Evony in big trouble

Roulette wheel

In the game of Evony you can buy in game cents for real money, $10 real money = 100 Evony cents. You can use cents for many things including buying Amulets. An Amulet costs 5 Evony cents or 50 cents real money. It allows you one spin of a roulette wheel on which you are gambling to win in game items. Here are the potential rewards.

In America they have the Unlawful Internet Gambling Enforcement Act of 2006, which enacts Federal law to outlaw financial transactions involving the providers of online gambling service providers.

So it seems to me that it is very possible that the purchase of Evony cents in the USA is illegal under Federal law.

It is also worth noting that Evony has probably exposed millions of children to online gambling. That the game has no age rating. That the advertising for the game carries no age rating. And that the advertising for the game contains no warning about the gambling content.

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30 comments ↓

#1 IRGRL on 09.14.09 at 11:56 am

brilliant, I feel a bit more vindicated now.

Great research Bruce

always supportive

#2 LOL@YOU on 09.14.09 at 6:43 pm

Sorry man but you have no clue what your talking about and anyone who takes advice from this old guy is an even bigger ***. Do you even play mmo’s ? I could name about 10 off the top of my head who all promote buying virtual goods then have a system set it up where u can spend a little to have a chance for alot more. Like a lottery,random box, and roulette wheel etc. So good luck with your war against gaming lol

#3 Kempion on 09.14.09 at 10:38 pm

We can worry about this legislation in December WHEN IT GOES INTO EFFEC, Bruce. Of course, there is a LOT opposition to this legislation as well.

#4 Rodri on 09.14.09 at 10:52 pm

The conversion of cash into game cents means that you are no longer gambling with real money. There is also no way of converting those game cents back into cash.
There are other gaming companies that have similar wheel spins or lucky dips.
This company is not doing anything much different from other online games.

#5 Althulus on 09.14.09 at 11:06 pm

LOL@YOU
that is all true.
BUT Evony presents its gambling mechanism in a roulette wheel. Which feels much more like gambling to me.

And I don’t recall any reputable F2P game having a gambling mechanism that cost as much as 50cents each!

Good luck Bruce!

#6 NBForrest on 09.15.09 at 3:15 am

I have done alot of research on this topic and in my humble opinion Evony is indeed in violation of internet gambling laws and based on the wording of califorinia laws they are definately in violation of california gambling laws.
A chat site that I used to frequent had a slot that required real money to use in order to win “in game” items. The site in question was used by both adults and children.After informing the site owners of the california gambling laws they consulted their legal eagles and removed the “pay to play” aspect of the slot machine.

Based on that particular situation I maintain that evony is indeed in violation of internet gambling laws.

#7 Kempion on 09.15.09 at 8:33 am

Gambling involves risk. Where there is no risk, there cannot be gambling. Stop trying to play Perry Mason simply because you suck at a PVP war game.

#8 IRGRL on 09.15.09 at 3:00 pm

Bruce, the “people” trolling your site now were on thirteen1 forums, one has been banned, Kempion, he at first was going to throw Evony under the bus in a DM on twitter to me, but when I told him he was a tool he jumped on the Evony bandwagon. The rest have been bombarding our forums as well.

Funny, they don’t make Evony look any better when your looking at it as a whole with community standards, which is what I wrote about.

I would let them post, but disregard any comment to them, they dig their own hole as representatives of the community within.

always supportive,
Steph
~IRGRL~

#9 Wildreamz on 09.15.09 at 5:07 pm

It is true that most MMO’s have a “lucky dip” system.
It is also true that it treads a fine line between gaming and gambling.

“It is also worth noting that Evony has probably exposed millions of children to online gambling.”

But you seem to exaggerate things in favour of your own opinion. As always.

#10 AC on 09.15.09 at 5:58 pm

To assist any reader here who may desire to see how this gambling wheel works, here is a basic tutorial from an independent player on YouTube named, suitably, EvonyTutorials. Like all Evony players he refers to it a “roulette wheel.”

