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On May 6, 2009, Representative Barney Frank (D-Mass.), with a little help from his friends, introduced three bills in Congress that would legalize, regulate and tax Internet gambling in the United States. They would allow licensed operators to run online poker games, casinos, lotteries, parimutuel racing and bingo, but not sports betting. Bets could be accepted from players from every state, unless a governor sends a notice to opt out within 90 days of the bills becoming law.
The bills appear to, and do, create a federally regulatory system under the Secretary of the Treasury. But their true goal is for operators to be licensed and controlled mostly by a single state, Nevada. There would also be enormous opportunities for federally recognized tribes, if they acted quickly enough. And a few overseas sites may eventually also be allowed to legally take bets from some states.
On August 6, 2009, Senator Robert Menendez (D-NJ) introduced his proposal to legalize Internet gambling. The bill, S.1597, is similar to the Frank bills, in its basic structure, although it differs in some important details.
More recent attempts in Congress to expand Internet gambling have come from Senators Ron Wyden (D-OR) and Judd Gregg (R-NH), who filed their proposal in February 2010. Called the Bipartisan Tax Fairness and Simplification Act of 2010, S.3018, includes provisions to regulate, as well as tax, online gaming.
And Rep. Jim McDermott (D-WA) in March filed HR4976, his Internet Gambling Regulation and Tax Enforcement Act of 2010.
All this movement in Congress has led many investors to become optimistic about the return of foreign online poker operators, who abandoned the U.S. market after the passage of the Unlawful Internet Gambling Enforcement Act (“UIGEA”) in 2006. But the bills all have provisions that make it difficult for their foreign competition to continue or reenter the U.S. market. Only the Menendez bill, which has no-cosponsor at this time, would expressly reopen the U.S. door to foreign operators.
It has been said that politics is the art of the possible, or the art of compromise. This reminds us that laws are made by men and women, and committees.
The truth is that almost no one in Congress cares about Internet gambling. So, decisions about what to do about it are not often the result of reasoned conclusions made after careful study.
The UIGEA is the worst example. This bill was rammed through Congress by a failed politician, then-Majority Leader of the U.S. Senate, Bill Frist (R.-TN). Frist planned to run for President and wanted to gain points with a then-powerful Congressman from Iowa, Jim Leach (R.-IA), who actively opposed Internet gambling. Because almost no one else in the Senate cared either way about the issue, Frist had a problem. He couldn’t get a prohibition bill to the floor for a vote. So, Frist added his Internet gambling Act to a completely unrelated bill dealing with port security. In a cynical move, he risked the safety of the U.S. in its war against Islamist terrorists to show his right-wing religious base that he opposed gambling.
The House of Representatives had already passed the port bill. Frist hand-picked a Senate-House Conference Committee to add his pet Internet gaming bill as an amendment. According to Sen. Frank R. Lautenberg (D-NJ), who, of course, has an interest in bills affecting gaming, Frist refused to let any Democrat on the Senate-House Conference Committee see the final language of the bill, called the report.
Conference reports cannot be amended, so members of Congress could only vote against this proposed ban on Internet gaming by voting against the SAFE Port Act. The vote came up at literally the last minute, after midnight, immediately before Congress recessed for the 2006 elections.
The irony is that Frist couldn’t even keep both houses of Congress from falling to the Democrats, and never came close to getting the Republican nomination for President. And Leach lost his seat in a surprise upset to a Democrat; the slim margin of his defeat could have come from online poker players, motivated to vote against Leach for taking away their favorite activity.
Today, there are few people left in Congress who even follow online gaming. A couple of conservative Republicans, like Rep. Frank Wolf (R.-VA), still feel strongly that all gambling should be outlawed. Jon Kyl (R.-AZ), with the longest record in opposition, is still in the Senate and still opposes Internet gambling. When Congress approved a six-month delay in implementing the UIGEA regulations, Kyl even went so far as to block an uncontroversial Treasury appointee from being approved. However, Kyl is from Arizona, where Indian casinos have grown very rich and politically powerful; so he is not against all gambling, which makes his position look hypocritical.
But the elections of 2006 and 2008 have changed the political dynamics of Congress. The Democrats have the Presidency and both houses of Congress. The Republican Party and the far right have decided that they will oppose everything that might make President Barack Obama look good.
