As advantage players turn to new ways to maximize their wins and at the same time remain welcome patrons of casinos, many have turned to comps to supplement their play. The use of players cards and the redemption of comps have raised numerous and somewhat complicated legal issues, leading players to ask many questions about the use of players cards. As a lawyer, I hear many of these questions, and the answers to many of these questions are usually simple and entirely unsatisfying: "I don't know, and nobody knows."

Complimentaries, or "comps," are the casino's way of rewarding their loyal players and encouraging them to return to the casino in the future. Based on the amount of money a player puts into action, the casinos have an expected theoretical win that correlates to the house advantage of each game. If, based on you much you have bet, the casino expects to theoretically earn $100, they'll return to you some amount that they think will lure you back, let's say $20 in value, which may take the form of room discounts, free food, cash back, free play, tickets for drawings, etc.

You want in on these comps? You begin be getting a players card on which they will track your play to determine the amount of comps for which you qualify. Just go to the players club and sign up for the card (it's free). Nowadays you must show them valid identification, such as your driver's license, and they will then give you a players card. Up to about 15 years ago, a husband and wife might have shared a players card account, earning comps jointly; however, that opportunity has almost disappeared nowadays, the majority of casinos require that each player must have their own separate card and account number.

There are little or no laws that deal directly with players cards and comps. In essence, comps are gifts; casinos are not required to give out comps, and they can make up their own rules concerning how and when to give out comps. Most players clubs have rules, and they may be as simple as "non-transferable" or "comps are the property of the casino and can be cancelled at any time." The rules may be much more specific, and are contained in brochures that are available in the casino (or on the casino's web site).

There are many ways in which advantage players may try to profit from opportunities to profit from the structure of certain comps or promotions. Most simply put, if the value of a comp is greater than the expected loss of earning that comp, then this structure gives the player an advantage. Some groups of advantage players have teamed together, such that each player puts their play on a single card that is used by all players on the team. This setup can yield an advantage to the players when a higher level of cumulative play yields more in comps (or free play) than each person individually would earn. Conversely, if a large bonus is being given for a minimal amount of play, some individuals will try to maximize the value of that promotion by playing it often under different names. This might be equivalent to a store offering a "loss leader" to its patrons with the caveat, "limit one per customer." On a small scale, this might be a petty situation of "who cares?" But if a team of individuals can generate serious money from such tactics, the casino may resent it, and consider it illegal.

For the purposes of legal considerations, violations of players club rules do not create criminal liability. Those violations might result in cancellation or revocation of comps, but you can't be prosecuted for those violations. However, there are a few existing, more general laws that can create criminal liability for "misuse" of players cards. For instance, the use of someone else's players card, WITHOUT THE PERMISSION of the cardholder, would likely be a form of theft or identity theft in most states.

There are certainly ways in which the use of players cards and even multiple IDs can be used legally; however, there are also laws which criminalize the possession or use of multiple drivers' licenses in different names. I know that some players learn that some specific facts make something legal, and they assume that all scenarios with multiple cards are legal. That's a real dangerous assumption. Every state has different laws, and every state enforces their laws differently.