IntraState Gaming and the Internet
Online Payments
When you make online payments to a website you have to be sure it is licensed and regulated in your country, otherwise you may be breaking the law.
When you make online payments to a website you have to be sure it is licensed and regulated in your country, otherwise you may be breaking the law.
Intrastate Gaming
White Paper Betting Gaming Barton Bill
Harry Platis makes submission to Ways and Means Committee for the Legalization of Internet Gambling.
Document Submitted to the Ways and Means Committee studing the legalization of Internet Gambling
Hearing on Tax Proposals Related to Legislation to Legalize Internet Gambling
Chairman Levin Announces a Hearing on Tax Proposals Related to Legislation to Legalize Internet Gambling Ways and Means Chairman Sander M. Levin today announced a full Committee hearing on tax proposals related to legislation to legalize Internet gambling. The hearing will take place on Wednesday, May 19, 2010, in the main Committee hearing room, beginning at 9:30 a.m. in 1100 Longworth House Office Building. In view of the limited time available to hear witnesses, oral testimony at this hearing will be from invited witnesses only. However, any individual or organization not scheduled for an oral appearance may submit a written statement for consideration by the Committee and for inclusion in the printed record of the hearing.
FOCUS OF THE HEARING:
The Committee will discuss the current tax laws and reporting requirements applicable to wagering in the United States. The Committee will consider tax and other proposals in the Committee’s jurisdiction related to legislation pending in the Congress to license and regulate Internet gambling activities.
BACKGROUND:
The Department of the Treasury (Treasury) has jurisdiction over various statutory provisions related to wagering and gambling. The Internal Revenue Service ensures compliance with the Federal excise and occupational taxes applicable to legal and illegal gambling activities. The taxes are 0.25 percent of the wager and $50 per year, if the wager is authorized under the State law where it is accepted, and 2 percent of the wager and $500 per year, if unauthorized under the State law. Pari-mutuel wagering, coin-operated devices, and state-conducted lotteries are exempt from taxation. In addition, individual and corporate income taxes, and third-party information reporting requirements, are applicable to income from gambling. Treasury’s Financial Crimes Enforcement Network (FinCEN) monitors compliance with the Bank Secrecy Act and certain other anti-money laundering laws. Under these laws, financial institutions, including casinos and money services businesses must file currency transaction reports and suspicious activity reports to assist the government in detecting and preventing money laundering, tax evasion, or other criminal activities. FinCEN has analyzed the potential regulatory and law-enforcement implications of electronic commerce, including Internet gambling.
The Unlawful Internet Gambling Enforcement Act (UIGEA) prohibits any person from knowingly accepting payments in connection with the participation of another person in unlawful Internet gambling. The regulations implementing the UIGEA were issued by Treasury and the Board of Governors of the Federal Reserve System last year and are scheduled to take effect on June 1, 2010.
In this and prior sessions of Congress, legislation has been introduced to license and regulate online gambling. Companion legislation, within the jurisdiction of the Committee, would impose gambling licensing fees and certain information reporting and other requirements.
Note: All Committee advisories and news releases are available on the World Wide Web at http://waysandmeans.house.gov.
Hearing on Tax Proposals Related to Legislation to Legalize Internet Gambling
“The Committee will discuss the current tax laws and reporting requirements applicable to wagering in the United States. The Committee will consider tax and other proposals in the Committee’s jurisdiction related to legislation pending in the Congress to license and regulate internet gambling activities.”
Pari-mutuel Wagering Proposal for the Ways and Means Committee “hearing on tax proposals related to legislation to legalize Internet gambling”.
Currently taxation on Pari-mutuel wagering, coin-operated devices, and state-conducted lotteries are exempt from taxation. My proposal is to consider an expansion of the laws to include Internet wagering on pari-mutuel events (including lotteries) and to exclude all exemptions regarding online pari-mutuel wagering so as to create tax revenues from online pari-mutuel wagers. I would suggest that tax revenues should be collected from any and all online pari-mutuel events that generate revenues within the United States (not necessarily by US citizens alone). I would also suggest a tax rate of one (1) percent for any and all online pari-mutuel bets to be applied (and removed) from each pari-mutuel pool.