If the Democrats can get organized, particularly in the Senate, they still can get legislation passed. President Obama may be personally opposed to legal gambling, although he plays poker, but he knows he needs states like Nevada to win elections. He certainly would never veto a bill to regulate and tax gambling passed by the Democratic Congress. But he isn’t really interested in Internet gambling.
In fact, almost no one in a position of power cares about the issue. As a strange coincidence, two of those who do are in positions of great power: Barney Frank is the powerful chairman of the House Financial Services Committee, and Harry Reid (D.-NV), who represents Nevada, is the Majority Leader of the Senate.
Frank, one of the first openly gay members of Congress, is viewed as a left-wing liberal. But he is really a libertarian when it comes to government intervention in private lives. He feels the federal government in particular should not be deciding what people do in the privacy of their own homes.
Frank has so much seniority, and the Democrats have such an overwhelming majority, that he can get any bill he wants through the House of Representatives. But to become law, the bill also has to pass the Senate.
Reid claims he is personally opposed to Internet gambling. But he is deeply unpopular in his home state and in political trouble, so more than ever he needs the contributions of Nevada casinos. And at least a few Nevada gaming companies, especially Harrah’s, want to run the games themselves.
Frank’s many co-sponsors in the House – 68 as of this writing – include people like Robert Wexler (D.-Fl.), who feel that Internet poker should be made legal. But they also include Shelley Berkley (D-Nev.), the former national director for the American Hotel-Motel Association, who represents the city of Las Vegas and the adjacent Las Vegas Strip. He has gotten powerful, bi-partisan support, in the House, with backing by Peter King (R-NY), top Republican on the Homeland Security Committee, and the Chairs of the Judiciary, and Education and Labor, Committees, John Conyers (D-MI) and George Miller (D-CA).
The Wyden-Gregg Tax bill contains most, if not all, of the provisions of the Frank bills. It is a companion bill to the measures introduced by Frank and friends in the House of Representatives. This is the common way laws are made in Congress: Similar bills are discussed simultaneously in the two houses and then reconciled in conference committee. It makes everything go faster and neater.
So, it is possible that an Internet gaming bill will pass this summer, before the November 2010 mid-term elections.
If it doesn’t, the chances for a partial repeal of the UIGEA depend upon whether Harry Reid gets reelected, and remains Majority Leader, since he is one of the few senators who cares enough about the subject of gambling to keep the issue alive. If the Republicans gain control of either house, or even gain a significant number of seats, they will see their strategy of becoming the party of “No” as a success. All legislation in Washington, DC, will come to a complete stop, obviously including legalizing online gaming. Only if Reid keeps his position, and the Democrats regain their 60 seat super-majority in the Senate, or get the courage and political unity required to kill the filibuster – events which seem highly unlikely at this time – would a federal Internet gaming bill pass in 2010 or beyond.
If Frank and Reid do push legalization through in mid-2010, there would then be many months more before implementing regulations are promulgated. After that happens, gamblers in states like Utah will still not be able to make bets online. But residents of California, New York and probably even Texas may have the right to play poker and other games for real money on the Internet, without having to worry whether they, or the operators, are breaking federal law.
Frank knows how to get bills passed. He gave the first, HR 2266, the imposing name, the “Reasonable Prudence in Regulation Act,” although all it actually would do is delay implementation of one minor set of regulations. Under the UIGEA, federal agencies issued rules to make it difficult for financial institutions to send money for illegal online gambling. The regulations were supposed to go into effect on December 1, 2009. This bill would have delayed them for one year. Even though it has not yet passed, Frank, with help from Reid and even the Republican leadership, responding to pressure from banks, got Treasury and the Federal Reserve to delay the regulations for six months to June 1, 2010. (Later Reid and Treasury Secretary Timothy Geithner gave in to threats from John Kyl to hold up more appointments to Treasury and promised they would not delay the regs any further.)
HR 2267 is the heart of Frank’s proposal. It would amend current statutes to “provide for the licensing of Internet gambling activities by the Secretary of the Treasury, to provide for consumer protections on the Internet, to enforce the tax code, and for other purposes.” As if that weren’t clear enough, Frank named the bill the “Internet Gambling Regulation, Consumer Protection, and Enforcement Act.”
But, the federal government has no experience or expertise in regulating gambling. The closest it has ever come are parts of the Indian Gaming Regulatory Act (“IGRA”). Public policies toward gambling, including questions of prohibition or regulation, have always been left up to the individual states. Even IGRA says that tribal gaming is limited to states where that particular form of gambling is permitted.
