Re: November 14th: House Judiciary Committee Hearing Thread
 

Comment from the American Greyhound Track Operators Association: www.federalreserve.gov/SECRS/2007/November/20071108/R-1298/R-1298_26_1.pdf

It's 11 pages (plus 55 more pages of attachments), but the bottom line is that they are very concerned about overblocking, and they are requesting a definition to the term "unlawful Internet gambling".

Re: November 14th: House Judiciary Committee Hearing Thread
 

Chamber of Commerce comment, at http://www.regulations.gov/fdmspublic/component/main

[ QUOTE ]
The Chamber does believe, however, that the federal “good government” laws that regulate the regulatory process need to be adhered to regardless of the specific issues involved. Although these “good government” laws include the Regulatory Flexibility Act, the Information Quality Act, and Executive Order 12866 as amended, the Chamber writes specifically regarding the Paperwork Reduction Act (PRA) since the Chamber has been a strong supporter of the PRA from its inception. ... Thus, the Chamber strongly encourages you not to approve the proposed collection of information associated with the UIGEA unless and until it fully complies with all statutory requirements.

Sincerely,

R. Bruce Josten

[/ QUOTE ]

Re: November 14th: House Judiciary Committee Hearing Thread
 

I reviewed all the submitted UIGEA regulations comments and I didn't see any comments from 2+2 LLC or any of its authors. Maybe they already have and the comments have either not been published yet or were overlooked by me. If so, I hope someone from 2+2 LLC will post those comments here to motivate others to submit their comments. If not, I hope they will consider doing so -- as book publishers they have a legitimate business case for claiming harm by overblocking.

I recall BluffTHIS and others have mentioned here the importance of weakening the regs. As such, I'm sure they'll agree in the importance of 2+2 LLC submitting their comments. After all, even the Chamber of Commerce has commented in our favor.

Re: November 14th: House Judiciary Committee Hearing Thread
 

To comment:

Click here to comment at the FRB site
Click here to comment at the Treasury Dept site. Select "DEPARTMENT OF THE TREASURY*" at line 2 (the circled "2"), click submit, then click the comment icon to right of the UIGEA proposed rule.

To review sumbitted comments:

Clck here to view comments made to the Federal Reserve
Click here to read UIGEA regulations comments at the Treasury Dept site. Select "DEPARTMENT OF THE TREASURY*", click submit, then click the link to the far left of the UIGEA proposed rule ("TREAS-DO-2007-0015").

Re: November 14th: House Judiciary Committee Hearing Thread
 

November 23, 2007

Jennifer J. Johnson
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, DC 20551

Dear Secretary Johnson:

I am writing with comments for the proposed regulations for implementing the Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA). The current regulations as they stand now, would likely force financial institutions to block not only illegal internet gambling transactions as intended (sports gambling), but also many legal gambling transactions (skill games, horse racing, dog racing, and fantasy sports).

The UIGEA ,as originally written by gambling opponents, was intended to make illegal all wagering transactions in the United States. Congress did not pass this version of the bill, but a “watered-down” version that dealt with funding for what is already unlawful and not expanding the definition of unlawful. If the regulations as written stand, there would be in effect, a law against all gambling in the United States, which is not what was voted on and signed by the President. Gambling (other than sports gambling) is based on 50 different state laws, and it is unfair to the financial institutions and American citizens to have laws determined by the tens of thousands of banks interpretations.

Thank you for your consideration.

Sincerely,


"uglyowl"

Re: November 14th: House Judiciary Committee Hearing Thread
 

[ QUOTE ]
November 23, 2007

Jennifer J. Johnson
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, DC 20551

Dear Secretary Johnson:

I am writing with ....

[/ QUOTE ]

Very nice! I hope everyone here will follow your example.

Re: November 14th: House Judiciary Committee Hearing Thread
 

The funny thing is that the DOJ considers offtrack pari-mutual betting, horse and dogs, to violate the Wire Act. Ms. Hanaway claims that the BetOnSports case includes horse racing, but it is not mentioned in the complaint. The truth is that the DOJ have never prosecuted anyone for offtrack pari-mutual betting.
However, the Treasury could ignore the American Greyhound Track Operators Association comments on the grounds that it is not legally correct. But how can they ignore our comments that online poker is legal in most states when we can cite In Re Mastercard?
I submitted one comment on this matter when I suggested a definition of UIG. Now I may submit a comment seeking an exemption for online poker transactions unless they are in a state that expressly prohibits online gambling. Are partial repeat comments ok?

Re: November 14th: House Judiciary Committee Hearing Thread
 

[ QUOTE ]
The funny thing is that the DOJ considers offtrack pari-mutual betting, horse and dogs, to violate the Wire Act. Ms. Hanaway claims that the BetOnSports case includes horse racing, but it is not mentioned in the complaint. The truth is that the DOJ have never prosecuted anyone for offtrack pari-mutual betting.
However, the Treasury could ignore the American Greyhound Track Operators Association comments on the grounds that it is not legally correct. But how can they ignore our comments that online poker is legal in most states when we can cite In Re Mastercard?
I submitted one comment on this matter when I suggested a definition of UIG. Now I may submit a comment seeking an exemption for online poker transactions unless they are in a state that expressly prohibits online gambling. Are partial repeat comments ok?

[/ QUOTE ]

Correct. The DoJ claims all interstate Internet gaming is illegal per the Wire Act, but they don't bother enforcing this against pari-mutuels. It seems they've tried to have it both ways. That's why the DoJ doesn't want a definition for UIG....they like it this way. Hopefully implementation of UIGEA will drive a definition, either via clear regs or via legal challenges resulting from overblocking (banks are immune, but the federal government isn't).

It will be interesting to see how this plays out. It's great to see these disparate groups joining us in one manner or another. I'm glad we all took the time and effort to write to these businesses a few months ago. It's paying off now.

I did read your comment on both sites. Well done, thanks. I think it's fine to repeat the same questions in a different context.

Re: November 14th: House Judiciary Committee Hearing Thread
 

[ QUOTE ]
I reviewed all the submitted UIGEA regulations comments and I didn't see any comments from 2+2 LLC or any of its authors. Maybe they already have and the comments have either not been published yet or were overlooked by me. If so, I hope someone from 2+2 LLC will post those comments here to motivate others to submit their comments. If not, I hope they will consider doing so -- as book publishers they have a legitimate business case for claiming harm by overblocking.

I recall BluffTHIS and others have mentioned here the importance of weakening the regs. As such, I'm sure they'll agree in the importance of 2+2 LLC submitting their comments. After all, even the Chamber of Commerce has commented in our favor.

[/ QUOTE ]

Will someone here please PM or email Mason to ask him to submit a UIGEA comment on behalf of 2+2 LLC? Thanks.