[superpokermon]

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#2 is a terrible idea. You certainly *don't* want the regulations to spell out what 'unlawful' gambling is - what happens if they take you up on it and reach a conclusion you don't like? Up until the WTO matter is dealt with, I'd like my online poker gray, not black, thanks. Keep in mind that a bad result will have to be litigated in court by somebody whose bank account is directly affected, possibly even in every appellate circuit.

#1 has the same problem; you and I may think this, but, if pressed, the regulators could very well come to the exact opposite conclusion.

#3 and, to a lesser extent, #5, are the arguments that should be focused on. Don't ask the regulation drafters to come up with their own interpretations; instead, delay them and/or point them to existing case law. This is a much, much better approach than relying on people who likely know nothing about poker to decide whether it's a game of skill.

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These are good points, and I urge the PPA to take these points into consideration and revise the talking points. The regs, as currently written are not that strong. Asking for things such as clear definitions could cause them to be made stronger. The regs are fairly weak right now, let's not encourage the DOT to fix them so they actually mean something.