In fact, IGRA can be considered a rough model for the Frank proposals and the Wyden-Greg Tax bill. Under IGRA, a federal agency, the National Indian Gaming Commission, has some power to oversee Class II gaming, meaning bingo and non-banking card games like poker. Class III gaming, including casinos, lotteries and racing, are primarily regulated pursuant to agreements between states and tribes, with little federal involvement.
A similar system would be set up under the proposals pending in Congress. Although the Secretary of the Treasury would technically be issuing licenses, good for five years, HR 2267 and its counterpart have these neat little provisions:
Any State or tribal regulatory body with expertise in regulating gambling may—
(i) notify the Secretary of its willingness to review prospective applicants to certify whether any such applicant meets the qualifications established under this subchapter; and
(ii) provide the Secretary with such documentation as the Secretary determines necessary for the Secretary to determine whether such State or tribal regulatory body is qualified to conduct such review and may be relied upon by the Secretary to make any such certification.
The bills then give the Secretary only 60 days to determine whether he should rely on these state or tribal regulators in issuing licenses for Internet gambling operators:
RELIANCE ON STATE OR TRIBAL CERTIFICATION – Any applicant may provide a certification of suitability for licensing made by any State or tribal regulatory body . . . together with all documentation the applicant has submitted to any such State or tribal regulatory body, to the Secretary, and any such certification and documentation shall be relied on by the Secretary as evidence that an applicant has met the suitability for licensing requirements under this section.
It would be more than a little embarrassing if the federal government said that a well-established regulator, like the Nevada Gambling Control Board, is incompetent. But the bill clearly gives tribes the same power, if they start now in creating a record to show they have “expertise in regulating gambling.”
In fact, under the Frank bills and its counterparts, the federal government will end up doing nothing, except for a little unnecessary duplication of effort to make it seem like there is federal oversight:
RELIANCE ON QUALIFIED REGULATORY BODY FOR OTHER PURPOSES — At the discretion of the Secretary, the Secretary may rely on any State and tribal regulatory body found qualified under this subsection for such other regulatory and enforcement activities as the Secretary finds to be useful and appropriate to carry out the purposes of this subchapter.
As for the other states, where the patrons will be, the bill does allow states and tribes to opt out. Governors and tribal leaders must notify the Secretary within 90 days of the bill becoming law. Licensed operators cannot knowingly accept bets from players in states and tribes which have opted out.
Utah will probably be able to reach a political consensus in 90 days that it wants to block all Internet gambling. But states like California might have trouble making a decision like this in 90 months, let alone 90 days. There is a complicated provision allowing states and tribes to opt out after the first 90 days, but it involves waiting at least until January 1 of the next year.
The bills contain a large number of other provisions. They have the now standard language about protecting underage and problem gamblers. They clarify that unlicensed operators who continue to accept Internet poker players from the U.S. are violating federal law, although they do not explain how prosecutors are supposed to go after a website in another country. And they would be the first federal laws that I know of that would make cheating at gambling a crime.
The bills should protect operators from state anti-gambling laws. They would create a federal preemption: “A licensee may accept bets or wagers from persons located in the United States, subject to the limitations set forth in this subchapter, so long as its license remains in good standing.” The Wyden-Gregg Tax bill is even clearer: “It shall be a complete defense against any prosecution or enforcement action under any Federal or State law against any person possessing a valid license under this subchapter that the activity is authorized under and has been carried out lawfully under the terms of this subchapter.” This means a licensed online gaming operator can take bets from every state and tribe, except those where the governors or tribal leaders have notified the Secretary they want to opt out.
HR 2267 does not give Nevada’s gaming companies everything they would like. Sports betting, for example, is expressly excluded. This was done solely to prevent the professional and college sports associations from opposing the bill.
But the bill does seem to cut out competition from foreign operators. The Secretary has to deny a license to anyone who “is delinquent in filing any applicable Federal or State tax returns or in the payment of any taxes, penalties, additions to tax, or interest owed to a State or the United States.” This is potentially bad news to every Internet gaming site that ever took bets from the U.S., whether or not they stopped when the UIGEA was passed. It is possible that the Secretary of the Treasury, who also runs the Internal Revenue Service, could conclude that an operator that had American players was doing business here, and should have been paying federal, and maybe even state, taxes.
