A Celebration of Class
Class II is something of a hot commodity in tribal gaming these days. Suppliers report rising demand for Class II games, most responding with accelerated development geared to both Class II and Class III.
Class II-only casinos in states like Alabama and Texas now have access to the top brands and game families in the slot industry, as manufacturers continue to port their most popular game content over to the Class II format. Suppliers have all increased Class II production and marketing of games.
Much of the new attention on Class II games traces back to newer Class II technology, which has advanced to the point that Class II games are all but indistinguishable from their Class III counterparts. And reports from the field confirm that the games are earning their keep.
Buddy Frank, a veteran slot executive and EKG Slot Operations Hall of Famer who spent years in the tribal gaming market as head of slot operations at California’s Pechanga Resort, notes that the improved quality of Class II slots has been evident for more than a decade. Recalling the 2015 opening of the Tohono O’odham Nation’s West Valley Casino, Frank, who was a consultant on the project, points to the success of West Valley’s first two years, when the casino was restricted to Class II games in the middle of a strong Class III market in Phoenix.
“If you have modern Class II games, you can compete just as well as anything else.”
—Buddy Frank, veteran slot executive
“They were in a warehouse; they knew it was temporary as a permanent facility was being built, so they placed all Class II games in a Class III market,” Frank recalls.
“But here’s the difference, and it’s really important—they were all brand new Class II machines. And their numbers met or exceeded anything on a win-per-device-per-day of anything in the whole Phoenix area. It goes to show that if you have modern Class II games, you can compete just as well as anything else.”
Frank adds that new formats are beginning to appear in Class II. Eclipse Gaming Systems has partnered with Interblock to introduce Class II electronic table games. Frank notes that a company called Planet Bingo has developed a Class II video poker platform that plays and behaves like traditional video poker.
“Most of the Class II pokers are horrible, but some new companies have really good models out,” Frank says. “And if someone like IGT ever adopted that, you could change all your pokers over to Class II and no one would know. I’ve seen a Class II roulette ETG out there. It doesn’t make sense, but they worked out the math.
“Class II technology today is something that should be explored more and more by some operators, particularly those who want to have leverage dealing with states—political leverage for tax purposes, or dealing with artificial expansion limits on the games they can offer. Class II is very viable.”
Class II footprints in casinos that also offer Class III games support their importance in the overall revenue picture for tribal casinos. In Oklahoma, there are some 88,000 slot positions and nearly half are Class II games, according to Skyelar Perkins, corporate senior director of slot operations at Choctaw Casinos & Resorts.
Perkins says a lot of the success from placing Class II on the floor is connected to the renewed attention to the genre by the major manufacturers. “Initially, some of those manufacturers didn’t take Class II seriously, and they were just kind of copying and pasting. Math models didn’t translate, and what we got from traditional Class III manufacturers trying to get into the Class II space just didn’t do well.”
He says smaller manufacturers like the former VGT—now part of Aristocrat—and Class II-first companies like the former Multimedia Games (now Everi/IGT), AGS and Bluberi began to approach Class III differently. Titles already popular in Class III began to appear in Class II, and soon, traditional Class III suppliers were building up their Class II libraries.
Perkins comments that hits and misses happen in Class II, just as in Class III. However, he says the fact that major manufacturers are paying attention to the format is a good thing. “They’re getting live data, real-world information,” he says. “They can start making tweaks and development changes to make that product better.”
Many Class II games, in fact, measure up to their Class III counterparts in terms of performance. According to the January Eilers-Fantini Performance Report, a sample of 6,813 Class II games from Aristocrat Gaming registered win numbers of 1.28 times house average, and games from IGT, Light & Wonder and Konami performed near, at or slightly above house average.
According to the January Eilers-Fantini report, the top 10 indexing Class II games included many titles very familiar to Class III players, like Lightning Link from Aristocrat, Frankenstein from Light & Wonder, Prosperity Link from IGT and more.
Perfecting the Technology
The reason Class II is alive and well, and registering solid performance for casinos, is that the technology has been perfected over the past two decades.
“Going back 20 years, the Class II machines were terrible,” comments Frank. “Outside of Oklahoma, where the performance was terrific when that’s all they had, everyone—especially us old veterans—thought Class II was junk. But when you get to the newer games, they’re pretty darn good. Most players have no idea they’re playing Class II games. You can’t see a bingo card unless you look for it.”