How much will this proposal generate in annual tax revenues?
As an example I will consider pari-mutuel poker and the impact on tax revenues in one calendar year. There are tens of thousands of poker tournaments held in the United States and abroad that can be wagered on via the Internet as easily as one could bet on the Kentucky Derby (also online). The grand daddy poker tournament of them all is the World Series of Poker. It is a collection of 50+ poker tournaments that are held annually in the United States which offer over $250,000,000 in total prize money to the participants of the events. If Americans (and non Americans) were allowed to place an online wager on one or more of the World Series of Poker events using my pari-mutuel wagering system, such a system would yield an estimated $2,500,000,000 in bets (ratio of $10 bet for each $1 in prize money) for the World Series of Poker events. A 1% tax on those bets would generate $25,000,000 in additional tax revenues to the Federal Government for the World Series of Poker event alone.
I suggest that tax revenues be collected on Internet based pari-mutuel poker bets for any and all poker tournaments (both land based and Internet based).
I would also suggest that if you were to expand the number of online pari-mutuel wagers to include all possible pari-mutuel events across multiple sports and games (including lotteries) the estimated tax revenues (at a one percent taxation rate) would increase to over four billion dollars per year.
Kindly note that when the Federal Government legalizes Internet wagering (for pari-mutuel events) more and more people (from all countries) will purchase their lottery tickets, bet on their favorite pari-mutuel events, and enjoy the trust and security that a US regulated operator brings to the online pari-mutuel gaming industry. This applies to all Americans and non Americans who wager on the Internet. I believe that the regulation of Internet gambling will bring tens of millions of foreign gamblers to America to make their pari-mutuel wagers and such an inflow of activity will benefit all Americans via regulation and taxation.
Below is a table of estimated revenues across several pari-mutuel events:
Event Tax Rate Total Internet Wagering / yr Total Tax Revenues / yr
poker / online poker 1% $184,000,000,000 $1,840,000,000.00
billiards 1% $60,000,000,000 $600,000,000.00
lotteries 1% $85,673,600,000 $856,736,000.00
games 1% $10,000,000,000 $100,000,000.00
sports* 1% $145,574,400,000 $1,455,744,000.00
Total $485,248,000,000 $4,852,480,000.00
* excludes all wagering on horses, jai alai, and dogs.
How much would the Federal Government need to invest (or spend) in order to create these additional tax revenues?
The beauty of the pari-mutuel wagering system and software is that it would cost the Federal Government zero (0) dollars to create all these additional tax revenues. All the software and server requirements for this system have already been created and tested by Pari-mutuel Entertainment (and Harry Platis) over the past four and a half years. The software and program is available right now. The tax revenues could be made available immediately. There is no risk at all to the Federal Government and absolutely no downside potential as pari-mutuel wagering is a pool based betting system that does not produce any loss to the operator (and zero downside potential means positive tax revenues now and forever).
In fact the Nevada Gaming Board approved my (Harry Platis) concept to the degree that they have assigned me (Harry Platis) the opportunity for a provisional equipment license to go ahead with pari-mutuel event betting in the State of Nevada.
Canada is creating Internet gaming legislation and online gambling is a reality for several provinces.
In addition the Republic of South Africa has authorized Internet gaming and has granted me a patent for pari-mutuel wagering. It is only a matter of time that this concept will be implemented world wide. Why shouldn’t the United States of America, which allows pari-mutuel wagering on horses, jai alai http://en.wikipedia.org/wiki/Jai_alai and dog racing, lead the world in the regulation and taxation of all types of Internet based pari-mutuel wagering? I believe the world wants the United States to lead, regulate, and tax, all forms of Internet wagering.
There is absolutely no risk to the Federal Government in implementing my patented pari-mutuel software and in so doing change the landscape of Internet wagering to the benefit of all Americans for generations to come. I look forward to helping the Federal Government generate billions of dollars from Internet wagering.