Of course, this would not be a problem for American companies, like Harrah’s, which desperately want to get into the Internet gaming business, but have never had online gaming for money.
But even Nevada casino companies may not rush to go online. The problem is the last of the three bills, HR 2268. This would impose a federal fee of 2% of the money deposited by players. The same provision is in the Wyden-Gregg Tax bill. Operators cannot pass this fee on to players. Of course, operators don’t make any revenue off of deposits, only from wagers. So gaming sites that now are constantly encouraging players to reload will have to figure out ways to gets players to make more bets without keeping large deposits in their accounts.
These bills have another hidden trap: There is no limit on what taxes the states and tribes can impose on operators.
But if the states and federal government don’t get greedy, these bills can be made to work. The federal 2% fee should be on gross gaming revenue, not deposits. And the Australian model could work for the states and tribes: A licensed operator in one state or tribe would have to send tax revenue, at a reasonable rate, back to the state or tribe where the player is located. So Harrah’s, for example, in Nevada would send some portion of the money it earned from Californian players back to California. Nevada would keep the taxes earned from patrons in other countries. That may be the only way to get the other states not to opt out.
And the low tax rate has to be written into the federal statute. Because every state that has ever legalized gambling has raised its taxes or fees once the money started pouring in.
The Menendez bill is more comprehensive than all of the Frank bills and their counterparts put together. Although it still needs some revisions, it answers many important questions left unclear by the proposals in the House and the Tax bill in the Senate. Yet, it also is more limited, starting with the fact that it would only authorize Internet poker and other games of skill.
In fact, Menendez expressly exempts games of skill that are now “not regarded as gambling under an applicable provision of State or Federal law . . .” Imagine the fights over whether online poker operators have to be licensed in a state like Colorado, where a trial court jury recently ruled poker was not gambling because it was predominantly skill and then reversed himself, ruling whether poker was predominantly skill was irrelevant.
The bill is clear in expressly preventing entrepreneurs from setting up clubs where players go to play poker online.
Menendez adopts the language of the Frank bills in appearing to establish a federal licensing and regulatory system, while actually turning most power over to the states and tribes. But Menendez clearly anticipates Treasury issuing licenses to overseas operators. S.1597 states that no one can be found suitable if they knowingly accepted sports bets from the U.S. But as for poker:
The Secretary of the Treasury may not deny an application for a license . . . submitted during the 90-day period beginning on the date that the Secretary begins accepting applications . . . because the applicant operated an Internet game-of-skill facility, in interstate or foreign commerce, in which bets or wagers were knowingly initiated, received, or otherwise made by individuals located in the United States, without a license issued to such person by the Secretary . . .
Since every jurisdiction today can deny a gaming license to an applicant for having been involved in illegal gambling, this provision is designed to allow the federal government to overrule Nevada and all other states and give licenses to past, and present, online poker operators.
Menendez, like Frank, makes it clear that there will never be sports betting, and that horse racing is already legal. But while Frank’s bills and its counterparts would allow online casinos, bingo and lotteries, Menendez limits gaming to: “an Internet-based game in which success is predominantly determined by the skill of the players, including poker, chess, bridge, mah-jong and backgammon.” Of these, only poker is further defined, and this obviously needs some work: “The term ‘poker’ means any of several card games that are commonly referred to as poker; that are played by 2 or more people who bet or wager on cards dealt to them; in which players compete against each other and not against the person operating the game; and in which the person operating the game may assess a commission fee or any other type of fee.”
The bills entered in the House and Senate both require programs to keep out anyone under 21 and bad guys and protect compulsive gamblers, though the Menendez bill goes into greater detail here. It requires that there be background checks on at least the top five “individuals receiving the most compensation from the applicant.” Menedez, like Frank, puts the burden on applicants to prove by clear and convincing evidence, a tough standard usually reserved for such things as civil commitments, that they are persons “of good character,” they won’t “pose a threat to the public interest or to the effective regulation and control” of gaming, are competent, adequately financed, etc., to get a five-year license.
The Menendez bill included the provision in the Frank bills that looks like it was designed to exclude foreign operators who accepted poker players from the U.S. prior to the passage of the UIGEA in 2006: No one can be licensed if they failed to file a federal or state tax return that they should have, or owe back federal or state taxes.