The bingo card, of course, is the basis of Class II technology. The classification was created by the 1988 Indian Gaming Regulatory Act (IGRA), which stipulated that tribes were free to offer bingo without having to share revenue with state or federal governments.
The key language of IGRA that eventually would enable Class II slots to flourish was a section permitting “the use of electronic, computer, or other technologic aids in connection with the play of Class II games.”
This phrase in the statute provided a basis for a few operators and manufacturers to work on the development of a workable Class II system that would compare favorably with Class III gaming. Beginning in the early 2000s, slot executives headed by Charlie Lombardo, who was VP of slot operations for Florida’s Seminole casinos, worked with manufacturers and regulators—primarily the National Indian Gaming Commission—to strip away the more cumbersome elements of early Class II games, such as requirements to daub numbers as in live bingo and to include the prominent display of a bingo card.
“As the market grows, further development of our Class II offering will position us to grow with market expansion.”
—Jesse DeBruin, Senior Vice President, Class II and CD Markets Business Leader, IGT
Lombardo, now a member of both the American Gaming Association Gaming Hall of Fame and the EKG Slot Hall of Fame, says he was tasked by Seminole Gaming CEO Jim Allen to develop a workable, legal Class II system. “That was my first introduction to Class II,” says Lombardo, who had headed slot operations at Caesars Palace, Bally’s and Paris Las Vegas by that point in his career. “All I knew of it were gray-area games in California and several other states. Everything was gray area; they were skirting the law. There weren’t any true Class II games out there.”
Working with legendary tech wizard Lyle Bell, who was chief information officer for the Seminole casinos at the time (later systems chief for IGT) and game developer Bob Luciano of Sierra Design Group, Lombardo refined the Seminoles’ Class II system, applying the “technological aids” permitted by IGRA to create a Class II system that would eventually convince the major slot manufacturers to ramp up production of Class II games.
“Our drive was to build a platform that would mimic Class III in every aspect, which meant anyone who wanted to hang a game on our platform could communicate with it. And, we wanted it to be seamless to the player.”
Lombardo’s team was on a tight deadline. It was late 2002 when Seminole Gaming sent an RFP to all the major manufacturers to join the project. The winning proposal would come from Sierra Design Group, the Reno company founded by Luciano, a veteran IGT engineering executive, in 1996. (It was acquired by Bally in 2004.)
The goal was to have the system ready for the debuts of Hard Rock Tampa and Hard Rock Hollywood, which both opened in 2004.
The Seminole Hard Rock casinos would prove to be laboratories of modern Class II gaming. The ensuing years would see legal battles and negotiations with NIGC officials, whose position was that there should be a “bright line” between Class II electronic bingo and Class III slot machines.
Eventually, the national regulators agreed to technical standards that would eliminate physical daubing, cancel the need to touch a machine twice for each play (once for the bingo draw, once for the slot spin), and relegate the heart of the system—the bingo card—to a small display in the corner of the slot screen, all but unnoticeable during play that closely resembled Class III slot play.
The key element of the system developed by Bell, Lombardo and Luciano was the math. The simulated bingo number draws awarded prizes not just for lining up a bingo, but for any of hundreds of bingo number “patterns” that were analogous to winning combinations in a slot program. Every spin involving at least two players triggers the bingo draw and corresponding slot results. The Seminoles linked the system among six Florida casinos, so there is always a bingo game possible.
The system, linking games to a central computer, opened Class II to a variety of content from the top suppliers. Where maybe eight vendors initially supplied Class II, each with its own platform, some games not accepting cash, the Seminole system “didn’t discriminate with anybody,” Lombardo says.
“Class II or Class III manufacturer, hang your game on our system, and we’ll entertain putting your machines on the floor. We were following all the laws of what NIGC stated was a bingo game, but we were doing it differently from what everyone else was doing.”
The growing Oklahoma tribal gaming market was the other laboratory for advancing Class II technology. While Class III would be approved for Oklahoma in 2006, Perkins says the arrival of the broader range of manufacturers strengthened the Class II footprint to where it still maintains half of the game mix in the state.
“The manufacturers found a path for Class II, and suppliers like IGT and Light & Wonder have gotten more serious about the product they’re making for the Class II side, and that stuff is getting better every day,” Perkins says. “We’re having more and more success with our Class II product.”
Class II Resurgence
The Class II game format is enjoying a resurgence. While the improved quality of the games themselves has provided tribes with considerable leverage in compact negotiations, manufacturers report burgeoning demand and growing Class II libraries.
