To Whom It May Concern,

My name is I’m a 3rd year Australian Philosophy and Business Law student and I’ve played online and live for about two years. Poker for me is a challenging source of competition, due to the high level of skill present within , which is masked by poker’s luck factor. The legislative response to such a game should be to regulate rather than ban poker, especially when there are much more damaging forms of gambling widely available in Australia such as gaming machines.

Skill in Poker

In the short term, poker is dominated by luck, or variance. However, in the long term all players are exposed to the same situations through being dealt the same random distribution of cards, and their long term strategy will determine whether or not players win or lose in poker. The more decisions points there are in a game for a player to make, the more skilful the game.

Unlike other forms of gambling where games are structured so that players lose in the long run to house edge (roulette, baccarat, blackjack, gaming machines, etc.), whether or not a poker player wins is relative to the skill of the other players at the table. To win in poker, a player must win from the other players at the table at a faster rate than they pay rake to the house (rake being commission taken by the house from each ), which is possible if the other players execute poor strategies. Poker definitely still involves a lot of luck, and this adds a lot of excitement to the game. Poker is however, fundamentally different from other forms of gambling, because a player’s long run result is determined by skill and strategy.

Brains Vs AI Challenge

A great example of skill in poker is demonstrated by the Brains vs AI challenge. On two occasions, a team from Carnegie Mellon University created an artificial intelligence computer program (bot) designed to play No Limit Texas Hold’em heads up (1 vs 1). In explaining his motivation for designing the bot, Prof.Sandholm said:

"Poker is now a benchmark for artificial intelligence research, just as chess once was. It's a game of exceeding complexity that requires a machine to make decisions based on incomplete and often misleading information, thanks to bluffing, slow play and other decoys".

The Carnegie Mellon team would not have invested such time and effort into building poker bots if poker was an unskilled form of gambling such as roulette. It is clear that over a large sample, the skill in poker strategy becomes prevalent, and is a great forum for testing artificial intelligence.

The Brains vs AI challenge was conducted on two separate occasions, with two separate bots. Claudico and its successor Libratus were pitted against four of the top heads up poker players at the time. In the first April 2015 challenge, four human players beat Claudico for 732,713 chips over 80,000 hands at 50/100 blinds, resulting in a human combined win rate of 9 big blinds per 100 hands. In the second January 2017 challenge, Libratus beat four human players for 1,766,250 chips over 120,000 hands at 50/100 blinds, resulting in Libratus’ win rate of 14.7 big blinds per 100 hands.

Libratus had a much more complicated and refined strategy than Claudico, and the results speak for themselves in the Brains vs AI challenges. Overnight, Libratus would refine and improve its strategy for the 20 day challenge, leading the bot to constantly improve throughout the challenge. Libratus’ strategy is much too complicated for humans to replicate, and as a result over the long run, Libratus resoundingly defeated four top heads up human players. Here we clearly see how an improvement in bot strategy led to a drastic change in win rate due to the skilful strategic nature of poker.

Poker was used as a proving ground for the Libratus AI. The bot itself wasn’t programmed to play poker well, but rather to solve problems with incomplete information using an algorithm, which means that the AI can have real world and future problem solving applications.

Legislative Response to and Australian Gambling Culture

Gambling is a widely accepted and promoted part of Australian culture. It goes hand in hand with Australian drinking and mateship culture. This is clear in the national success of casinos such as Crown, which generate massive amounts of revenue and are regularly packed with customers throughout the week.

It does not appear that live gambling will be restricted through legislation in the near future, which is dissonant with the angle being taken on online poker. As previously mentioned, poker is a very skilful form of gambling. If the legislative goal was to regulate Australian gambling, it would be much more logical to focus first on restricting live casinos before restricting online poker. Forms of gambling such as roulette and gaming machines, which set up players in long term losing positions, are much more toxic for the average player than online poker. Suggesting bans on online poker, the one format where players have a chance to win at all, before bans on gambling formats such as gaming machines is a very inefficient strategy if we consider efficiently reducing harm to the average player.

The legislative goal should be to regulate online poker rather than ban and exclude it. Australians clearly enjoy gambling, with the highest amount spent (lost) per player when compared with other parts of the world (pictured above). Banning online poker will leave players with only unsafe options to wager their money online. Sites such as Americas Cardroom still operate online poker rooms illegally and offer online access to Americas, where online poker has already been banned. Players face constant risks with the security of their funds and the integrity of the games they play. It would be a lot safer for Australians if the legislative approach was to encourage a dominant Australian organisation to provide regulated and safe online poker. The United Kingdom has a great regulatory stance to protect poker players, rather than outright ban their hobby.

Conclusion

The legislative focus in regards to online poker should be to protect Australian players. As an intensely skilful form of gambling, poker should be regulated, but not banned within Australia. Australian legislative energy and money would be much more efficiently spent restricting the most toxic forms of gambling such as gaming machines and live betting in casinos, rather than focussing on banning online poker. Poker is often lumped in with all other forms of gambling even though poker is much more skill intensive. The suggestion of banning poker along with other forms of sports betting is an oversight of the nature of poker in relation to other forms of gambling.

Many thanks to you for taking the time to review the Australian online poker ban. I hope the future holds a safe and player focussed view towards regulating online poker.

Sincerely,