Who benefits from the Legalization of Internet Gambling?
Regarding who ultimately benefits from the legalization of Internet Gambling and the taxation and regulation of online pari-mutuel wagering, there is no doubt that every American would benefit from the regulation and taxation of pari-mutuel based Internet wagering. More than that, all those folks who wager via the Internet would be sure that they got paid when they won, and they would get the best odds going for the events that they wagered on. No system can compete with a pari-mutuel wagering system as it relates to event odds and payout terms. The pari-mutuel system can self adjust to offer the best odds going on any given event bar none.
Other entities that would benefit from the regulation and taxation of Internet wagering would be all those who provide advertising for all pari-mutuel events. Start with the search engines Google, Yahoo, and Bing. I would advertise heavily across all pari-mutuel related events and pay the search engines per click for all the traffic sent to our websites. Currently they do not make money from online gambling related keywords and that would change the moment I could offer the pari-mutuel wagering system to the world. I would also advertise on television and in Newspapers, and on the radio, and in all places that relate to any form of wagering at all. Not only does the legalization of Internet Gambling produce revenues to the Federal Government but it would also produce massive revenues to all advertising mediums across the United States, creating jobs and great share holder value to those entities who provide advertising, particularly online advertising.
There is no doubt that I too would benefit from the implementation of my pari-mutuel software for Internet based gambling. Please note that I would also allow the Internet to market my pari-mutuel offering via affiliate relationships so that in fact I would be helping all Internet marketing people monetize their efforts.
Finally, and most importantly, the use of pari-mutuel wagering and the regulation of Internet gambling would turn the entire Internet Gambling industry upside down from one that is controlled by offshore entities to one that is regulated and taxed for all Americans. That is the goal here with the pari-mutuel software and submission to this committee.
Yours respectfully,
Harry Platis,
16300 Mill Creek, Suite 105
Mill Creek, WA 98012
Phone: 425-776-3888, Cellular phone: 206-999-6655
Toll Free: 1-800-245-3777, Fax: 206-973-5335
Website(s):
Email: hplatis @ gmail.com
Pari-mutuel Revenue Estimation:
Look at STATEWIDE ALL NON RESTRICTED LOCATIONS for the Month of March, 2011 you will note that the reported gaming revenue in the State of Nevada was $909,845,000.
------------------------------------------------------------------------------------------------------------
Taxable Revenue by Area
3/01/11 to 3/31/11 1/01/11 to 3/31/11 4/01/10 to 3/31/11
Taxable % Taxable % Taxable %
County/Area Revenue Range Revenue Change Revenue Change Revenue Change
STATEWIDE ALL NONRESTRICTED LOCATIONS 909,845 -2.35 2,634,125 -0.39 9,684,387 -0.44
$1,000,000 AND OVER REVENUE RANGE 904,466 -2.31 2,620,274 -0.24 9,622,503 -0.28
CARSON VALLEY AREA ALL NONRESTRICTED LOCATIONS 8,617 0.85 24,301 2.64 102,327 1.86
$1,000,000 AND OVER REVENUE RANGE 8,442 2.28 23,807 4.56 99,784 2.70
CHURCHILL COUNTY ALL NONRESTRICTED LOCATIONS 1,929 5.22 5,171 -0.95 20,119 -3.16
CLARK COUNTY ALL NONRESTRICTED LOCATIONS 785,275 -1.40 2,280,039 0.38 8,208,539 0.20
$1,000,000 AND OVER REVENUE RANGE 782,700 -1.35 2,274,118 0.52 8,179,047 0.36
CLARK COUNTY DOWNTOWN LAS VEGAS AREA ALL NONRESTRICTED LOCATIONS 49,563 0.16 129,987 0.38 493,064 -4.12
$1,000,000 AND OVER REVENUE RANGE 49,357 -0.52 129,101 0.50 490,093 -4.09
$1,000,000 TO $12,000,000 REVENUE RANGE 2,424 -39.32 6,024 -44.55 30,678 -28.95
