[DeadMoneyDad]

[ QUOTE ]
"I never said we should not fight the regs by commenting between now and Dec 12th. "

Of course you did, in your BotCott thread lead paragraph:

"IMPO we shouldn't be lobbing Congress, the FED, or any agency on the proposed regulations."

Are you drawing some distinction now between "lobbying" an Agency and "commenting" on the Proposed Regulations ?

[/ QUOTE ]

Yes I am. IMHO the fight should not be on the government playground. To be honest I'd leave the fancy legal arguements to the group of lawyers the PPA and other major poker operators come up with. If in their opinion a massive comment might carry more weight than their single one, then they will let us know.

Personally I think getting out a response now on the proposed rule is foolish for a number of reasons. If for nothing else the last comments are perhaps the best as you get to read all the rest first before creating your response. It is classic proposed rule warfare 101 well perhaps 310.

Ultimately our comments do not carry as much weight as the Agencies are look for a creative solution from the banks and credit cards. Considering how many exemptions I read even with the rule I think we are better off than we were without it. Now a number of previouly blocked methods should work.

What I really mean is collectively we have more leverage with the banks than anyone else as we are direct consumers of the banks. Personally I think if we can find the right bank and hit the right pitch we might get a home run. If we get a banker of any size to agree that any potential class action for recovery of e-pass fees if the rule or law is overturned is worth telling the "agenices" to tell Congress "legalize" poker with the Wexler Bill or rewrite the UIGEA.

Considering that there is also the addition momentumn we might create for quick passage of a poker bill or exemption for skills game exemption, if for no other reason than to get us off their back is worth the effort. Now at least we have some number of bankers suggesting to their congressman/woman hey what's up with this damn poker group?

Can't you keep them from starting some damn class action suit?

If we get the smaller regional bank players involved where there are the numbers and leverage they might convince the majors for us.

I have said from the begining there are no extra points for speed in a proposed reg fight. A good well thought strategy, considering all the angles, that incorporates any good anti-our position with reasonable answers, while building as much support, and creating weakness or doubt in potential positions that even tacit aquisence, if worth the effort. That levarage point IMHO is throught the banks.

Aysemetrical warware.

Just one persons opinion and I am completely open to suggestions,


D$D