April 10, 2018 by

Both Players and Casino Operators to Benefit from New Regulations

Pennsylvania’s slow but steady movement into online gaming took a slight turn when the Pennsylvania Gaming Control Board decided to allow unlimited “skins” in all licensed casinos and online casino games. This is not exactly a major change but does have some significance for casino operators and game providers.

The key here is how the term skins is to be understood. There are three understandings of the term. The first is decidedly not applicable here: that understanding is “to cheat”.

The other two are actually mirror images of each other. The one allows the appearance of a symbol, icon, or character to change at the choice of the player. The second allows casinos to have a different appearance than another casino they also operate even though both casinos offer the same games.

Here is the text of the Gaming Board’s statement to the press:

“What the Pennsylvania Gaming Control Board did at its public meeting of April 4, 2018 was to approve temporary regulations that enable a very open and competitive market for internet gaming while at the same time assuring transparency and accountability for the consumers. Under these temporary regulations there is no limitation on the number of skins that a slot machine licensee may employ to deliver games, but every “skin” that a casino offers must be branded in a manner that makes it clear that it is offered on behalf of the slot machine licensee consistent with language of the act.”

This is what the statement means:

  • Even though there are as yet no online casinos within Pennsylvania’s jurisdiction, the Gaming Board is working diligently as a kind of super-legislature for gaming purposes.
  • The gaming Board recognizes that the previous restriction of five skins was illogical and unrealistic.
  • The Gaming Board is still not convinced that the new rules are logical and realistic; that’s why they are calling them “temporary regulations.
  • The Gaming Board sees an open and competitive market; as possibly in contradiction with the desire for transparency and accountability to consumers.
  • It is unclear exactly what the final clause, regarding branding of skins actually means.

The Purpose of Skins—Part One

First we’ll discuss the purpose of skins as they relate to a casino as a whole entity.

There are thousands of online casinos at this writing. It is expensive to set up an online casino and to run it with a broad choice of online casino games. There are “only” about 150 game providers. That means that there is a lot of overlap of games offered at online casinos. Every casino wants to look somewhat different than competing casinos even if the two casinos offer the same games.

The way they achieve a different appearance is by putting a different “skin” or façade on their casino. This is actually very obvious; a casino run by company A should look different than a casino run by company B. It’s the same as when a car manufactures has functionally the same car but wants to market them under different names. Under the hood, the cars are the same but consumers see them as different cars.

The same obtains in hotel and motel chains which may operate a few sub-chains under the same management but carrying different names and usually different prices per night.

What happens, then, when company A runs perhaps ten casinos? Then the company wants to have a different “skin” for each of its casinos so that players may play at several of the company’s casinos not being fully aware that essentially they are playing all the while at the same casino.

The new regulations simply allow casino conglomerates to cover their casinos with a different skin for each casino.

The Purpose of Skins—Part Two

Here we have an interactive offering to gamers to change a slot game slightly to make it both more personal and also more attractive and more in line with the kind of entertainment value the gamer is looking for. Casinos strive to have many varied slots under a single category. That is all well and good. But sometimes players would like a symbol or character to look different than the default look from the provider. To this end, providers may offer several alternative looks for a symbol or character.

This allows players to play a slot several times, changing its look each time, in order to keep the game as fresh as possible.

The Language of the Decision

From the decision and statement by the Gaming Board, we can presume that the Board was referring to both kinds of skins. It begs the question why the Board may have cared at all about an offer to change the appearance of a symbol when the decision to change the appearance is in the player’s hands.

The first type of skin may have made some sense; the Board was possibly trying to keep the number of online casinos run by a single management team to a maximum of five. The new regulations allow mangers to run an unlimited number of casinos within Pennsylvania’s jurisdiction.

The Board seems to have come to the realization that it doesn’t really matter how many casinos any one operator runs. Consumers are still the best deciders of where they will play online casino games. If the Board and the State Legislature didn’t trust the people of Pennsylvania to make their own decisions based upon their own desires, they might not have legalized online gaming at all.


We can expect more rules and regulation changes to come from the Pennsylvania Gaming Control Board going forward. The Board seems to be trying to be evenhanded between the needs of the casinos and the needs of players. As the Board gets deeper and deeper into the online gaming business and as it learns more, we can anticipate that more new decisions will emanate from it.

Jack Marsh Picture
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Jack Marsh enjoys examining the world around him from many different points of view: the mathematical, the psychological, the political, and the philosophical.

He will write from a mathematical perspective on why the cards fall the way they do, from a psychological perspective on why gamblers gamble the way they do, from a political perspective on why forms of entertainment that are encouraged in one place are prohibited in another, and from a philosophical perspective on the nature of happiness ... [Read Jack Marsh full bio]