[Nortonesque]

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I think the problem is still going to be found in funding. UIGEA targetted payment processors,

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UIGEA targeted transfers to UNLAWFUL gambling sites. Since there is no rake etc, the presumption is that it IS lawful. Hence, no problem.

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The absence of a rake doesn't make it lawful. Whether or not it is lawful varies state to state and may not even be true at the federal level. You will get shut down pretty fast.