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In the violation reports and the Department's Determination Letters, it is alleged that the Respondents violated S. C. Code Ann. §§ 12-21-3990 (A) (Supp. 1998) and 12-21-4030 (A) (Supp. 1998) by: (1) selling bingo cards to players for more than or less than their face value, not at the face value, (2) awarding "Bingo Bucks" in lieu of cash as the prize in a bingo game, (3) allowing the winner of a bingo game known as "Pop's Pick" or "Pick Six" to choose one envelope out of a number of envelopes after the play of a game, each envelope containing a set award of cash, and (4) allowing a player to trade an envelope won after a game for another envelope offered by the caller. Department seeks a monetary penalty of $500.00 jointly and severally against both Respondents, Greenville Lodge No. 858, The Benevolent and Protective Order of Elks and the promoter, Ramon J. Ashy. It asserts that the awarding of Bingo Bucks does not comport with any reasonable understanding of the word "prize"; that a prize must consist of a certain sum of cash or an item of merchandise.
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