In order to encourage people to use this roulette wheel, Evony offers every account holder a free spin on it once a day. In order to spin the roulette wheel one needs to expend a game amulet, this is a virtual item, like a coin. Therefore one purchases virtual amulets with real money in order to gamble on the roulette wheel.

However, most importantly because one can buy items in Evony with real money or elect to try to win these items on the roulette wheel, one needs to compare the cost of buying items compared to gambling for them. Many item are comparatively expensive for what they are, therefore Evony does encourage their users, some of whom are minors (children), to gamble in the hope of obtaining their desired virtual item. They profit in the context that they do not have to spend as much real money for items, conversely they can lose more money in the gambling attempt. I for one have specifically purchased amulets in Evony in the hope of avoiding paying the full cost for an item. In this respect I do view the Evony roulette wheel as gambling.

It should also be noted that the Evony game alliances encourage their players to use the roulette wheel and to share their results with others in the game. Many cheer when good items are won, thereby encouraging people to do this more often. The best item on the roulette wheel that I have witnessed is 300 coins because this equates to real money.

While some other online games do employ virtual gambling, I have not as yet come across any game that encourages it like Evony, but this could be a good future article for respectable games consultants like Mr Everiss to look into, because I am sure many browser game companies are becoming concerned with their own concerns given the publicity on this topic. There are a number of large browser based games in existence. Some German concerns claim to have 70 million customers. So I think it could make for an illuminating insight.

The Evony roulette wheel in action http://www.youtube.com/user/EvonyTutorials#play/uploads/32/mOec2T5itCI

AC

#11 David W on 09.15.09 at 8:40 pm

While you are entitled to your opinion, I feel that your comments about Evony and related gambling statements are unfounded and unreasonable. Obviously I am a supporter of the Evony game and I hope you are open to have my comments dispalyed on your blog as my contribution to free speech.

I believe the usage of online items called amulets and gambling there-of via “the wheel” are not applicable to the US “Unlawful Internet Gambling Enforcement Act of 2006″ for several reasons.

1) From your own comments, this Federal law “outlaw financial transactions involving the providers of online gambling service providers.” Seeing as Evony is most likely classified as an “online real time MMORPG game” and NOT an “online gambling service provider” such as an online poker site, I would guess this law does not apply here.

2) The online items known as amulets are virtual items that are rewarded to everyone online player once per 24 hours. True, each player has the OPTION to purchase more. However there are MANY games that currently enable players to purchase additional items for their respective games. Despite that fact, your usage of the term gambling via “the wheel” assumes that those online virtual items are the same as real money – which is obviously not the case. Therefore I am unsure from this aspect that the law applies here.

3) IF the US Federal government does decide to challenge this fact of gambling with online virtual items, I can think of much larger games that have HUGE US corporations backing them. For the time invested, the US Federal government would most likely go after “larger pockets” such as those who own and control games such as WoW or Everquest.

Additionally, I wish to respond to your comment that “children are exposed to gambling.” Any online purchase of Evony coins involves a credit card or some other form of purchase method that requires authorization of an adult. IMO, it would be irresponsible for any parent to allow a child to make those decisions w/out their approval. Furthermore, “the wheel” is a random element of reward that is given to all players and has been part of the game ever since I started to play. If a parent is properly supervising their child and does NOT approve of this random element of chance as an appropirate option to expose them to, they shouldn’t allow their child to play.

The Terms of Use for the game requires approval of the user to represent they are “an adult in your country of residence.” While I know children will click away and install things on their own, I firmly believe it is the sole responsibility of the individual parents to monitor their children and should in no way be the responsibility of Evony or any other company that sells / distributes computer games.

Thanks in advance for allowing my comments to be a part of your blog. I sincerely hope this post reaches your site. Sincerely, David W. US resident

#12 Bruce on 09.15.09 at 8:53 pm

@David W
You miss the very obvious difference.
All other MMOs you have to earn any in game money you gamble by playing the game.
In Evony there is gold farming built into the game, so you can gamble real money.

