TechTalk#10: Moving Goalposts - The Double Standard Threatening California Cardrooms

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Hi Everyone,

Last month, we covered California's proposed player-dealer rotation rules and the major impact they'll have on cardrooms statewide. But there's a deeper issue at play here that every operator needs to understand—one that could reshape the entire California gaming landscape.

This week, I'm sharing insights from one of the true pioneers in California gaming innovation: Steven Wright, the inventor of Pure 21.5. His recent open letter to the Department of Justice highlights a troubling pattern of regulatory inconsistency that affects every cardroom in the state.

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The Gaming Innovation Paradox

For decades, California cardrooms have operated within strict regulations that prohibit "house-banked" games and certain games like roulette and craps. To stay compliant and competitive, cardrooms have invested heavily in developing innovative game variations that satisfy legal requirements while offering engaging experiences for players.

But here's where the paradox emerges:

• Cardroom game innovations are scrutinized under increasingly narrow interpretations of the law

• Meanwhile, similar innovations from tribal casinos face virtually no regulatory pushback

This inconsistency isn't just frustrating—it threatens the very foundation of the cardroom business model in California.

Few understand this challenge better than Steven Wright, founder of United Gaming Solutions and creator of some of California's most successful cardroom games. As a small business owner who has dedicated over two decades to developing games that meticulously comply with DOJ regulations, Wright has become a voice for innovation and fairness in the industry.

Pure 21.5: A Case Study in Moving Goalposts

Wright's signature creation, Pure 21.5, exemplifies the type of thoughtful innovation that has kept California cardrooms competitive. Developed specifically to comply with DOJ guidelines, the game:

• Cannot have 21 as the best possible hand

• Cannot have exceeding 21 result in an automatic loss

• Must offer player-dealer position to all players

What makes Pure 21.5 truly innovative is its unique deck structure. Wright replaced traditional face cards with "Bonus" cards that have different values depending on the cards they're paired with. This isn't just a cosmetic change—it fundamentally alters the mathematics of the game, creating an experience distinct from traditional blackjack. The innovation was significant enough to earn trademark protection.

This game has been approved and played in California cardrooms for nearly two decades. Yet now, the DOJ is reconsidering whether this game—after 20 years of operation—suddenly violates regulations. The goalposts are moving.

"It takes time (2 years minimum) and a significant amount of investment capital to develop a game," Wright notes in his letter to the DOJ. "There's zero guarantee that this 'new' game will be successful and have a return on investment."

The Tribal Casino Double Standard

In his recent letter to the DOJ, Wright highlights a troubling inconsistency: while cardrooms face intense scrutiny, tribal casinos appear to be offering what are essentially prohibited games with minimal modifications.

As Wright points out, tribal "roulette" games feature:

• The same wheel number layouts, colors, and betting options as Vegas roulette

• Nearly identical odds and payouts

• The same felt layouts and betting procedures

• The modified wheel has replaced the need for a ball .

"Why the double standard?" Wright asks. "I am not advocating that these games be outlawed—far from it. I believe the tribes should be able to offer their variations of roulette and craps, just as I should be allowed to offer my 21 variants. The problem is that the DOJ applies one set of rules to the tribes and another to cardrooms."

This observation is particularly relevant given that California voters explicitly rejected Proposition 26 in 2022, which would have allowed tribal casinos to offer roulette and dice games. The ballot's No vote statement clearly indicated that "Tribal casinos would continue to be unable to offer roulette and games played with dice. No changes would be made to the way state gambling laws are enforced."

The Real Stakes for Cardrooms

The implications for cardrooms are severe:

• Game development costs can exceed $100,000 and take years

• Approved games represent significant investments in training, equipment, and marketing

• Sudden rule reinterpretations render these investments worthless overnight

• Unlike mega tribal casinos, most cardrooms can't absorb these losses

Even more concerning is what comes next. If Pure 21.5 can be reinterpreted after 20 years, what other games might suddenly be deemed non-compliant? How can cardrooms justify investing in innovation when the rules seem to change arbitrarily?

The Impact Beyond Cardrooms

This isn't just about cardroom profits. The consequences of these inconsistent regulations affect:

• Local economies: Many municipalities depend on cardroom tax revenue for up to 70% of their general fund

• Employment: Thousands of jobs are at stake in communities that need them most

• Responsible gaming options: Cardrooms provide regulated alternatives that keep gaming dollars local

• Competitive balance: Fair competition benefits players and raises standards industry-wide

The Technology Angle

As cardrooms invest in modernization through platforms like CardOpz, regulatory uncertainty complicates every aspect of technology development. How can we build efficient systems for games that might be arbitrarily banned tomorrow?

Technology vendors serving cardrooms face the same uncertainties:

• Development roadmaps become impossible to plan

• Integration with existing systems is complicated by changing game requirements

• Training and documentation must constantly adapt to shifting regulations

• Return on investment calculations become exercises in guesswork

Moving Forward: A Call for Consistency

Wright's call for consistency resonates throughout the cardroom industry. The solution isn't preferential treatment—it's fair application of rules across all gaming venues. California's gaming industry needs:

• Clear, objective criteria for game compliance that don't change based on who's offering the game

• Regulatory decisions based on mathematics and game mechanics, not political pressure

• Reasonable grandfather provisions for games with long histories of approved operation

• Equal enforcement of standards across all gaming venues

"I am asking for a straightforward, good-faith discussion," Wright concludes in his letter. "Cardrooms are a longstanding part of California's gaming landscape. Our innovations, including Pure 21.5, were developed under clear DOJ guidelines and have been played in the market for decades."

The good news? The California cardroom industry is unified in advocating for fair treatment. Innovators like Wright, alongside organizations like the California Gaming Association, are actively working with regulators to address these inconsistencies.

As we modernize cardroom operations through technology, we also need to modernize the regulatory approach. The future of California gaming should be built on innovation, fair competition, and consistent rules—not moving goalposts.

Want to stay updated on California cardroom regulations? Subscribe to Cardroom Tech Talk for ongoing coverage of these critical issues.

Shoutout to this month's sponsor: CardOpz – The All-In-One Platform for Poker & Table Game Operations.

That's the talk. See you next Monday.

— Caleb

💬 Has your cardroom been affected by regulatory inconsistency? Share your experience in the comments.

Learn more about the CardOpz platform at cardopz.com

Players, operators, or industry folks – know a cardroom that could use better technology to navigate these challenging times? Refer them and earn. Details on our website.

Sources

• Steven Wright, "Ongoing Challenges to Pure 21.5 and the Future of Cardroom Gaming" (Open Letter to DOJ, March 2025)

• California Penal Code § 330

• California Department of Justice, "Initial Statement of Reasons" (2025)

• California Gaming Association, "Impact Assessment of Proposed Regulations" (2025)

• 2022 California General Election Results, Proposition 26

• Internal CardOpz Industry Analysis (2024-2025)