“We’ve strategically expanded our Class II library in response to sustained customer demand and the continued strength of tribal gaming markets,” says James Starr, president of Aristocrat’s VGT subsidiary.
“Operators are looking for deeper content pipelines, more premium experiences and greater differentiation on their floors, and Class II has become a critical part of that mix. We’re also seeing a shift in player expectations. Players want the same level of polish, math sophistication and entertainment value in Class II that they experience in Class III. That demand has accelerated our investment and broadened our roadmap.”
Jesse DeBruin, senior vice president, Class II and CD markets business leader for IGT, also reports increased demand for Class II, and he says the supplier is focused on improving Class II content.
“We’re focused on the player experience, so we make a concerted effort to ensure that our best Class II content is available to more players,” DeBruin says. “We’re leveraging top studio talent to continue the powerful player affinity and brand recognition of our Class II games.”
Similar reports come from two suppliers that started out in Class II markets, AGS and Bluberi.
“Class II is core to AGS’ heritage,” says Ben Kongpipattanakarn, product manager, slots for AGS. “Since our start in the tribal gaming markets in 2005, we’ve consistently supported and expanded our Class II portfolio, continuing to deliver content that resonates with players today. Demand will always exist as long as there is a market, and we continue to provide our greatest content to operators for players to experience.”
“Our growth in Class II, both in footprint and revenue, has allowed Bluberi to increase overall game footprint,” comments Brett Vela, vice president, product management & analytics for Bluberi. “We reinvest profit back into our research & development teams, allowing us to open more studios and acquire top talent, resulting in not only more games, but higher-quality games and the ability to pursue larger floor shares in Class II. Revenue from Class II is essential for growing our business.”
As suppliers focus more on Class II development, advancing technology has made the increase in Class II production possible.
“Advancements in modern game‑development technologies, particularly AI‑driven tools, next‑generation software engines and more flexible cabinet ecosystems, have significantly expanded AGS’ ability to accelerate and scale Class II content production,” says Kongpipattanakarn. “As a result, the output increases not only in volume but also in quality, diversity and speed to market.”
“Advancements in platform architecture, tooling and game engine efficiency have significantly improved our ability to deliver Class II content at scale,” says VGT’s Starr. “These improvements mean we can bring new titles to market faster, with higher fidelity and more consistent performance across cabinets.”
“We’re always researching and keeping up with technology to improve our overall game development process and output,” says DeBruin at IGT, “but our increase in focus and content in the Class II space is less about technology enhancements and more about a dedicated, committed approach to Class II.
“Tribal operators need long-term relationships in the Class II space. Both IGT and Everi have deep roots in Class II, and we will continue to focus on Class II, as well as building and maintaining long-term relationships with our tribal customers.”
Into the Future
Meanwhile, Class II suppliers continue to increase their market footprint and develop new Class II content and technological advancements along the way.
“Strengthening our Class II portfolio has allowed us to support more operators, broaden our presence in key tribal jurisdictions and offer a more complete product suite,” says VGT’s Starr. “It also gives us the flexibility to meet operators where they are, whether they’re focused on Class II, Class III or a blended floor strategy.”
As far as Class II, several Aristocrat titles have strengthened the game library. “Several titles have exceeded expectations, particularly when we’ve adapted strong Class III franchises into Class II,” Starr says.
“Players respond to familiarity, brand equity and proven math models, and we’ve seen that translate into exceptional performance in Class II environments. While we always expect our top franchises to perform well, the speed and consistency of adoption in Class II has been a pleasant surprise and reinforces our strategy of delivering premium content across both categories.”
IGT, in addition to ramping up Class II production, released a product designed to expand the Class II market online. “We have historically enjoyed good game performance and market share in Class II gaming, so as the market grows, further development of our Class II offering will position us to grow with market expansion,” says DeBruin.
“A great example of how we address this is with our recent announcement with the Muscogee Nation of the first-ever installation of a mobile Class II gaming solution, utilizing our Everi Vi platform. This allows for real-money Class II gaming across the Muscogee reservation, with over 20 available game themes today and a commitment to adding new content each month.”
AGS has crafted launch events for Class II products, such as the recent debut of the So Hot Super 4 series. “This demonstrates a targeted push toward increasing production depth in this category through improved tooling and platform flexibility,” Kongpipattanakarn says. “The original So Hot series has been extremely popular in the Class II markets for nearly 20 years.”
