[TheEngineer]

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The funny thing is that the DOJ considers offtrack pari-mutual betting, horse and dogs, to violate the Wire Act. Ms. Hanaway claims that the BetOnSports case includes horse racing, but it is not mentioned in the complaint. The truth is that the DOJ have never prosecuted anyone for offtrack pari-mutual betting.
However, the Treasury could ignore the American Greyhound Track Operators Association comments on the grounds that it is not legally correct. But how can they ignore our comments that online poker is legal in most states when we can cite In Re Mastercard?
I submitted one comment on this matter when I suggested a definition of UIG. Now I may submit a comment seeking an exemption for online poker transactions unless they are in a state that expressly prohibits online gambling. Are partial repeat comments ok?

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Correct. The DoJ claims all interstate Internet gaming is illegal per the Wire Act, but they don't bother enforcing this against pari-mutuels. It seems they've tried to have it both ways. That's why the DoJ doesn't want a definition for UIG....they like it this way. Hopefully implementation of UIGEA will drive a definition, either via clear regs or via legal challenges resulting from overblocking (banks are immune, but the federal government isn't).

It will be interesting to see how this plays out. It's great to see these disparate groups joining us in one manner or another. I'm glad we all took the time and effort to write to these businesses a few months ago. It's paying off now.

I did read your comment on both sites. Well done, thanks. I think it's fine to repeat the same questions in a different context.