[BluffTHIS!]

Milton,

Thanks for your further explanation that the important distinction here is whether the membership is secret or known. That along with your Costa Rica reference implies what is behind the curtain. Which is either a group of sports-betting concerns who cannot come into the limelight, or some poker site affiliates who don't wish to either. The shame is that this is the perfect type of suit to be litigated by the sites themselves (and the PPA).