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PRE-COMMITMENT AS A STRATEGY FOR MINIMIZING GAMBLING-RELATED HARM Professor, Faculty of Health Sciences & Coordinator, Alberta Gaming Research Institute Abstract Pre-commitment is a relatively new harm minimization strategy for problem gambling. To date, its primary use has been in casino self-exclusion programs, a few Internet gambling sites, and to limit land-based EGM play in a few jurisdictions. Empirical research on it is quite limited, but does tend to indicate that it holds significant promise as an additional technique to promote responsible gambling and to limit the harms associated with problem gambling. Drawing on the existing research, as well as lessons of problem gambling prevention research, it is reasonable to surmise that the degree to which pre-commitment is voluntary, revocable, exceedable, of short duration, available for just some EGMs or some Internet sites, available for just some forms of gambling, and does not use biometric ID, is the degree to which the technique is primarily of benefit to non-problem gamblers (which may or may not translate into a decreased future incidence of problem gambling). In contrast, the degree to which all avenues for excessive gambling have been closed, is the degree to which the technique likely has broader utility for problem and non-problem gamblers. What is Pre-Commitment? also indicates that these limits are often minimization strategy whereby pre-set limits on time, frequency, or money spent gambling are How is pre-commitment currently being used? registered prior to the start of play. Pre- commitment usually refers to player-initiated limits, to distinguish it from the limits that may be imposed by the operator, government, or Casino self-exclusion programs represent a the actual gambling format. Pre-commitment is believed to be a useful harm minimization exclusion programs have been used by various strategy because it a) allows the player to make casinos since at least the 1960s. The first involvement prior to actually engaging in Manitoba, Canada, coincident with the opening gambling (Parke et al., 2008) and b) obliges the of the country’s first permanent, year-round player to keep to these preset limits. Research casino. Since that time, many casinos and indicates it is fairly common for regular jurisdictions around the world have adopted gamblers (including problem gamblers) to have self-exclusion programs (Nowatzki & Williams, budgetary limits in mind prior to gambling 2002; Responsible Gambling Council, 2008; (McDonnell-Phillips, 2006). However, research Williams, West, & Simpson, 2007; 2008). The features of these programs vary depending the person has had 20 visits a month over the on the jurisdiction. The contract may apply to past 3 months then the person is automatically just one casino, or to all casinos in the approached to see whether they would like to jurisdiction. In a few jurisdictions, the exclusion sign a visit limitation contract or self-exclusion extends to other gambling venues such as bingo halls or racetracks. Self-exclusion programs usually require casino operators to remove excludees from mailing lists. The policy may also require casinos to refer to their list of self- Pre-commitment has been offered for several excluded persons before issuing new player years on a small portion of the ~2,300 existing loyalty cards, cashing cheques, extending credit, online gambling sites (Wood & Williams, 2009). or paying out large jackpots. Self-exclusion Here again, the pre-commitment parameters contracts are usually irrevocable for the time available to the player vary depending on the period covered, although a few jurisdictions site. Most common are deposit limits (e.g., have a process for agreements to be revoked daily, weekly, monthly); bet size limits; loss before they expire. Some jurisdictions offer a limits (e.g., weekly, monthly, yearly); short-term fixed time period, whereas others offer a choice exclusion from certain game types (e.g., 6 months); and short- total account suspension lifetime. Requirements for re-entry vary, with (e.g., 6 months). For most sites, deposit and some jurisdictions having no requirements and loss limits tend to be revocable, but self- others requiring a waiting period, a formal seminar. Most countries1 require government Some of the voluntary online gaming regulatory issued ID at the entrance which is scanned and bodies (e.g., e-Commerce and Online Gaming compared to the digitized self-excluder list. In Regulation and Assurance (eCOGRA)) require countries that do not require ID, security personnel are required to identify self-excluders accreditation. In the case of eCOGRA, sites are required to allow the player to set a maximum jurisdictions, people who breach their contracts bet limit as well as to self-exclude for periods of are simply asked to leave. In other jurisdictions, they may be subject to a trespassing charge Currently, there is no system in operation which links all Internet gambling sites within a In addition to absolute bans, certain countries jurisdiction, or across jurisdictions, with