So, even under Menendez, operators like PartyPoker cannot be turned down because they took poker bets from the U.S. without a license, but they can be turned down because they did not file some obscure state tax returns. It is likely that the provisions will be amended to make it clear operators have the right to cure, out of basic fairness. But the cost could be tens or even hundreds of millions of dollars in back taxes, penalties and interest.
The Menendez bill makes it clear it would be a crime to continue to operate any form of Internet gaming without a license. As with the Frank bills, there would be a tax of 50% of funds on deposit on any operator who takes bets from the U.S. without a license. But Menendez also establishes a detailed structure for imposing costs and fees on applicants and licensees, including fines of up to $100,000.
There are complicated provisions involving tribes and the interrelationship between tribes and states. This is an area that needs to be thought through completely. A smart tribe, with good legal help in advance, can set itself up to license a tribal entity or anyone else to operate poker online, taking bets from most of the rest of the nation. There are dozens of tribes already involved with Class III gaming, and with poker, that can act very quickly if this bill becomes law. Tribes would have the additional advantage of being able to demand that no other licensees take bets from anyone physically on their land. This would be difficult to enforce, giving the tribes additional legal and political leverage over competing licensing states and operators.
Menendez adopts Frank’s short 90 day opt out provision, and makes it clear that existing state anti-gambling laws don’t apply: “No provision of State law enacted prior to [this Act] shall be construed to require a State to provide notice pursuant to this subsection [giving governors 90 days to opt out].”
The Menendez bill has more details than the Frank bills on requirements imposed on operators, including having to allow problem gamblers to self-exclude, to bar bets from states and tribes that have opted out, to maintain player privacy, to prevent money laundering, and, of course, to pay taxes. As with the Frank bills, Menendez would make cheating a crime.
As for taxes, Menendez is asking for both less and more: A Federal Internet gaming license fee of 5% of deposited funds and a State or Indian tribal government gaming license fee of another 5%. This does get over the big problem with the Frank bills, that the big states, like California, where the customers will be, have no incentive to support Internet gambling operated and taxed by Nevada. Under Menendez, California gets that 5% tax. Although the states won’t like this provision: Tribes are treated like states, so if a player is on Indian land, that tribe gets the full 5% and the state in which the tribe is located gets nothing.
Of course, the tax system is still screwy, since it is a tax on deposits, not revenue. But it might work, at least for states and tribes, if not players.
And don’t worry about Nevada. There is nothing preventing the state that is recommending and regulating the online poker operator from imposing a state tax on gross gaming revenue, or even another tax on funds on deposit, if the operator has a physical presence in that state.
But another set of tax provisions puts operators licensed under the Menendez bill at a distinct disadvantage compared to overseas poker sites that refuse to be part of this system. S.1597 requires operators to report to the U.S. Treasury, which, of course, includes the Internal Revenue Service, the following information on “each person placing a bet or wager”: name, address and tax-payer identification number, meaning Social Security number; “gross winnings, gross wagers, and gross losses;” “net Internet gaming winnings;” amounts deposited and withdrawn; taxes withheld. The last applies to anyone who wins more than $5,000 in a poker tournaments; the current rate is a minimum of 25%. The I.R.S. has ruled that land-based poker rooms do not have to withhold, if they turn over the names and i.d.s of their big winners.
Interestingly, Menendez does a better job than Frank, who is, after all, Chair of the House Financial Services Committee, in trying to fix up the mess caused by the UIGEA. He would require the Director of the Financial Crimes Enforcement Network (“FinCEN”) to make up a list of every website that takes bets from the U.S. that is not licensed. Anyone, including law enforcement agents, sports organizations and players can ask for this list, and get detailed information about owners and operators. But the real kicker is that all payment processors, or at least those within reach of the U.S. federal government, will then be on notice that they cannot transmit any money to these website operators. All of the other regulations issued under the UIGEA will be redone.
Obviously, many players will not want information on their winnings given to the I.R.S., let alone having taxes withheld. Overseas operators will figure out ways to get around the ban on money transfers, for example, by using foreign payment processors and credit cards from non-U.S. banks. Although the bill makes operating unlicensed Internet poker a felony, enforcement against foreign sites would still be difficult, and the money to be made too good to pass up.