Suppliers and operators agree that more expansion is in store for what is now a healthy Class II market.
Bluberi has transformed one of its most popular titles, Timber Jack, into a Class II success story. “The original Timber Jack was first installed on Class II floors over a decade ago, and continues to be a player favorite in Class II casinos,” says Vela.
“Legacy Class II markets, like Alabama and Florida, saw a strong start in low-denomination play on Timber Jack and over time it was able to carve out a space in high-limit rooms. Our most recent iteration, Timber Jack Going Wilder, was able to build on the success of the original in Alabama and Florida, while newer Class II markets like Texas and Washington saw early player adoption of the latest Timber Jack theme. After 10-plus years in the market, Timber Jack remains a favorite of Class II players.”
Vela is among the suppliers predicting further Class II expansion. “Bluberi believes Class II gaming will continue to represent a stable and growing segment of the North American gaming market. We are seeing ongoing expansion through new property developments, broader Class II deployments, and continued floor reinvestment across tribal operators. These trends reinforce the importance of sustained investment in Class II content and platforms as part of Bluberi’s long-term growth strategy. Class II will always remain a vital part of tribal gaming in many states and provinces.”
Other suppliers share the optimism. “As Class II is where we began, AGS will always continue to build, innovate and expand upon the content that originally made the company successful,” says Kongpipattanakarn. “The Class II market will remain strong, trending towards integrating the popular mechanics we see in Class III. This opens the potential for creating new types of experiences and mechanics that can only be found in this market.”
AGS anticipates entering the online Class II market this year.
“We expect continued growth,” says VGT’s Starr. “Class II remains a vital and innovative segment of the industry, and operators are increasingly looking for premium experiences that rival Class III in both entertainment value and performance. We will continue to provide a quality gaming experience regardless of the category for both Class III and Class II players.”
“We do expect continued growth opportunities in Class II gaming,” says DeBruin at IGT, “as Class II is a tool for tribes to strengthen their sovereignty. IGT is committed to the tribes in Class II and we look forward to continuing to grow and support tribes as we work together toward a bright future.”
CLASS II POWER
Eclipse Gaming Systems applies the power of Class III talent to create new Class II experiences
Most slot suppliers have or are creating game libraries for both Class II and Class III gaming. One notable supplier that has chosen to remain solidly on the Class II side is Duluth, Georgia-based Eclipse Gaming Systems.
Under the guidance of former CEO Tim Minard and Rob Visintainer, president and chief operating officer, Eclipse has moved the past few years to bring in talent from the Class III side, notably Bally and Ainsworth veteran Mike Trask as chief product officer.
But the new team is not tasked with creating a Class III platform, just with maximizing the quality of its Class II product.
“There are 75,000-plus Class II machines in the market,” Visintainer says. “Eclipse is an exclusive supplier to Class II primarily due to the relationships with both the tribes and properties we serve. We are honored to serve this market due to these relationships, and it means much more than just a ‘transaction’ type business. This is where Eclipse’s ‘Going Beyond the Game’ motto comes from. Eclipse Gaming will remain dedicated to Class II content for the foreseeable future, and we’ll continue to focus on value-add content that benefits our customers.”
Visintainer says the new boost of talent crosses both classifications of games, not just Class III. “From a development perspective, we hire best-in-class talent across both Class II and Class III,” he says. “The difference in these two verticals is in the platform (one is bingo and the other RNG). In terms of content and game creation, there is very little difference, which helps us pull from a larger pool of talent across the industry.”
Eclipse has continued to expand its footprint in Class II, not only in slots, but in last year’s launch of its first Class II electronic table games, produced in partnership with ETG leader Interblock. “We saw a great deal of momentum due to the relationships and strong desire to place ETGs into some of the customers we serve,” Visintainer says. “We are releasing the Class II Craps at the Indian Gaming Tradeshow, and we expect a lot of success based on the feedback and requests we have received for this product.”
Visintainer sees a lot of green space in front of Eclipse in the Class II market. “We see tribes continuing to place Class II into their properties indefinitely,” he says. “The content is continually becoming harder and harder for players to notice any difference from Class III… In the future, we believe you won’t be able to notice a difference between a Class II and a Class III property.
“Lastly, there are tax advantages that the tribes are able to enjoy that do not exist in Class III. If we continue to produce and launch content that performs for these properties, then I see Class II hanging around a long time.”