an (Netherlands, Denmark), offer casino ‘visit integrated self-exclusion or pre-commitment limitation contracts’ (Williams et al., 2008). The requirement to show ID at Dutch casinos gives Holland Casino the ability to track the frequency Plastic/Smart Cards for Land-Based Gambling of casino visitation. If there has been a significant increase in visitation frequency or Most of us are familiar with simple magnetic strip plastic cards with an associated PIN (Personal Identification Number). A ‘smart 1 For Western countries this includes: Austria, card’ is any pocket-sized plastic card with Belgium, Croatia, Czech Republic, Denmark, Estonia, embedded integrated circuits providing some Finland, France, Germany, Greece, Hungary, Ireland, Italy, Luxembourg, Macedonia, Malta, Moldava, capabilities when interacting with external card- Monaco, Netherlands, Poland, Portugal, Slovenia, Spain, Sweden, Switzerland, United Kingdom. identification, authentication, data storage, and application processing. In gambling, these been reached and players were not required to use their loyalty card to play. In 2009, Global Player Loyalty/Reward card and/or a debit card Gaming Industries conducted a similar trial using player cards with radio frequency ID tags jurisdictions have used plastic cards and smart cards that enable gamblers to establish limits on their gambling behaviour. New South Wales has some provision for pre- commitment on loss limits on cashless / card- The Crown Casino, in Melbourne, Victoria was the first casino in the world to introduce player The Nova Scotia Gaming Corporation (NSGC) EGMs3 in 2002 using a simple plastic card with a piloted the use of pre-commitment smart card PIN. However, play did not stop when limits between 2005 to 2007. As a result of this were met and players did not have to carry ID research, NSGC is currently in the process of to play. Beginning in December 2010 all new installing an ‘Informed Player Choice System’ – “next generation” EGMs in Victoria will have to more recently referred to as ‘My-Play’ - on all of have a pre-commitment mechanism that allows the province’s 2,800 video lottery terminals a player to pre-set time and loss limits. All (VLTs). Players begin by registering with the EGMs in the state of Victoria (i.e., 30,000 in 550 system using their driver’s license or other venues) will have to have such a system by government–issued ID to obtain a plastic card and an associated PIN.4 This information is used to create a unique identifier, with no personally identifying information retained on the central Queensland conducted its first trial of voluntary system. The card is then placed into a VLT to pre-commitment in 2005 at a single venue. In use the machine as well as to access player 2008-2009, Queensland conducted another trial information tools. These tools allow the player to a) determine amount spent in the past day, expenditure in two venues using a cashless week, month, or year; b) set daily, weekly, gaming system. Currently, pre-commitment monthly, or yearly limits on spending; c) set card-based gambling is operational across 48 daily, weekly, monthly, or yearly limits on gambling venues. However, use by the player amount of time they wish to play; and d) lock In 2008, Worldsmart Technology conducted a Use of a card is currently voluntary. Limits are trial of smart card time and spending pre- irrevocable. NSGC has indicated that Non- commitment via their loyalty cards in South problem gamblers are the primary target of this Australia. However, similar to Victoria, play was system in an effort to reduce the future allowed to continue after limits had been had 2 Further details of the Australian pre-commitment The state owned gambling operator, Svenska Spel, began offering a smart card in 2006 coincident with the launch of its online poker site. This card can now be used for its online 3 EGMs refers to slot machines, video lottery terminals, electronic keno, poker machines, fruit Venue-assisted enrollment is possible with 2 pieces poker and sports betting, as well as for land- The card provides play summaries, money and based bingo, lotteries, and sports betting. Card time limit setting (i.e., players can set lower use is mandatory only for online gambling. To use the card, the card number, username and password are required. The card allows players assessment. For EGMs (called Interactive Video to a) transfer money onto the card from their Terminals, IVT) 5 players must insert their card, bank account; b) see a summary of their past verify their player ID, and then remove the card before they can start playing. After one hour of monetary spending limits; d) set time limits; e) continuous play, the EGM refuses that player’s exclude themselves for brief periods of time; bets for a 10-minute cooling off period. and f) obtain a risk assessment of their behaviour. ‘PlayScan’ is the risk assessment tool that compares the player’s behaviour against known problematic gambling behaviour. commenced in 2008) requires players to set It allegedly can determine whether a player is weekly and monthly spending limits, with a currently