Meetings & Information


Thursday, March 24, 2016

Letter to AG Maura Healey on Penn National's Deceptive Online Marketing Practices

Below is our letter today to Attorney General Maura Healey requesting that her office take swift action to protect Massachusetts consumers from Penn National's deceptive and unfair online marketing practices as reported in today's Boston Globe.

I encourage you to contact her office by email or a hard copy letter, urging her to act against these fraudulent practices. 


Les Bernal,
Stop Predatory Gambling
March 23, 2016

Attorney General Maura Healey
Office of the Attorney General
c/o Gaming Enforcement Division
One Ashburton Place
Boston, MA 02108

Dear Attorney General Healey:

On behalf of Stop Predatory Gambling (SPG), I am writing to request that your office act swiftly to stop the unfair and deceptive marketing practices being used by Plainridge casino in their online marketing program.

As reported by The Boston Globe on March 23rd, Plainridge’s parent company Penn National has designed a fraudulent online slots game that creates an illusion of success with the intent of luring more citizens to use real slot machines.

According to the story:

“If the games look the same and sound the same, but the payback of one is much lower, then that’s misleading,” said Natasha Dow Schull, an associate professor at New York University and the author of Addiction By Design: Machine Gambling in Las Vegas.
Schull said online casino sites have a bait-and-switch quality to them because their large payoffs condition players to expect the same at the casino.

The goal of online slot machines, a growing trend known in the casino industry as social gaming, is to “prime your system for gambling — to hook you in,” she said.

The real slot machines inside Penn National’s casino are designed mathematically so users are certain to lose their money the longer they play. At the same time, the machines are literally designed so citizens cannot stop using them, exploiting aspects of human psychology and inducing irrational behavior.[1] Every feature of a slot machine - its mathematical structure, visual graphics, sound dynamics, seating and screen ergonomics - is designed to increase a player's "time on device" – which means how long a person plays.[2]  (See Figure 1 below)

Figure 1: Addiction By Design by MIT Professor Dr. Natasha Schull, Pg. 112


No single act of government creates more inequality of opportunity than its promotion of gambling. Bringing about major reform on this public policy includes stopping the unfair and deceptive marketing practices used by commercial gambling operators such as Penn National.

For additional information on the issue, please contact me at (202) 567-6696. Thank you for your attention to this important consumer protection issue.


Les Bernal
National Director
Stop Predatory Gambling


[1] Natasha Dow Schull, PhD, Addiction By Design, Machine Gambling in Las Vegas, (2012), available at

[2] Natasha Dow Schull, PhD, Beware: Machine Zone Ahead, Washington Post, July 6, 2008,
Build a more humane and just society: sunset the policy of government-sponsored gambling because it's dishonest, financially damaging to citizens and contributes to rising inequality of opportunity.

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