So everything you say is invalid.

#13 Robert on 09.16.09 at 12:55 am

I have seen this issue on another game (Maplestory). They have a “machine” called gachapon that requires purchasing tickets from the cash shop in order to get a lucky dip. The tickets can only be purchased using special “NX cash” which is obtained by purchasing with real life money. It costs more than evony but basically is the same concept. The fact that every player wins a prize is the key different between online “gambling” and online “lucky dip”.
That being said, I do not play Evony and am not a fan of the system. But from what I have read, this is essentially a loophole to avoid being classified as gambling as every player wins a prize.

#14 AC on 09.16.09 at 11:46 am

Delaware Gambling Laws
http://www.Gambling-Law-US.com/State-Laws/Delaware/

As you can see from the above, items are given terms:

“Slot machine” means a gambling device which, as a result of the insertion of a coin or other object [Such as an amulet], operates, either completely automatically [Such as through a browser device] or with the aid of a physical act by the player, in such manner that, depending upon elements of chance [1 in a possible 24], it may eject something of value [An item of use within Evony].

It would therefore appear that the correct term for the Evony roulette wheel is a “slot machine.”

Because the value of the items won can vary greatly. People do gamble on the Evony slot machine in order to try to save themselves real money and thus negate buying the more expensive items within the Evony shop. Because the cost of using the slot machine is 5 coins a go (an amulet), one can compare the gambling value in contrast to what it costs to buy the same item in the shop. Players usually gamble in order to win medals and other luxury items. As these cost over 100 coins each it is therefore quite clear that one uses the slot machine in order to gamble for expensive items in Evony.

The person responsible for Delaware state law is the Attorney General. His office would be able to clarify existing Delaware gambling laws.
http://attorneygeneral.delaware.gov/

Cornell Overview of Gambling Laws
http://topics.law.cornell.edu/wex/gambling

Do note the Skill Game Protection Act listed under Federal Regulations. As you can see from Sec.2, Congressional Findings part 6 it list four things. I will list them here for convenience:

a) minors are prevented from playing for money;
b) persons with compulsive behavior should be identified and referred to treatment;
c) operators of such games should not be vulnerable to, or participate in criminal or terrorist money laundering; and
d) appropriate taxes are collected.

Here are a few interesting facts:

- Evony has no parental controls or means of identifying if the user is a legitimate adult;
- Evony is a real time strategy (RTS) game, it runs 24/7 and players can and are attacked when they are offline. Therefore all users are at risk of acquiring a compulsive behavior towards Evony. No health warning exist;
- The director of Evony has now been convicted of fraud from Microsoft;
- In my PalPal receipts, the address of Civony/Evony as “The seller hasn’t provided any postage details yet”;
- In my investigations, like Mr Everiss, I traced the original company to China;
- The United States has no jurisdiction in China;
- Specific benefits are offered to companies that are registered in Delaware. I am sure the Mr Everiss as a former accountant understand these all too well.

AC

#15 Barry Davis on 09.18.09 at 2:10 pm

Oh My God! Gambling on the internet? Say it ain’t so!

Bruce, you need to get a life and stop this silly tirade against Evony. I’ve played it for over a month and never spent a dime on it. I’ve spun the Wheel of Fortune and got some good stuff off it too.

The Unlawful Internet Gambling Enforcement Act of 2006 is yet another example of too much government. BFD, life should involve making choices and you should live by the consequences of those choices. The real reasoning behind that anti gambling law is not to “protect” the people, it’s to prevent competition of government sanctioned gambling like the lottery. Allowing the people to spend money in a rigged game is okay when government is the beneficiary but some how immoral when private industry does it?