experiencing problematic levels of gambling behavior and/or is at risk for future Self-exclusion for certain types of lottery games problems. For online poker, it is mandatory for players to set their own limits regarding day, week, and month money spending, as well as session, day and month time limits. However, The government of Singapore has mandated there is no maximum time or monetary limit. If pre-commitment for all forms of gambling the customer wants to increase their limits, within their two casinos by 2011. The limits they need to wait 24 hours whereas decreased that are set also apply across all forms of casino limits take immediate effect. Players are kept gambling. Singapore also employs casino self- informed of how close they are to their limits. operator, Norsk Tipping, introduced a magnetic strip player card allowing lottery purchases to be directly made from a person’s bank account effectiveness of casino self-exclusion, and that and any winnings directly deposited. By 2005 which exists tends to be of poor quality and all of these cards were replaced with smart conducted in jurisdictions without effective cards for enhanced security. Since February detection systems (Williams & Nowatzki, 2002; 2009 the use of these smart cards has become Productivity Commission, 2010; Responsible mandatory for all forms of gambling (online Gambling Council, 2008; Williams, 2010). A full gambling, sports betting, EGMs) except lotteries discussion of self-exclusion effectiveness is and instant win tickets. Players can use the beyond a scope of this paper. However, suffice cards on their home computers with the use of to say that evidence tends to indicate that a) an accompanying card reader. Because the only a small portion of at risk and problem cards are connected with the player’s bank gamblers are aware of casino self-exclusion account, money can be put directly onto them. programs and an even smaller percentage ever Players can also add money to their card by utilize them; b) most people who self-exclude giving cash to retailers, who then put a credit tend to report that the program was helpful in for that amount onto the card. Norsk Tipping limits the amount that can be put on the card to 5 IVTs were privately operated until 2003 and then 400 kroner per day or 2200 Kroner per month. reducing or stopping their gambling for a short period of non-RG use that allowed for a pre- period of time (and a small minority for longer post comparison. These individuals were found periods of time); c) in jurisdictions that do not to have a significant decrease in per session require ID, a large percentage of people re- expenditure ($47 to $40), an increase in play enter the casino during their ban without being length (82 min to 98 min), and no change in detected; d) the overall effectiveness of the frequency of play per month (9.3 to 9.3). program is presumed to be much higher in Examination of individuals with high risk jurisdictions that require ID for entry (Williams & Nowatzki, 2002; Productivity Commission, expenditure for high frequency players (18+ 2010; Responsible Gambling Council, 2008; times in 6 months), and a tendency toward decreased per session expenditure that was Anecdotally, problems have been expressed frequency of play for people with Canadian about the effectiveness of pre-commitment Problem Gambling Index (CPGI) scores of 5 or higher. It was also found that approximately readily available (as is the case in New South 37% of players swapped cards and/or obtained Wales (NSW)) (Nisbet, 2005). There is also a concern that because of the significant amount system, with this being particularly true for initially put on the card (e.g., $200 in NSW) people with higher CPGI scores (Bernhard et al., gamblers may increase spending, either due to 2006; Omnifacts Bristol Research, 2007). more money being readily available or because they require less embarrassing interactions with Preliminary results from the 2009 Worldsmart cashiers and other gambling venue staff (Parke South Australian (SA) trial showed that less than et al., 2008). That being said, people who have 1% of loyalty card holders had voluntarily opted to use cards for the purposes of pre- activated the pre-commitment options on their commitment and have agreed to report on their card (Productivity Commission, 2010). For use tend to indicate that the card helped them those who did, the most popular options were limits on: daily spending (59% of cards); breaks in play (19%); weekly spending (14%); monthly Schrans, Grace and Schellinck (2004) found that spending (12%); daily duration of play (10%); a feature allowing players to set a time limit on monthly duration of play (8%); fortnight their VLT play was only effective in influencing spending (6%); weekly duration of play (4%); one of the six behaviours being targeted for fortnight duration of play (4%); and spending history (3%). Utilization of pre-commitment features tended to increase with time. Among Focal Research Consultants (2007) tracked VLT the 94 individuals with 3 months of baseline play for a 6 month period in a region of Nova data, there