Games whose outcome is determined by the skill of the player are generally legal; whereas, games whose outcome is determined by the laws of probability are illegal under the gambling laws of many States. In the penny falls game, the player begins by inserting a coin into the shooter. Coins of previous players are on the playing surface, which is periodically swept by an arm that moves the mass of coins toward the win chute at the bottom of the machine or to slots on the side which receive money for the machine owner. The ability of the player to direct the shooter toward certain spots on the playing surface and to stop the sweeper for a period of time give the illusion that the player can control the number of coins that fall into the win chute. In actuality, however, various impediments built into the machine ensure that the 'house' will win a certain percentage of the coins played, making penny falls a game of chance. 8 footnotes.