards, under the terms of NMi UK's ISO/IEC 17025:2005 accreditation: Document Remote Gambling and Software Technical Standards (August 2009) Abbreviation Used RTS Test Methods The test item was assessed by code review, mathematical analysis and manual play. Page 7 of 15

8 Mathematical Treatise The following analyses have been carried out on version of the mathematical treatise: Individual Match RTP The RTP was determined for each combination of teams, playing at home and away. Based on the supplied team strengths and odds offered, a minimum RTP of 80% was determined for a bet on Team 2 (Home) playing against Team 19 (Away). Average Match RTP The average RTP for all single match bets was determined to be 93.89% Multiple Bets League Results Team 1 Team 2 Team 3 Team 4 Team 5 Team 6 Team 7 Team 8 Team 9 Team 10 Team 11 Bets on multiple games offer returns that are multiples of those offered for the individual games. A bet on 2 options each returning 80% will return 64%. The RTP for bets placed during week 1, on individual teams winning the league was determined by simulation. Over 100,000,000 simulated plays we did not observe any league wins for teams 18,19 and 20, meaning that the RTP for bets on these teams approaches zero. The RTP for teams 1-17 was determined as follows: The RTP for bets placed during week 1 on Team 1 winning the league was determined to be 82.53% with a 95% confidence interval ranging from 82.41% to 82.65% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 2 winning the league was determined to be 85.96% with a 95% confidence interval ranging from 85.88% to 86.04% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 3 winning the league was determined to be 85.12% with a 95% confidence interval ranging from 85.05% to 85.2% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 4 winning the league was determined to be 92.01% with a 95% confidence interval ranging from 91.57% to 92.45% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 5 winning the league was determined to be 72.14% with a 95% confidence interval ranging from 71.95% to 72.33% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 6 winning the league was determined to be 58.87% with a 95% confidence interval ranging from 58.61% to 59.13% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 7 winning the league was determined to be 81.24% with a 95% confidence interval ranging from 80.88% to 81.6% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 8 winning the league was determined to be 81.15% with a 95% confidence interval ranging from 80.53% to 81.77% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 9 winning the league was determined to be 59.53% with a 95% confidence interval ranging from 58.92% to 60.14% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 10 winning the league was determined to be 53.01% with a 95% confidence interval ranging from 52.2% to 53.83% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 11 winning the league was determined to be 30.5% with a 95% confidence interval ranging from 29.91% to 31.09% for batches of 10,000,000 plays Page 8 of 15

9 Team 12 Team 13 Team 14 Team 15 Team 16 Team 17 The RTP for bets placed during week 1 on Team 12 winning the league was determined to be 18.25% with a 95% confidence interval ranging from 17.54% to 18.95% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 13 winning the league was determined to be 9.31% with a 95% confidence interval ranging from 8.7% to 9.93% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 14 winning the league was determined to be 4.29% with a 95% confidence interval ranging from 3.91% to 4.67% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 15 winning the league was determined to be 1.53% with a 95% confidence interval ranging from 0.9% to 2.16% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 16 winning the league was determined to be 0.44% with a 95% confidence interval ranging from 0.17% to 0.71% for batches of 10,000,000 plays The RTP for bets placed during week 1 on Team 17 winning the league was determined to be 0.19% with a 95% confidence interval ranging from 0% to 0.47% for batches of 10,000,000 plays Page 9 of 15

10 Code Review Football Frenzy is a client/server game, with the main game logic written in Java and located on the server. The client interface is Flash-based, with JSP (Java Server Page) used to transmit user bets to the server. The following files were included in the scope of this code review: MD5sum 57c4bd f6dce18ffdfb5b2c6e7 00ccbb223e5174d265f311aeed6b73ce d225bcdbb987c64f039f7966c7b750d9 b4e35bc349b75a20c2201f9e4dcbbd70 a208f178069bcabdbe33583a9140d159 File F1X2_DATAMySQL_ODDS MultipleCalculator.java PlayMatches.java processbet_real.jsp SettleBets.java processbet_real.jsp This jsp file is responsible for sending bets to the server. It retrieves account and bet details from the Request. It carries out various validations on the bet details: maximum Stake not exceeded for user book is still open for event. odds in request match odds in database check for duplicates (i.e betting on both outcomes of the same match. If bets are valid, they are recorded in the database. PlayMatches.java This class is responsible for playing out the games of Football, and updating the database with the results. It contains the following key methods: calculatescores This is the key method which determines the outcome of the matches and the league. For each fixture the method: gets Home and Away Team from Participants table. gets the Strength array for each team from Team Strength table gets Home and Away Score for each team from the strength array, using the previously tested RNG. updates the Particpants and Books table with results and calls updateleague. After all games played, the method calls newleagueprices. updateleague This method is called after each game is played. It updates the leagueresults table with the score, points and goal difference for the home and away team. newleagueprices This method calculates the odds for each team to win the league following the latest match results. For each team the method: gets the difference between team points and current leader points (or for current leader, difference between second place points). The difference is capped at +/-15. gets the odds from the leaguepricesn table for the position and pointsdifference (where N is the team), for the appropriate week. updates the Participants table with the new odds. updates Books table with the total percent which has been offered. settlebets This method instantiates a new SettleBets object, and calls methods to settle the single, multiple and league bets. Page 10 of 15