$12,000,000 AND OVER REVENUE RANGE 46,933 2.87 123,077 4.66 459,414 -1.79
CLARK COUNTY LAS VEGAS STRIP AREA ALL NONRESTRICTED LOCATIONS 476,845 -1.45 1,441,074 0.90 5,081,393 2.56
$1,000,000 AND OVER REVENUE RANGE 476,378 -1.51 1,441,101 0.92 5,078,251 2.64
$12,000,000 TO $36,000,000 REVENUE RANGE 15,157 5.97 37,681 -2.88 149,697 -7.38
$36,000,000 TO $72,000,000 REVENUE RANGE 46,853 24.68 121,400 15.95 393,108 -0.09
$72,000,000 AND OVER REVENUE RANGE 413,196 -3.92 1,275,806 -0.31 4,514,033 3.24
CLARK COUNTY NORTH LAS VEGAS AREA ALL NONRESTRICTED LOCATIONS 27,452 -2.54 75,018 3.27 270,213 -2.99
CLARK COUNTY LAUGHLIN AREA ALL NONRESTRICTED LOCATIONS 51,053 -3.21 132,579 -3.26 478,129 -1.74
CLARK COUNTY BOULDER STRIP AREA ALL NONRESTRICTED LOCATIONS 74,662 -1.33 208,603 0.76 756,447 -4.67
CLARK COUNTY MESQUITE AREA ALL NONRESTRICTED LOCATIONS 11,926 -0.23 32,545 0.29 115,896 -1.73
CLARK COUNTY BALANCE OF COUNTY ALL NONRESTRICTED LOCATIONS 93,773 -0.83 260,233 -1.65 1,013,397 -3.17
$1,000,000 AND OVER REVENUE RANGE 92,543 -0.69 256,842 -1.58 999,572 -3.12
DOUGLAS COUNTY SOUTH SHORE LAKE TAHOE AREA ALL NONRESTRICTED LOCATIONS 15,397 -37.77 47,243 -17.34 202,219 -9.33
ELKO COUNTY ALL NONRESTRICTED LOCATIONS 23,863 1.59 68,273 -0.04 258,875 -1.37
ELKO COUNTY WENDOVER AREA ALL NONRESTRICTED LOCATIONS 14,643 -2.10 42,782 -4.87 162,027 -2.87
ELKO COUNTY BALANCE OF COUNTY ALL NONRESTRICTED LOCATIONS 9,220 8.06 25,491 9.25 96,848 1.24
HUMBOLDT COUNTY ALL NONRESTRICTED LOCATIONS 2,078 16.32 5,475 18.90 21,334 14.77
LYON COUNTY ALL NONRESTRICTED LOCATIONS 3,701 12.35 10,034 0.62 40,099 1.45
NYE COUNTY ALL NONRESTRICTED LOCATIONS 4,882 0.78 13,453 3.26 51,140 -1.97
WASHOE COUNTY ALL NONRESTRICTED LOCATIONS 62,110 -4.27 174,992 -5.91 757,806 -4.75
$1,000,000 AND OVER REVENUE RANGE 61,047 -4.53 171,731 -6.05 746,443 -4.63
WASHOE COUNTY RENO AREA ALL NONRESTRICTED LOCATIONS 44,771 -5.30 126,696 -5.95 552,185 -3.68
$1,000,000 AND OVER REVENUE RANGE 44,332 -5.64 125,322 -6.29 548,313 -3.65
$12,000,000 TO $36,000,000 REVENUE RANGE 6,904 -9.25 19,249 -5.30 84,910 -5.30
$36,000,000 AND OVER REVENUE RANGE 35,841 -3.26 101,678 -5.11 442,687 -2.22
WASHOE COUNTY SPARKS AREA ALL NONRESTRICTED LOCATIONS 11,156 3.13 29,815 -4.19 120,799 -8.57
$1,000,000 AND OVER REVENUE RANGE 10,953 3.57 29,262 -3.70 118,785 -8.41
WASHOE COUNTY NORTH SHORE LAKE TAHOE AREA ALL NONRESTRICTED LOCATIONS 1,708 -14.15 5,647 -7.79 27,374 -4.66
WASHOE COUNTY BALANCE OF COUNTY ALL NONRESTRICTED LOCATIONS 4,475 -6.73 12,835 -8.54 57,448 -6.59
WHITE PINE COUNTY ALL NONRESTRICTED LOCATIONS 803 26.60 2,054 22.30 8,162 6.98
BALANCE OF COUNTIES ALL NONRESTRICTED LOCATIONS 1,191 -2.60 3,090 -7.91 13,765 -6.91
$1,000,000 AND OVER REVENUE RANGE 945 6.35 2,458 0.06 10,383 -2.21
Page A-01
Taking the month of March 2011 as the base of activity the total reported gaming revenue in the State of Nevada was $909,845,000. We use this reported gaming revenue number and an estimated profit margin in order to extrapolate the total handle in the month of March 2011, that is to say, the total aggregate wagered. Why are we so interested in the amount wagered? Our interest in the total dollar amount wagered is the demand for gaming, and our intention is to estimate the total demand for gaming world wide, and the corresponding demand for Internet gaming (assuming that Internet Gambling is licensed and legal in America).
