Ok, let's get technical. The (a) part of that law is written for casinos, not players, as it refers to dealing and operating games. The requirement is that the

Ok, let's get technical. The (a) part of that law is written for casinos, not players, as it refers to dealing and operating games. The requirement is that they do this knowingly. The casino didn't know. The operation of this game did not in any way deceive the public. No player was tricked. The operation of the game also did NOT alter the result of the game. The same side (banker/player) would have one irrespective of the rotated cards, as the rotation has no affect on gameplay and the outcomes are deterministic (no choices during play like in blackjack). All that was changed as a result of the extra knowledge was which side to bet on. The game itself was not affected in any way.