Proposed Comments to submit concerning UIGEA Regulations

[DeadMoneyDad]

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What do we gain by secrecy? All our legal arguments, if needed after the regs are finalized, are already stated in the iMEGA and Kaplan cases. Are there secret ways to comment on proposed regulation that actually make a difference? For the record, I will be happy to contribute lots of comments. But don't ask me to be optimistic that all our comments will matter.

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As a hypothetical.

Lets say one of the "our" lawyers thinks if we can change a few words through brute force comments that makes the ultimate published rule easily defeatible in a court challenge... We don't want to post that idea in an open forum(the lawyers strategy), the brute force comments we plaster the receiving office with. Considering the review a reg gets in the administration this hypothetical is a little far fetched but not out of the realm of past history.

Some comments are open and public intended to raise the ire of the opposition into doing something stupid or forcing them to take an opposing position with more venom that in the end favors us. You've seen some of the stupid stuff that get printed in the various public exchanges like in the BW forum exchanges. Some of "our" comments were childish. Some of their arguments fall over on their own. Why shout obsenities when a reasoned wisper is more effective?

Some of our opponets positions we want them to win without a fight or second consideration of the ultimate value of their position, as it is advantagious to us, as helping them clairify their position to one of greater strength actually hurts us.

Again this is only a personal suggestion and purely hypothetical until the proposed rules are published.

Sometimes I loose arguments only to be proven right in time, sometimes I over think things, sometimes I am completely wrong........


D$D