Valve has responded to the Washington State Gambling Commission's demand that it shut down skins gambling by denying that it facilitates gambling.
Valve missed the WSGC's original October 14 deadline but was granted a short extension, and in a letter finally delivered on Monday October 17 (subsequently uploaded by TechRaptor) the company set out its position, which is essentially that it is the victim of unscrupulous souls misusing its technology, that it has taken reasonable steps to discourage this, and that, frankly, the WSGC is being a bunch of old fuddy-duddies.
"As we have explained on multiple occasions, Valve is not engaged in gambling or the promotion of gambling, and we do not 'facilitate' gambling," Valve's in-house counsel Liam Lavery began, as though addressing a child who refuses to accept it is bedtime.
"The operation of Steam and CS:GO is lawful under Washington law. We were surprised and disappointed that the Commission chose to publicly accuse Valve of illegal activity and threaten our employees with criminal charges.
"There is no factual or legal support for these accusations. Notwithstanding, as you know Valve has taken its own steps to discourage skins gambling on third-party websites. We are open to further cooperation with the Commission."
Lavery's letter goes on to trace the broad outline of the situation that led to the WSGC's threats. Skins are a core part of Counter-Strike: Global Offensive, he explained, and there's nothing illegal about players selling or trading them using Steam.
The way that third-party gambling sites tap into this to fuel their shady trade is through Steam Marketplace and Valve's OpenID system, the off-platform secure login system that resembles similar services from Facebook and Google. Again, Lavery said, these systems are legal.
Valve doesn't like skins gambling either, Lavery explained, and has taken steps to discourage it, shutting down the accounts used by the sites and issuing cease-and-desist letters to over 40 of them since July. It's difficult to keep up with the creation of new sites and accounts, often using sophisticated bots, but Valve does what it can, said Lavery.
"The Commission's main argument seemed to be, 'Valve could stop this, so it should.' We do not want to turn off the Steam services, described above, that skin gambling sites have taken advantage of. In-game items, Steam trading, and OpenID have substantial benefits for Steam customers and Steam game-making partners. We do not believe it is the Commission's intention, nor is it within the Commission's authority, to turn off lawful commercial and communication services that are not directed to gambling in Washington."
Overall, Lavery argued, Valve's operations are within the law and it makes an effort to enforce its Steam user agreement on people who misuse Steam to operate gambling services. He challenged the WSGC to cite any criminal statute or regulation that Valve is violating, and said Valve would be happy to work together to identify skins gambling sites and accounts they use.
One gets the impression this won't be the last we hear on this subject. And we still don't have Half-Life 3!