[TheEngineer]

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TE, I like your comment.

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Thanks.

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However, I have a question. Should our comments be general in nature like your comment or concern specific parts of the proposed regulations and the discussion on them like the one that I posted?
Also, is it wise to suggest that the Agencies define the term unlawful internet gambling? They might not use your excellent definition but one unfavorable to us. Also, the Agencies might then use their interpretation to develop the list of unlawful internet gambling busineses. I thought that you wanted to keep the regulations vague to avoid litigation over them.

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I'll be submitting many comments. Many will attack specific parts of the regs.

As for the definition, if they were going to include poker, they would have already, I think. After all, poker is the only offshore Internet gaming that still operates in the open, with commercials (at least for the .nets). Surely they'd be the regs' first target if the Treasury Dept felt they could. I don't want litigation at all (and I certainly don't want the definition to go against us), but I do want to demonstrate that we don't fear a definition.

I also want to express our need to stop banks from overblocking, which is a big risk for us. Keeping the vague definition while getting overblocking protection would not be a bad outcome at all.