Assuming one passes, which version of the future of Internet gaming will win — Frank’s or Menendez’s? There will be hearings on both sets of bills. Frank has enough power, and the Democrats have such a large majority, that he can get anything he wants through the House. But nobody in the U.S. Senate really cares about this issue — except for a few anti’s, like Kyl; Menendez, the author of the poker-only bill; and, of course, the senators from a few states like New Jersey and Nevada, including, at least for the moment, the Majority Leader, Harry Reid.
So ask yourself what the Nevada casinos want. That’s what is most likely to actually pass Congress this year, if it is ever going to pass.
Meanwhile, half a dozen states aren’t waiting. The Great Recession has torn enormous holes in state budgets, and legal gambling is often seen as a painless tax. States have been looking at authorizing, and taxing, Internet gaming for years. But they were always afraid of running afoul of federal anti-gambling laws.
The furthest along, at this writing, is California. The state government has tried everything, from raising sales taxes to the highest in the nation to closing not just courtrooms, but courthouses. Ironically, proposals to legalize intra-state Internet poker could not get traction in the last few years, because the state’s deficit was too large. It did not make sense to spend political time and capital on discussing a controversial plan to raise on the order of $200 million per year when the state needed $20 billion. But things have become so desperate that politicians will look at literally anything that could bring in any money – legalizing marijuana for its tax revenue will be on the November ballot.
Other states are equally as desperate, but were not able to get bills passed in 2010 due to their short legislative sessions. Serious proposals for Internet gaming were introduced in state legislature in Iowa and Florida, and by the Governor of New Hampshire. The idea is still being discussed in Pennsylvania and New Jersey.
Attempts to legalize Internet gaming on the state level face great political hurdles, usually from existing operators, who fear the competition. The most obvious examples are the small number of politically powerful gaming tribes in California, who argue that they would no longer have to share gaming revenue with the state under their compacts, because they were promised exclusivity. In New Jersey, it is the licensed casinos of Atlantic City, who are ambivalent about online gaming.
The states are taking different approaches, although a consensus seems to be building that the only form of gambling that would be allowed would be poker. Licensing would undoubtedly go to present operators in each state, although the Florida proposal had the interesting, and unique, provision that operators would be required to be licensed to offer Internet poker in a foreign country.
The ultimate irony is that it was the UIGEA, written and then rammed through without being read, by a conservative Republican, to outlaw Internet gambling, that allowed the states to move forward. For the UIGEA has an express exemption for purely intra-state online gaming. Although other federal laws, like the Wire Act, could conceivably still stand in the way, virtually everyone, including federal agencies and the states, take the UIGEA as a clear expression of Congressional intent: States are free, once again, to decide for themselves what they want their public policies to be about gambling within their own borders.
I. NELSON ROSE
Professor I. Nelson Rose is a Distinguished Senior Professor at Whittier Law School and a Visiting Professor at the University of Macau, an internationally known scholar, author and public speaker, and is recognized as one of the world’s leading experts on gaming law.
Prof. Rose is best known for his internationally syndicated column and 1986 landmark book, “Gambling and the Law®.” He is the co-author of Internet Gaming Law (1st and 2nd editions), Blackjack and the Law, and the first casebook on the subject, Gaming Law: Cases and Materials. Prof. Rose is co-editor-in-chief of the Gaming Law Review & Economics.
Harvard Law School educated, Prof. Rose is a consultant to governments and industry. He has testified as an expert witness in administrative, civil and criminal cases throughout the United States, in Australia and New Zealand, including the first NAFTA tribunal on gaming issues. Prof. Rose has acted as a consultant to major law firms, international corporations, licensed casinos, tribes and local, state and national governments, including the provinces of Ontario and Québec, the states of Arizona, California, Delaware, Florida, Illinois, Michigan, New Jersey, Texas, and the federal governments of Canada, Mexico and the United States.
With the rising interest in gambling throughout the world, Prof. Rose has addressed such diverse groups as the National Conference of State Legislatures, Congress of State Lotteries of Europe and the National Academy of Sciences. He has taught classes on gaming law to the F.B.I.; at universities in Spain, France, Slovenia and China; and as a Visiting Scholar for the University of Nevada-Reno’s Institute for the Study of Gambling and Commercial Gaming. Prof. Rose has presented scholarly papers on gambling in Nevada, New Jersey, Puerto Rico, Canada, England, Australia, Antigua, Portugal, Italy, Argentina and the Czech Republic.
Prof. Rose can be reached through his website: www.GamblingAndTheLaw.com