was a 25% reduction in daily Scotia that only had player-card activated turnover subsequent to utilization of pre- machines available (~51 EGMs in 9 locations commitment. However, it is possible these played by 1,824 players). Roughly 71% of individuals continued to gamble and just regular players (i.e., playing once a month or decreased use of their voluntary card. There more) opted to try one of the responsible gambling (RG) features these cards permitted exceeded their pre-established limits (in the SA (i.e., spending limit, time limit, 2 day exclusion, system, when a limit has been met it can be or playing history). Roughly 65% of these overridden by venue staff). It is unknown what percentage of pre-commitment breaches this features in subsequent sessions. A subsample 600 figure represents (Productivity Commission, of these RG adopters (n = 122) had a baseline Participants reported that a) monetary limits Maxgaming’s Simplay system showed that only were more useful than time limits; b) 1/3 of 15% of Simplay cardholders opted to use pre- commitment, although this percentage may be excessively high and 40% set time limits that were excessively high (essentially disabling the Commission, 2010). The most popular option pre-commitment system); c) for individuals (used by 45 out of 340 people) was a daily who hit their limits, 37% went to another online spending limit. No one set playing time limits. site and 32% simply changed their limits; d) 5% Thirty of the 45 people setting spending limits of players barred themselves for a period of exceeded them on at least one occasion. There time, with one week being the most common was tentative evidence that expenditure may length (25% of people who barred themselves have decreased subsequent to limit setting. also began playing online poker at other sites); However, here again, this assumes that players e) 26% used the risk assessment option and did not continue playing using cash (i.e., once a 52% of these individuals found it useful. limit was exceeded the only consequence was the inability to use the card for cashless Although there is no available empirical gaming). Since the system has been expanded research on the effectiveness of the Norwegian throughout Queensland approximately 14,000 system, it is instructive to note that Norway has people have opted to use this voluntary system. one of the world’s lowest documented rates of Of these people, 9% have set spending limits problem gambling (significantly lower than (with this percentage increasing over time). other Nordic countries such as Finland and Results from the Odyssey trial in Queensland were similar, with only 5% of players (n = 66) In summary, the empirical research on the opting into cashless gaming (that would also effectiveness of pre-commitment is fairly allow pre-commitment), and 28% of these latter limited, but that which does exist indicates that individuals opting to set a daily spending limit. Sixty percent of users reported that pre- technique. Part of the problem in evaluating commitment was useful, with this percentage pre-commitment concerns the many different being higher for high-risk players. There was ways of implementing it (i.e., mandatory or also a 40% reduction in spending by players voluntary; exceedable vs. nonexceedable limits; who set limits compared to a 3% reduction in revocable vs. nonrevocable limits; short vs. long players who did not set limits. However, this duration of limits; presence on all or just some reduction might be offset by increased cash- EGMs; etc.). Similar to research on other based play, as this option continued to be problem gambling prevention initiatives, the available (Productivity Commission, 2010). ‘devil is in the details’ and the actual effectiveness of a technique is usually very much dependent on how it is applied (Williams et al., 2007; 2008). Drawing on the lessons of percentage of the gambling population have obtained smart cards (in 2008 this was roughly (Williams et al., 2007; 2008), it is reasonable to 1.3 million Swedes and 1.9 million Norwegians) exceedable, of short duration, available for just The Internet Poker Committee (2008) (cited in some EGMs or some Internet sites, available for Responsible Gambling Council, 2009) surveyed just some forms of gambling, and does not use approximately 3,000 participants of the Swedish biometric ID, is the degree to which the technique is of primary benefit to non-problem commitment has the most harm minimization gamblers (which may or may not translate into potential. If pre-commitment implementation is not pervasive, problem gamblers will tend to gambling). 