How did I figure out aggregate gaming total for the State of Nevada? What I did was to take the total profits in the State of Nevada ($909,845,000 for March 2011) and using an average margin figure of 3% I calculated the total handle in Nevada in the month at $30,328,166,667. Note that there is an inverse relationship between the margin and the total handle, so if the margin was 2.5% the total handle would rise significantly in order to maintain profitability. The Nevada handle was approximately $30.328 billion dollars. This figure does not factor in all the betting in every Casino in the U.S.A., or any non regulated betting, so I assumed that the grand aggregate total dollar value of bets across the USA (legal and illegal) is approximately twice the Nevada total for any given month. This is why I use $60.656 billion as a total approximate aggregate total handle for the month of March, 2011 for the USA aggregate demand alone. Because of the fact that our estimated revenue data uses global demand I used the USA aggregate total as a proxy for world demand and assumed that all other wagering in the world was twice the total in the USA for any given month (or period of time). So for March of 2011 data the world aggregate demand was $121.312 billion dollars. This world total demand is the total handle of land based legal and illegal gaming that occurred in the month of March 2011. In other words Americans make up half the total dollars wagered world wide in a land based environment. I have been told that although the rest of the world is betting more every day, nevertheless, North Americans still make up at least half the total aggregate demand for land based gambling. As such it is not unreasonable to estimate the total world wide demand for land based gaming at $121.312 billion a month (based on March 2011 data). This works out to $1.45574 trillion in total estimated world wide wagering demand for a year. This assumes March to be an average month, not higher, and not lower, than any other month. Our contention is that this aggregate demand for land based overall gaming is still growing as more and more games of chance are offered to people in a land based establishment. This we believe will tend to drive the demand even higher. Yes there are those that claim that Indian and Nevada casino revenues are down year over year, while we contend that the total handle, in Nevada, in every Indian casino, in casinos in Macau, and in every “new” gaming establishment world wide is still rising, that is to say, total aggregate demand.
2 - I have assumed that Internet wagering will total roughly 1/3rd the aggregate total of all land based wagering as soon as it is legal in America. The point here is that foreigners would rather bet in a US Regulated Internet Gaming site as compared to any other jurisdiction world wide (yes even more than British online gaming sites). As such I believe that total Internet based gambling will hit a massive $485,248,000,000 as soon as the USA legalizes online gambling. According to Ipsos Reid (see page 11 reference), the game of choice over the Internet is Poker at 38% of the total handle. This means that online poker total action is estimated to be a $184 billion dollar market world wide the moment it is legal in America. This could explain why the Government clamped down on Pokerstars, FullTiltPoker, Ultimate Bet, and Absolute Poker. It is big business and big money from a tax creation perspective. At a 3% rake this market is worth over $5 billion dollars a year. The next biggest gaming interest for online gamblers is sports betting, and that represents 30% of all bets, or some $145,574,400,000. Yes indeed sports betting is huge online compared to action in a land based casino. Perhaps the simplicity of betting online and the privacy of betting in your home and getting some action on a live sporting event is something that makes online sports betting so huge. In land based environments betting on sporting events or tournaments is not that popular, however, betting on a live event using pari-mutuel wagering, say a live pool tournament or a live poker tournament, one has the ability to make a lot of very exotic bets that traditional bookmakers cannot figure out how to rate, which makes pari-mutuel wagering even more appealing to the operator and to potential punters.
