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The examples which we go on to use refer to ‘simulates physical devices’.Then we have the assertions about the game representing a device. This includes, but is not limited to the following:………”It is my office which has to decide if what occurred amounted to an operator breaching that rule....

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” So the games were not adaptive as we or any other regulator defines that term.Third and final comment:It appears we are never going to agree on this issue, but let me have one last attempt, on your terms and through your method, to explain why we are so far apart on our views. Well, where is that rule? Indeed, where is that card game that uses 12 of 13 cards in this way and with these bets? The claim that it breaks an imaginary US or European rule is a complete nonsense....

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If you take the trouble to visit our website and read our rules, you will see that the GRA is not the Gibraltar gambling regulator. If you take the trouble to visit our website and read our rules, you will see that the GRA is not the Gibraltar gambling regulator.” So the games were not adaptive as we or any other regulator defines that term....

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