It seems to me that they can make the promo favorable to them without needing to violate the rules of the promo:
1. Get rid of high denominations to eliminate scenarios where someone would get a big early hit and quit. Plus with low denominations, if a lot of people quit after only being down 10k or so, there's a greater chance that people skip some of the freeplay pickups because the amounts aren't as big.
2. Lower payables to the point that it is highly unlikely for people to be ahead after significant play.
3. Only allow freeplay on select slot machines with the minimum legal return. Limiting which machines customers can use freeplay on also makes it easier to monitor whether people are collecting freeplay for other people. I'm sure there are a lot of out-of-towners hoping to have others collect freeplay for them so that they don't have to make so many trips.
4. With that in mind, maybe even make people go to the desk and show ID to have the freeplay loaded.
5. Have a good investment strategy for the large interest free loan the customers are giving them.
And yet it wouldn't surprise if they still end up modifying the rules...
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