Twelve and thirteen together equal a strategy of manipulation that is clearly not acceptable to the CR group.
Do we know of any incidences where, without using a bonus, these terms were invoked? Not likely because the methods, when used together, are not EBM.
Granted, 13 should not be able to be used against a player if not in conjunction with another 'strategy', because it is incumbant upon the casino to set the wagering requirements and invocation of an FU clause like that, by itself, would be unfair BUT it is a term the player agrees to.
That said, I would agree with you that the existence or invocation of thirteen alone, without a bonus(and I understand it isn't delineated in the eCogra policy) would place the casino in a position of breaching the responsible gaming terms of their agreement with eCogra.
So, where do we go from here? Add another fifteen layers of legalese to the T&C? The casinos will continue to modify the bonus terms as long as bonuses exist. Isn't it better to simply know the HE and be a gambler and leave boni alone? I think so, but that's just me. It's called gambling, not 'strategy of manipulation to come out ahead'.
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