I read in a Wired News clip a while back that the Justice Department was going after these online poker sites as gambling establishments. Come on people, this would be a clear example of government gone amok. Do they have enough to do? Did the stamp out all other more serious crime such as rape, kidnapping & murder and I just didn’t get the memo?

As I said earlier choices you make have consequences. Good luck with your defense in Evony’s libel suit against you. You brought it on yourself.

#16 jordan on 09.19.09 at 10:19 pm

Gambling is generally defined as wagering something of value on an event with an unknown outcome with the hope of winning something of value.

To those of you that say that what Evony is doing is not gambling because you have converted your real money into tokens or points or whatever, you are making a semantic argument. The points have real value, you paid for them and now you are wagering them. That’s like saying that gambling in a casino isn’t gambling because you have traded in your real money for chips. You paid for the chips; they have value, so you are wagering something of value.

If it is true that you cannot convert your Evony money back into real money, then there is a least a chance that this is not gambling. The question then, which is actually a larger debate, is what is the value, if any, of virtual goods? If the virtual goods truly have no cash value, then you are not winning something of value and this is not gambling. The reason this is part of a larger debate is that people are still wondering if virtual goods have value and should have, for instance, sales tax applied to them. Until the debate is settled on whether or not virtual items have value, what Evony is doing is probably legal in the eyes of the law. That being said, it looks like gambling to me 

#17 BS on 09.20.09 at 9:41 pm

Zomg…Super Mario Brothers 3 for the NES system had a slot machine game where you had to match up the mushrooms to get extra lives. Since you had to buy the game for the system, that must mean that Mario 3 is now illegal to sell!

#18 BS on 09.20.09 at 9:44 pm

Oh..and Jordan…you are wrong. Gambling is defined as: “to stake or risk money, or anything of value, on the outcome of something involving chance: to gamble on a toss of the dice.”

With Evony coins, you aren’t risking anything. You’ve already bought the coins. Whether you spend them on an item in the shop or on an amulet which is then used for a “random item”, you have not risked anything. Because, that is basically what an amulet is. It isn’t a roll of the dice where you can win or lose. It is an option to let the game choose for you what item you get.

#19 Bearfoot on 09.21.09 at 4:06 pm

Wow.. I wonder how many of the previous postrs work for Envoy.

Hey it’s the old “trade the balls for prizes” pachinko work around. It’s not gambling.. cuz there’s a middleman.

Lots of idioticy around here.

He wasn’t saying it was guys, just that it could be.

Get a hold of the EFF Bruce.. if I had the money you’d have a lawyer. Unfortunatley I don’t.. :(

#20 IAHed on 09.21.09 at 10:50 pm

A number of MMORPGs have been falling into shady practices, and I think it’s time to revive the idea of a Bill of Rights for players. The game I play, IAHgames Granado Espada, pursued a similar Online Gambling idea – but they recently dialed it back (perhaps in light of the Evony case). One of their major investors, GigaMedia, runs Online Poker sites. IAH and/or Granado Espada’s developer IMC is engaging in some other problematic practices similar to what you’ve said about Evony. For instance they have an in-game currency called Feso, which can be indirectly bought through real money (cash shop items called Growth Stones produce Feso). There are ways to get a few Feso in-game but no way to get enough to actually buy stuff. Where items that can be bought in the direct cash shop and Feso shop overlap (for example “pet food”), the Feso shop version ends up costing even more real money – but this is hidden by several layers of intermediary currencies: real money > gpoints > growth stones > Feso. IAHgames is not always so subtle. Past “Events” have consisted of players competing to buy the most cash shop items to “vote” in popularity contests. IAHgames has also turned to censoring critical comments, saying it’s against the ToS to “slander” the company.

I would not put IAH on the same level of Evony, though I can see them getting to that low point if no one stands in their way. Other publishers of Granado Espada have been losing money (Hanbitsoft, The9), and there may be a sense of “get as much as you can while you can” without any regard for cultivating longterm customers.