So in calculating my data I used land based gaming statistics from Nevada and presumed how the rest of North America wagers. Once I had that data I calculated how the rest of the World gambles in relation to America, and now we have an aggregate demand for land based gaming world wide. I am confident that my data will be accurate and that the total aggregate number for online gambling will be in the hundreds of billions of dollars the moment America legalizes it. How much of the $145 billion bet on sporting events and tournaments could be handled using my pari-mutuel wagering system is still open to debate. I contend that in order to give a pure handicapping and best odds going in any event or tournament pari-mutuel wagering systems is the only way to go.
3 – My pari-mutuel wagering concept will focus on the best odds and the best payments for all players. Furthermore my pari-mutuel wagering system can setup lines for any event where there are two people who want to bet on that event (and take opposite sides). Given that my pari-mutuel system has no risk to the operator and guaranteed tax revenues to the government (never negative) therefore we can run our wagering pools on the smallest of smallest of margins and still generate huge sums of profits and potential tax revenues. Not only that we can provide real time odd (or line) comparisons to bettors but we can also create a line instantly and over time the real handicappers will notice that they get a better bang for their buck with our pari-mutuel wagering system and as such they will tend to prefer to bet using our system. Remember it is riskless to the house so there is never an event that can generate a loss – never! My system is simple. My system is quick. And best of all the pari-mutuel system is idiot proof, and hack proof. There is no doubt that the expected return on a bet made in a pari-mutuel wagering system is higher (to the gambler) than a bet made at a bookmaking line (where a risk needs a premium). This is the difference between pari-mutuel betting systems and bookmaking lines. Yes we can guarantee the best odds world wide on every tournament, event, and activity, bar none. Everyone who bets over the Internet will confirm that non American gamblers would rather bet through an American regulated company (trust factor) as compared to any other entity world wide. We will be known as the system that pays on time all the time.
All this to say if our annual aggregate estimates of total action over the Internet is correct and if we can get a license to operate in America (and offer our action to the world) well then we will get a large chunk of not only the pari-mutuel action, but the poker action as well. An American regulated online gaming website is nothing short of a money printing press, and we are talking big money.
Research Shows Canadians like to play poker online.
May 19th, 2011
A recently released study by Ipsos Reid and by the Canadian Gaming Association regarding the unregulated Internet Gambling market:
• The GamblingData Core Estimate: According to the Canadian Gaming Association, a gambling industry trade group, the country’s unregulated Internet gambling market currently generates around C$1bn in revenues, annually. In comparison, a report from market research firm Ipsos on online gaming deposit levels published in April 2010 estimated C$868m of deposits and a participation rate of 8 percent of Canadian adults.
• The Unregulated Internet Gambling Market: The Ipsos survey provided some picture on which products Canadians are gambling. Among respondents who gambled online at least once a year, 38 percent played poker, making it the most popular product. Next is sports at 30 percent, then comes skill games at 28 percent, casino slots, bingo and raffle tickets at 26 percent each, and casino table games at 23 percent. Horse race betting follows up at 20 percent of players.
• Expansion of Regulated Internet Gambling Continues Apace: In recent years, provincial lottery corporations in British Columbia, Ontario and Quebec have begun to broaden aggressively their online footprints. The British Columbia Lottery Corporation, though, has led the way and in July 2010 launched the first government-run Internet casino in North America.
