Re: Proposed Comments to submit concerning UIGEA Regulations
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What do we gain by secrecy?
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Nothing.
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All our legal arguments, if needed after the regs are finalized, are already stated in the iMEGA and Kaplan cases. Are there secret ways to comment on proposed regulation that actually make a difference? For the record, I will be happy to contribute lots of comments. But don't ask me to be optimistic that all our comments will matter.
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We have to try. I'm glad you'll be there with us. We'll know more once the regs are released for comment.
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