IAH is also not the worse that I’ve seen. I took a pass on Malaysia’s Perfect World, which was paying existing to players to induce new players to “top up” – and called the new recruits their “downline” like some sleazy multilevel marketing scheme!

I left another MMORPG, Tantra, after their money-milking maneuvers just became too obnoxious to bear. Tantra’s Events consisted of directly selling the *top* weapons and armors to players. Each month said weapons and armor would be upgraded in some way, so players would always have to buy the new one to stay on “top”, as one of the chief attractions of Tantra was it’s player vs. player warfare. So far, though, we are just talking about exploiting captive customers, handcuffed to the game by their friends and previous investments. The truly slimy thing Tantra did was require a “recipe” for each upgraded item: the item you got from the last Event plus a number of items from the cash shop. This meant players were re-investing in the same item every couple of months, and the true cost was being hidden under recipes-for-recipes. I felt lucky I got out when I figured out I had put a few hundred dollars into the same item. I’m sure some players spent thousands, but it would be really hard for the younger ones to figure out where the money went or how it was spent. By the time shocked parental supervision comes into play, the game publisher has already gotten away with the kid’s college fund.

I strongly support your efforts to raise awareness about Evony. I’m also hoping that this opens the door to a broader discussion of limits for the F2P business model. Everyone knows that the MMORPG customer base is young, and it’s too easy to exploit their impulsiveness. The game publishers themselves should act to set industry standards before some child protection groups come in and set the standards for them.

Perhaps it’s also time to revisit the Avatar Bill of Rights idea, as well.

#21 IAHed on 09.21.09 at 11:18 pm

One more comment – I’m wondering if a big part of the problem is how MMORPGs are being presented to potential investors. If they are presented as a Get Rich Quick scheme, then investors will insist on Getting Rich Quick.

#22 Victor on 09.22.09 at 5:58 am

I played this game for a week recently and have come to some suspicious conclusions about it. It appears that there are people inside the company who are playing the game and they get everything they want for free and get ahead of everyone quickly and bully others in an attempt to get them to buy coins to advance quickly.

I am not sure but it seems like some pretty shady stuff is going on behind the scenes.

#23 AC on 09.23.09 at 5:12 pm

The reality is that young minds caught up in virtual worlds become incapable of separating truth from fiction. This makes them highly vulnerable to the manipulation of adults who have coded their game products with habit-forming game play. The notion of implying that a minor represents the “market” for a game that employs highly addictive gambling systems is farcical. I have played many browser games in my time and real time strategy (RTS) games are always the most addictive. While video games effect children, RTS can effect the most educated and responsible people in society.

Non-gamers generally attribute blame to the internet without understanding the actual cause of the problem. Until people begin to understand the sophisticated manipulation that transpires transpires within some internet games, they will continue to fail to understand the problem. Many games are social networking sites, and it is here where investigators need to direct more attention. The game mechanics of some products deliberately create a system that promotes a habit in their users; this habit has to be fed as it moves towards an addiction. The game social networking systems promotes this habit and slowly, as the people get to know each other more and become dependent on each other, the users start to become addicted to it. Young users are extremely vulnerable.

All game producers claim that their products are safe. If this is the case, then why do people face difficulties with them? Many people around the world are now aware of the difficulties that can be posed by games like World of Warcraft, but in reality videos games like this are far less addictive than many of the free browser games that exist online. In addition, the number of RTS players is likely to exceed the number of people that play online video games. Yet this remains a secret, perhaps because browser games are rarely viewed as being a legitimate product. Indeed, when browser games advertise that they can be played in secret, a minor is unlikely to advertise this fact to their parents, especially if the advertising is of an adult nature.

Internet addiction in China
http://www.youtube.com/watch?v=sa0L9Bhhwmg

AC

#24 Captain Rhubarb on 09.24.09 at 7:40 pm

If you’re looking for a good example of virtual gambling, check out Atlantica Online. It sells $10 “boxes” which randomly contain items worth anywhere between 50 million and 1 billion in-game currency. The odds of getting the most prized items are low, so players will usually have to purchase several boxes in order to get the premium item they’re seeking.

