Mail order organizations purchase lottery tickets issued by the provincial governments and resell them to foreign purchasers through the mail or through subscriptions. There have been questions regarding the legality of such operations, however, two appeal court cases suggest that there remain serious obstacles to successful prosecution. Although, according to the law, only provincial governments can legally exploit gaming machines, there has been a proliferation of poker, bingo, and blackjack machines in recent years. Most machines are found in pubs and convenience stores. Because free game machines are legal, the gray area of cash payout machines has made enforcement difficult; however, a recent court decision may render the illicit gray area activities more controllable. Number combination sales, which promoters offer with a "money back guarantee" are very popular in Canada. While such schemes probably violate the "Criminal Code" since they contain the three elements of a lottery, to date, no criminal proceedings have been initiated against such promotions. 5 notes