• Growth in Land-Based Gaming Stalls: In FY2010, five consecutive years of growth in land-based gaming ground to a halt. According to the Canadian Gambling Digest, total revenues from government-run gaming in FY2010 were down 2.3 percent versus FY2009. Likewise, total revenues from horse racing in FY2010 were down 9.6 percent relative to FY2009. Total revenues from charity-run gaming in FY2010, however, were up 3.2 percent compared to FY2009.
VIA FACSIMILE AND U.S. MAIL
Dennis K. Neilander, Chairman
Nevada State Gaming Control Board
555 East Washington Avenue, Suite 2600
Las Vegas, Nevada 89101
Re: Application Letter for Approval of Wagering on Certain Events
Pursuant to NGC Reg. 22.120(1)(e) and A.B. 218 (Enacted)
Our File Number: 100370-001
Dear Chairman Neilander:
As you may recall, we represent Harry B. Platis ("Mr. Platis"), a well-respected Washington attorney and gaming visionary. Specifically, for the last few years, Mr. Platis has been diligently pursuing his dream of making pari-mutuel wagering possible on various regulated and competitive events (specifically, poker, blackjack, baccarat, roulette, craps, and slot tournaments) held in Nevada and elsewhere by casinos and their affiliates. In the past, Nevada race and sports books have, of course, limited their wagering activity to horse races and athletic sporting events, pursuant to NGC Reg. 22.120(1)(e).
At the same time, with regard to poker and many of the other events referenced above, it is not an exaggeration to say that many of these events and tournaments are so popular they are virtually on fire. By proposing wagering on these new types of tournaments at Nevada sports books, Mr. Platis hopes to harness their popularity for the benefit of the Nevada gaming industry and the State of Nevada. For example, under Mr. Platis's proposal, a person at a Nevada sports book could now wager on Chris Moneymaker winning the World Series of Poker Tournament.
In Regulation 22, the Commission has already defined a "sports pool" as "a business that accepts wagers on sporting events and other events." NGC Reg. 22.010.20 (2008) (emphasis added). In continuing discussions that Jeff Silver has had with Member Sayre, we have been anticipating a change in the law that would provide the regulation with appropriate statutory support to permit wagering on other activities. With the enactment of A.B. 218 on June 3, 2009, the Nevada Legislature has expressly endorsed that Commission definition, as well as provided a specific mandate. See A.B. 218 (Section 3). In particular, with the enactment of A.B. 218, the Nevada Legislature has expressly clarified that permissible games, events, and tournaments on which wagers might be accepted at Nevada sports books could include those "other events" that are currently proposed by Mr. Platis and not just strictly athletic "sporting events." See id.
Specifically, we believe that A.B. 218 now allows the gaming industry and the Board to be as innovative in the sports book area as they can be on the casino floor. For example, when a new type or style of wagering device is introduced by a licensed manufacturer for the casino floor, it merely requires technical approval. In sharp contrast, the sports book regulations, without the additional permission for wagering on "other events" (as now expressly set forth in A.B. 218), have been less susceptible to timely innovation for wagering on new types of events and tournaments. This is a shortcoming that has now been remedied with the enactment of A.B. 218.
In particular, pursuant to A.B. 218, the gaming industry can now be as innovative in the sports book area as they have been on the casino floor. This opportunity for new innovation will undoubtedly come at a time when it is desperately needed by our state. Accordingly, pursuant to NGC 22.120(1)(e) and A.B. 218, we respectfully seek a "waiver" or "determination" that poker, blackjack, baccarat, roulette, craps, and slot tournaments are all "other events" on which wagering can now be readily accepted at Nevada sports books.
Thank you for your kind consideration.
Very truly yours,
GORDON SILVER
LOUIS V. CSOKA, ESQ.
LVC/cji
cc: Randall E. Sayre, Member
Mark A. Lipparelli, Member
The Future of all Internet Gaming will emerge from Intrastate Gaming.
Can Iowa make intrastate poker work?