I’ll bet they also have a huge credit-card chargeback rate, and tons of fraudulent payments.

#25 Mike Byron on 09.25.09 at 7:00 pm

Amulets are purchased for real money with the sole purpose of being used at the gambling wheel. For this reason, it is proper to consider them as you would with casino jettons.

#26 Kris W on 09.28.09 at 11:27 am

The real problem is that the wheel is rigged to land on junk most of the time.

#27 Simply Put on 10.01.09 at 11:59 am

Simply put…

1. Real money CAN become in-game Cents.

2. Cents -cannot- become real money.

Therefore, there is no gambling of real money.

#28 David W on 10.09.09 at 7:26 pm

Hello again. I for one appreciate AC’s comments and especially like the one on 9/23 very much. Very articulate and well done! I agree 100%.

I did some investigating myself about the gamling law sites that AC posted and I have yet to find any documents within the Delaware or US sites that refer to “virtual goods or currency.” With that said, I did a google search and found a very interesting and well written article on the topic.

http://venturebeat.com/2009/06/04/could-social-gaming-companies-get-nailed-for-illegal-gambling/

I give it 5 stars!

As for Bruce & your reply:

First I commend you on allowing my post to be kept upon your blog. Unfortunately I am disappointed with your response.

The amulet / wheel / gambling debate is one issue (that I had a hard time finding any government that actually took action on yet). The actual value of virtual goods is another (which is discussed in the article i posted above). And my comments regarding minors playing this game (which you first talked about in your original blog post) was NOT addressed by your response at all.

Your final statement of “So everything you say is invalid” is to be a bit reactive IMO.

With respect to gold farming, I find that gold within the game of Evony is becoming increasingly worthless! If you compare the virtual prices of the other desirable resources (food, wood, and iron) inside the market, they are often costing 5x or more the price of 1 gold piece (on server 25 anyway). I for one value food, wood, and iron as more valuable resources than gold ever will be for the rest of my game play.

The REAL virtual good / currency of any value is the COIN that is purchased with real money. Again, I stipulate that it is the players choice to purchase items with that coin (either attack / defense / speed up items or amulets to use on the wheel). If they choose to purchase additional amulets (yes, additional as they are still given FREE every 24 hours), then that is the players choice. I can wrap my head around the concept of the wheel being a slot machine. However I have yet to find a way to “cash out” any coin or virtual Evony items for real money which is probably what makes this such a tough issue to debate over. I do know that games like WoW, Everquest, and the Zynga Poker site does have many scammers trying to bilk players out of their real $.

Thanks again for all your comments. As I am a game player (not employee) of Evony, I do appreciate the discussion / debate.

Sincerely,

David W

#29 x1134x on 11.04.09 at 10:34 pm

Read the 1st few posts of retarded drivel and skipped down to point out how you’re wrong i apologize if someone already mentioned this:

The roulette wheel in evony is not gambling, gambling poses a risk of LOSS, in every spin of the roulette wheel the player *always wins something* they never lose and come away with nothing. They’re simply making a purchase of a random item at a set (in game) price. Once the game coins are bought, *poof* the real money is gone, its not the purchaser’s anymore its the game companies, not at risk at the roulette wheel.

#30 dale on 11.15.09 at 11:44 pm

ok you say they are wrong for having the ammy(its gambling)with minors online.ok my question is who is paying for the stuff from evony.i will tell you who adult.(its called parents.)and like most games online you have free to play or pay to play.the only diffrent here is they let peaple choose to buy stuff to help in game.theres a number of games online that has ways to get a better chance to advence in game.and to be honest you asking for donation should be against the law.(and thats a bigger gambling than the ammy is.)who knows how much cash you have tooken from peaple.any ways good luck on your quest rather its to get rich scam . or to cry about not knowing how to play.

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