Client application download servers
Games may be deployed using a “client application”, that is, a piece of software that is downloaded by and installed on the end-user’s device to present a rich graphical and auditory interface that represents the game. Client applications are designed for a range of end-user devices including PCs, mobile phones or set-top boxes (interactive digital TV).
Operators may deploy specific equipment to make client applications available for download. To improve the speed with which the customer is able to download the application, such equipment may be placed in a number of geographical locations. Typically the equipment is also used to download patches and upgrades to the application and to verify the integrity of the installed application, that is, to check that the client software has not been tampered with before permitting access to gaming.
In the context of download servers, the Commission would not normally consider equipment that is used as previously described as being used in the provision of facilities for gambling, as long as that equipment is only being used as a means of distributing, updating and checking applications to be installed on the end-user’s device and is not involved once the gambling commences. To meet this distinction the same equipment must not be used to determine the results of virtual events, pass on the contents of gambles from the client application to the server, nor pass results from the server to the client.
For example, an offshore operator may choose to place a server in Great Britain that is used for downloading game applications but once the client application has been installed and the gaming has commenced the equipment is no longer involved. In that case the operator would not require a licence (unless providing facilities for gambling to customers in Great Britain).
If however, an operator located a download server in Great Britain that was also used during gaming to exchange information about the content of the customer’s gamble and the results of the virtual event, this equipment would, under our interpretation, be used in the facilities for gambling. We would consider such equipment as being used “to present, to persons who are participating or may participate in the gambling, a virtual game, virtual race or other virtual event or process by reference to which the gambling is conducted” (Section 36(4)(b)) (opens in a new tab).
Therefore, in this example, the operator would have to hold a remote casino licence by virtue of having remote gambling equipment in Britain notwithstanding where their customers happened to be located.
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Last updated: 14 April 2021
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