John, it's been several years since I've seen the text of the Act, and I'm not aware of any court decisions which may have interpreted it since then.

I do recall obtaining the full text of the Act for the Club at the time, however. That was back when I was licensed to offer legal opinions and my opinion at the time was that the Act likely DID cover chips and tokens.

I was also of the opinion that it was unlikey the Federal government would ever consider a violation with respect to chips or tokens to be significant enough to follow up, unless a major casino's ox was being gored, or a State was losing significant revenue through counterfeiting.

Michael