ASA Adjudication on William Hill Organisation Ltd

Ad

A promotional e-mail, for William Hill Skill Games, was headed “We've brought you Poker, Casino, Games and Sport. Now William Hill would like to announce the launch of our new Skill Games.” The e-mail stated “Play our three classic games of Blackjack, Backgammon and Gin Rummy against other players for cash!” In a section entitled “Blackjack - Beat other players, not the house” the e-mail went on to describe the game; “If you rate your skill and strategy why not take on other real players rather than the house? - Choose either Head-to-Head cash games or Tournament format. - The 4 deck shoe is never shuffled, feel free to Count Cards. - Win by accumulating the most chips by the end of the match.”

Issue

The complainant challenged whether the ad was misleading, because he believed Blackjack was not a game of skill.

CAP Code (Edition 11)

Response

William Hill said the e-mail was sent only to their existing customers. They said the object of the Head-to-Head game was to amass a larger chip-stack than an opponent. They said the game allowed players several options during play, which permitted them to follow different strategies. They said points were awarded in the form of casino chip 'dollars, which were obtained by beating the dealer's hand of cards to build a chip-stack higher than that of the opponent. In order to beat the dealer's hand, a players hand had to have a higher of combined face value, without exceeding a total of 21. William Hill pointed out that that element of the game was identical to traditional Blackjack.

William Hill believed Tournament Blackjack required even more skill than the Head-to-Head game because the games were played over a set number of hands, up to 40, which meant players needed to follow a strategy and bet appropriately. They maintained that a significant element of skill was involved because each player took turns to bet first, meaning the value of each bet was crucial. As with the Head-to-Head game, the player with the most chips at the end of the game was the winner. William Hill said the deck of cards was not shuffled between hands, which allowed players to card count, which gave players an advantage. They explained that card counting involved apportioning a score to the value of each card from low to high. They explained, when the count was low, plenty of high cards were left in the deck, favouring the player. It was at this point a player could bet more aggressively with a greater probability of success. William Hill maintained that an obvious element of skill was involved in card counting. They said a basic counting guide to card counting could be found on their website to help players improve their skill.

Assessment

Not upheld

The ASA understood that Blackjack was a well-known card game and considered that recipients of the e-mail were likely to be familiar with the nature of the game, especially because they were existing William Hill customers. We also understood that Blackjack involved drawing from a randomized deck of cards and winning therefore depended on an element of chance. We understood, however, that the game also featured several appreciable elements of skill and strategy. We considered that it was highly likely that an experienced and skilful player would be consistently more successful at winning than an inexperienced or bad player. Moreover, we also noted William Hill actively encouraged players to count cards, which we understood was an acknowledged strategy for improving the outcome of a hand. We considered, therefore, that it was reasonable for William Hill to refer to skill being involved in their online version of Blackjack. We concluded that recipients of the e-mail were unlikely to be misled.

We investigated the ad under CAP Code clauses 3.1 (Substantiation) and 7.1 Truthfulness) but did not find it in breach.

Action

No further action required.

Adjudication of the ASA Council (Non-broadcast)