6 In contrast, the degree to which all seek out geographic locations or EGMs where avenues for excessive gambling have been closed, is the degree to which the technique likely has broader utility for problem and non- problem gamblers.7 Similar to what is found for other products with some risk of harm (alcohol, all forms of gambling. Problem gamblers will tobacco, firearms, motor vehicles), the most seek out less preferred forms of gambling if effective overall harm reduction strategies are ones that unfortunately also tend to constrain commitment is most easily extended to other and restrict the behaviour of people who are forms of gambling with existing electronic not at risk of developing problems (Williams et interfaces (e.g., Internet gambling; casinos that require ID for entry). However, electronic interfaces could potentially be created for other forms of gambling as well. The biometric USB key by Responsible Gaming Networks Pty Ltd is particularly well suited for broad application across gambling formats because of its built in connectivity to the Internet, TV set-top boxes, all EGMs jurisdiction-wide. EGMs are the most wagering terminals, lottery terminals, and mobile phones (Productivity Commission, 2010; Responsible Gambling Council, 2009; Ryan, 2010). 6 With reductions subsequent to limit setting in problem gamblers having more to do with a resolve to decrease gambling, as opposed to any constraints imposed by the self-commitment. This is very similar effective if it is mandatory. Voluntary use of to the presumed mechanism for reduced gambling pre-commitment is likely to be low. Although seen in casino self-exclusion programs where no many people indicate they would utilize pre- effective mechanisms for enforcement of the commitment if it was available, actual usage contract/program exist. In other words, the act of when it is available is much lower (Parke et al., self-exclusion (or pre-commitment) is reflective of a 2008). The effort involved initiating it, stigma, recognition that a problem exists and an intent to do privacy concerns, and failure to appreciate the something about it, with the self-exclusion contract benefits are all contributing factors. Although (or act of pre-commitment) being a convenient documentation/proclamation of this intent. Hence, commitment, they may find some benefits if the primary driving force behind the reduction in gambling is this new-found motivation and they did, particularly at-risk and problem recognition, rather than the imposed constraints gamblers. On the other hand, it is also true that there is clinical utility in coming to the realization that pre-commitment is needed. If 7 One of the defining features of problem gambling is a voluntary or opt-out system is used, it will be ‘impaired control’ (Neal et al, 2005). Hence, it is important that once a person begins using pre- naïve to think that simply providing problem gamblers with information about their gambling and/or ‘choice’ will be sufficient to curb their gambling. commitment that they be obliged to continue needed. Some sort of identification system is needed so that all versions of the gambling limit types, values and durations. Monetary format(s) within the jurisdiction recognize the limits appear to be the most important, but individual and his/her preset limits. It is also there may be a small percentage of people who would benefit from time or frequency limits. A biometric, otherwise some people (particularly wide range of available limits for money, time, problem gamblers) will endeavour to use other and frequency would accommodate all types of identities/cards when their own limits have gamblers. This would include the option of setting zero values that would act as a form of improvement over regular cards, but still do not exclusion. A recommended duration range for prevent card swapping, borrowing, or selling. these parameters would be 1 day to 5 years. Unless the card is used for other important The shorter durations would give people the purposes, then some gamblers (or potentially opportunity to try different parameters before venue staff) will give away or loan their PIN settling on ones that are best for them. The smart card to other players. A biometric system is also the best protection against underage constraints. Similar to casino self-exclusion, most jurisdictions currently only offer a selection of short pre-commitment durations, information is less preferable to storage on the which sends the wrong message to problem player’s pre-commitment interface device. gamblers (the majority of whom will have life- Utilization of pre-commitment tends to be fairly long propensities to gamble excessively and low, which is partly related to concerns that should be establishing long-term constraints). one’s play is being recorded or monitored by someone else (Bernhard et al., 2006; Omnifacts, 2007; Parke et al., 2008). Significantly greater be exceedable or revocable. In the case of utilization will occur if the player is confident his/her gambling behavior is confidential. Privacy laws in some jurisdictions will also require this (IGA, 2005). Non-central storage limits/constraints have been repeatedly broken. also ensures that the gambling provider does Thus, it defeats the purpose of pre-commitment inconsistent with player protection (e.g., (otherwise it simply becomes a resolution 8 The medication disulfiram (Antabuse) is a used for the purposes of pre-commitment. somewhat analogous harm minimization strategy for These two things are incompatible, in that alcohol abuse. People who take this medication traditional loyalty/reward cards