11 archivepreviousleague This method copies the league results to an archive table (leagueresultsold), in preparation for the start of a new league. SettleBets.java This class is responsible for settling bets following a 'week' of fixtures. SettleBetsInit This method prepares the class to settle bets for a particular fixture by setting the bookid; settlefixedoddswinonly This method resets the class to settle bets for a particular fixture and calls the method settlebets settlemultiples For each multiple bet, this method retrieves the details of all individual bets which make up the multiple, to check that the number of bets is correct. It then uses the MultipleCalculator class to calculate the maximum liability, and calls the payoutmultiple method. Finally the method calls the following three functions: addmissettledbet, getnonsettledwagers, nonsettledmultiples, and then sendtovc settleleague This method settles bets on the outcome of the league. It updates the Partipants table with the finish position of each team, sets the bookid to the league bookid then calls settlebets settlebets This method settles individual bets for the current bookid (match or league). For succcessful single fixture bets it calculates the return as odds multiplied by stake. For league bets on the winner only, the return is calculated as the odds multiplied by the stake. For each-way league bets where the participant is within the each-way limit, but not the winner, the return is calculated as: (stake * eachwayodds - 1) / 5 + stake For each-way bets where the participant is the winner, the return is as above plus the win odds multiplied by the stake. The method then caps winnings if they are greater than the maximum payout (Game parameter FOOTBALL1x2_1_MAXPAYOUT). The method calls the settlebet method on the GameBetRecord class and logs the details of the bet. payoutmultiple This method caps the winnings if they are greater than the maximum payout. The method calls the settlebet method on the GameBetRecord class and logs the details of the bet. sendtovc This method updates the database with details of settled bets. getnonsettledwager This method is called by the settlemultiples method, and appears to retrieve bets which have not been settled as yet for the previous 200 fixtures. It then processes them in a similar way to the original settlebets method. nonsettledmultiples This method is called by the settlemultiples method. It retrieves multiple bets from the last 200 fixtures which have not been settled. It then processes them in a similar wayto the original settlemultiples method. addmissettledbet This method retrieves all single and multiple settled bets (where issettled = 1) from the last 200 fixtures. It updates the issettled field in the Wager and Multiple table depending on the outcome of the bet: -1 for losing bets, -100 for bets without a vcintid. Page 11 of 15

12 MultipleCalculator.java This class extends (Multiple.java) which was not included in the submission and is responsible for calculatations relating to bets on more than one outcome. Page 12 of 15

13 Potential Issues Reference: Requirement: RTS / Gaming (including bingo), lotteries, and betting on virtual events. (7B) As far as is reasonably possible, games and events must be implemented fairly and in accordance with the rules and prevailing payouts, where applicable, as they are described to the customer. Assessment: No incorrect or misleading rules or descriptions were present on the test site during inspection. The published RTPs were determined to be accurate for individual bets but RTPs published for league bets are only applicable to the top 4 teams. The game provides all information necessary to calculate returns to the player. Page 13 of 15

14 Appendix A: Requirements Met Reference: Requirement: RTS / Gaming (including bingo), lotteries, and betting on virtual events. (7C) Game designs or features that may reasonably be expected to mislead the customer about the likelihood of particular results occurring are not permitted, including substituting losing events with near-miss losing events and simulations of real devices that do not simulate the real probabilities of the device. Assessment: No evidence of misleading features or messaging was observed in the code review or during manual play. Page 14 of 15

15 Appendix B: Requirements Not Applicable Reference: Requirement: RTS / Gaming (including bingo), lotteries, and betting on virtual events. (7A:1) Random number generation and game results must be acceptably random. Acceptably random here means that it is possible to demonstrate to a high degree of confidence that the output of the RNG, game, lottery and virtual event outcomes are random, through, for example, statistical analysis using generally accepted tests and methods of analysis. Adaptive behaviour (i.e. a compensated game) is not permitted. Assessment: The RNG has been reviewed separately in report NMI/049/001/UK/UKGC/01 Reference: Requirement: RTS / Gaming (including bingo), lotteries, and betting on virtual events. (7A:2) Where lotteries use the outcome of other events external to the lottery, to determine the result of the lottery (for example, using numbers from the National Lottery) the outcome must be unpredictable and externally verifiable. Assessment: External numbers (other than the externally tested RNG) are not used to determine results. END OF REPORT Page 15 of 15