Del. P.J.I. Crim. No. 11.1471(b)

PROHIBITED ACTS

In order to find Defendant guilty of Prohibited Acts, you must find the State

proved following two (2) elements beyond a reasonable doubt:

(1) Defendant [possessed/used/had] paraphernalia for the manufacture of

cheating devices; and

(2) Defendant acted [intentionally/knowingly.]

“Intentionally” means it was Defendant’s conscious objective or purpose to

possess, use or have paraphernalia for the manufacture of a cheating device.

“Knowingly” means Defendant was aware Defendant possessed, was using

or had paraphernalia for the manufacture of a cheating device.

"Cheating device" means any physical, mechanical, electromechanical,

electronic, photographic, or computerized device used in such a manner as to

cheat, deceive or defraud a video lottery machine or a table game. This includes,

but is not limited to, slugs, plastic, tape, string or dental floss which is placed

inside a coin or bill acceptor or any other opening in a video lottery machine in a

manner to simulate coin or currency acceptance, and is thereafter withdrawn, or

forged or stolen keys used to gain access to a machine to remove its contents, or

game cards or dice that have been marked, loaded or tampered with.

"Paraphernalia for the manufacturing of cheating devices" means the

equipment, products or materials that are intended for use or designed for use in

manufacturing, producing, fabricating, preparing, testing, analyzing, packaging,

storing or concealing a counterfeit facsimile of the chips, tokens, debit instruments

or other wagering devices approved by the State Lottery Office or lawful coin or

currency of the United States of America. This term includes, but is not limited to,

lead or lead alloy molds, forms, or similar equipment capable of producing a

likeness of a gaming token or United States coin or currency; melting pots or other

receptacles; torches; tongs, trimming tools or other similar equipment; and

equipment that can be used to manufacture facsimiles of debit instruments or

wagering instruments approved by the State Lottery Office.