encourage play, become ill if they consume alcohol within the next day or two. Hence, a person takes disulfiram as a form of pre-commitment not to use alcohol. However, 50 years of research has demonstrated disulfiram to have very poor clinical efficacy because 9 In general, Loyalty/Reward cards are not conducive alcohol abusers have poor resolve to take the to responsible gambling. However, if they are to medication on a consistent basis (Hughes & Cook, exist they should be rewarding responsible play, My Background I am a full professor in the Addiction Counselling Program, Faculty of Health Sciences, University of Lethbridge (Alberta, Canada) as well as a Coordinator for the Alberta Gaming Research Institute. I have published widely in the area of gambling; teach courses on the subject; provide frequent consultation to government, industry, and the media; presented my work at many national and international conferences; and am currently co-editor of International Gambling Studies, which is one of the two primary journals in this field. I am one of the world’s best funded gambling researchers and also recognized as a leading authority in the areas of: prevention of problem gambling; Internet gambling; the socioeconomic impacts of gambling, the proportion of gambling revenue deriving from problem gamblers; the prevalence and nature of gambling in Aboriginal communities; and the etiology of problem gambling. References Alberta Gaming Research Institute (2010). Problem Gambling Prevalence: Canada, U.S., International. Bernhard, B.J., Lucas, A.F., Jang, D. (2006). Responsible Gaming Device Research Report. International Gaming institute. University of Nevada, Las Vegas. Focal Research Consultants. (2007). Assessment of the behavioural impact of responsible gaming device (RGD) features: Analysis of Nova Scotia player-card data - the Windsor trial. Report prepared for the Nova Scotia Gaming Corporation. Retrieved November 14, 2007, from Hughes, J.C. & Cook, C.C.H. (2006). The efficacy of disulfiram: a review of outcome studies. Addiction, 92 (4), 381-395. Independent Gambling Authority (IGA). (2005). Inquiry into smartcard technology: Report. McDonnell-Phillips (2006). Australian National Survey of Gambler Precommitment Behaviour 2005. Commissioned by Gambling Research Australia. Neal, P., Delfabbro, P., & O’Neil, M. (2005). Problem gambling and harm: Towards a national definition. Commissioned for the Ministerial Council on Gambling. Prepared by the SA Centre for Economic Studies with the Department of Psychology, University of Adelaide. November 2005. Definition.pdf. Nisbet, S. (2005). Responsible gambling features of card-based technologies. International Journal of Mental Health & Addiction, 3(2), 54-63. Nowatzki, N. R., & Williams, R. J. (2002). Casino self-exclusion programmes: A review of the issues. International Gambling Studies, 2(1), 3 - 25. Omnifacts Bristol Research. (2007). Nova Scotia player card research project: Stage III research report. Retrieved May 30, 2007, from Parke, J. Rigbye, J., Parke, A. (2008). Cashless and card-based technologies in gambling: A review of the literature. December 2008. Commissioned by the U.K. Gambling Commission. Productivity Commission (2010). Australian Government Productivity Commission Inquiry Report. February 2010. Responsible Gambling Council (2008). From Enforcement to Assistance: Evolving Best Practices in Self-Exclusion. March 2008. Responsible Gambling Council, Toronto, Ontario. Responsible Gambling Council (2009). Play Information and Management Systems. Responsible Gambling Council, Toronto, Ontario. Ryan, P. (2010). Recent Global Developments in Player Pre-Commitment Policies to Reduce Problem Gambling. Presentation at the New Zealand International Gambling Conference 2010. February 26, 2010. Auckland, New Zealand. Schrans, T., Grace, J., & Schellinck, T. (2004). 2003 NS VL responsible gaming features evaluation: Final report. Report prepared by Focal Research Consultants Ltd. for the Nova Scotia Gaming Corporation, Halifax, Nova Scotia, October 2004. Retrieved August 12, 2006 (and URL updated February 26, 2009), from Williams, R.J., West, B., and Simpson, R. (2007). Prevention of problem gambling. In G. Smith, D. Hodgins, and R.J. Williams (eds.), Research and Measurement Issues in Gambling Studies. pp. 399-435. San Diego, CA: Elsevier. Williams, R.J., West, B., and Simpson, R. (2008). Prevention of Problem Gambling: A Comprehensive Review of the Evidence 2008. Report prepared for the Ontario Problem Gambling Research Centre, Guelph, Ontario, Canada. Dec 1, 2008. Williams, R.J. (2010). Peter A. Dennis & Zubin P. Noble versus The Ontario Lottery & Gaming Corporation (OLG). (Report on the effectiveness of casino self-exclusion.) Submitted to the Ontario Superior Court of Justice. Court File No.: CV-08-00356378-000. Date heard: Jan 13 – 15, 2010. Wood, R.T. & Williams, R.J. (2009). Internet Gambling: Prevalence, Patterns, Problems, and Policy Options. Final Report prepared for the Ontario Problem Gambling Research Centre, Guelph, Ontario. January 5, 2009.


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