Either the prizes are allocated by a process which relies wholly on chance a "simple lottery" ; , or, if there is a series of processes, the first of those processes relies wholly on chance "a complex lottery" ; . the gambling commission's view is that call tv quiz shows "have many of the attributes of what are defined as `complex lotteries' in the new act".44 if, however, the shows can demonstrate that viewers do not have to pay to take part, they may escape classification as a lottery and be treated instead as a "free draw" and be exempt from statutory control.45 schedule 2 to the act recognises provision of a means of free entry to a competition as being enough to qualify an arrangement as not requiring payment. the cost of postage, making a telephone call or using any other method of communication is not treated as a requirement to pay if the communication is at a normal rate as opposed to premium rate ; . 24. in august 2006, the gambling commission issued a consultation paper on the implications of the new law in distinguishing between lotteries, prize competitions and free draws.46 responses indicated that some, if not all, call tv quiz show operators would probably seek to argue that they were not operating "complex lotteries" as a free entry route using websites was available. the commission was cautious but thought it likely that at least some of the programmes would meet the "free entry" criteria. one or two operators, however, showed an interest in being licensed, so that their programmes would operate as lotteries.47 25. it must be remembered that providing a free entry route via a website would not automatically enable a call tv quiz show to escape the definition of a complex lottery under the act. web entry routes might fail to meet the "free entry" criteria because the routes were "user unfriendly" and failed the test of being no less convenient than entering by paying, 48 or because they were not publicised in a way likely to come to the attention of each potential participant.49 it is also open to challenge whether shows can justly claim that each participant does indeed have "a choice whether to participate by paying or by sending a communication". susan marks, a social policy officer at citizens' advice, told us that there were concerns about whether the internet entry routes would be an option available to citizens' advice bureau clients. 50 the most recent statistics published by ofcom show that only 28% of consumers aged over 65, and 35% of those in socio-economic groups d and e, have access to the internet.51 only 25% of consumers with annual incomes up to 11, 500 have internet access at home, compared with 88% of those with incomes over 30, 000 and a national average of 61%. icstis is currently considering whether the free web entry routes are genuine equivalent alternatives to paying for a premium rate service and draw poker rules. Bowne integrated typesetting system site: bowne of hong kong name: gigamedia crc: 26062 h01293.sub, docname: ex-1.3, doc: 2, page: 39 description: exhibit 1.3. Said one might win 0 a night playing six or seven hours, but that it and of poker rules. 15 art class 9am-12noon exercise with dee, 1 p.m poker rules and with joe, 1-4: 30 mah jongg, 1 p.m. sports talk reminiscing with richie, 2 p.m. 22 art class 9am-12noon exercise with dee, 1 p.m poker with joe, 1-4: 30 mah jongg, 1 p.m.

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