meeting. And we just needed 10 minute break. Thank you. Ready to go. Thanks so much. Okay. Good morning, everyone. We are starting just a few minutes later than we anticipated. Before we get started officially, I need to take a roll call because we are using a virtual Good morning, Commissioner Brian. Good morning. I'm here. Good morning, Commissioner Hill. Good morning. I'm here. Good morning, Commissioner Skinner. Good morning. I'm here. And good morning, Commissioner Maynard. Good morning. I'm here. Okay, and we'll get started. Again, my apologies for just starting a few minutes late. We just had our agenda setting meeting with our entire team. And we have had quite a bit of work to accomplish in that meeting. And we just needed a couple minutes to regroup. So thank you for your patience. I am calling to order today. This meeting of the Massachusetts Gaming Commission. It is Wednesday, December 14. And it's public meeting number 411. Before I turn to our general council, I'd like to make a few introductory remarks. And for those of you who have attended prior meetings of the Gaming Commission, where we've been evaluating sports wagering applications, this key statements will sound very familiar. And I thank you for your patience. But it's important for me to reiterate them, because today we do have a different applicant. And we also have different stakeholders. We're reminded that the MGC's licensees will be held to the highest standards of compliance, including an obligation to maintain their integrity on an ongoing basis. As we have said in the past, the award of a gaming license in the common law is a peerless privilege. And our laws require gaming licensees to be held to those highest standards. The MGC mission commits us to creating a fair, transparent and participatory process that engenders the confidence of the public and participants. By law, that process is to maximize the benefit to the commonwealth. But critically, it must minimize potential or realized negative or unintended consequences. Again, and I wish to thank my fellow commissioners for your commitment to that mission and for your thoughtfulness and diligence today over the course of our last week and over the next several weeks as we evaluate these applications. I feel very fortunate to serve with you, particularly as we work tirelessly to implement this new law, the public's interest in the forethought. Our last several months and the months ahead have been demanding and will continue to be demanding on our MGC team, a team I've described and I know my fellow commissioners join me in describing it as a team of excellence. We're grateful for the contribution each of you are making, sacrifices that you are enduring, and those contributions you make individually and as collaborating colleagues. We thank you for your dedication as public servants and commitment to the MGC mission. With that, let me give a brief overview of today's agenda. First, you'll hear from our general counsel, Todd Grossman, who will review the statutory and regulatory framework that will guide us as we evaluate the applications. Then American Wagering Inc., doing business as Caesar's Entertainment, will present its application for a category three license, Heathered to Encore Boston Heart. After that presentation will likely take a short break. And then we'll hear from GLI, the IEB and RSM, relative to the technology, suitability, and finance components of the application. And that will lead us to a section by section analysis of the application during which the applicant will answer our questions. Staff members in our legal team, in addition to GLI, IEB and RSM will be available to answer questions as well. To ensure that we have ample time to reflect, finalize any personal notes, memorizing our impressions and follow up with any unanswered question, we may break for five minutes or so at the conclusion of each section or a series of the sections. And then after any further questions, for purpose of review of the application, I'll seek from the group comments in a sense as to whether we have a consensus regarding the quality of the applicant's response to that section. Did the applicant not meet expectations relative to the standard of review outlined by General Counsel Grossly? Or did the applicant meet our expectations or did they exceed our expectations? And also at any time during this public meeting, the commission may determine that an executive session is required for us to fully review and evaluate certain information in the application as set forth in the agenda. And should we vote to go into an executive session at this time that would be anticipated that we would return to this public forum. After our review of the application, we will consider whether we wish to proceed with our determination process fully or in part, or defer that decision entirely to another day. That's our process. And with that, I turn to General Counsel Grossly. Good morning, Todd. Good morning, Madam Chair. Thank you. Good morning, commissioners and to all who are joining us here today, certainly prepared to walk through my remarks. Before I do so, I just wanted to make sure that that would be helpful. I know I went through them yesterday and they were related to American wagering as well since they were on the agenda. And I know some of them were here. So would it be helpful to go through them once again, or just rely on the record from yesterday? Okay, I'll go through them again. That's not a problem. So we're here to, of course, evaluate the application received for a category three tethered sports wagering license submitted by American wagering Inc, which as you referenced, Madam Chair is affiliated with Caesar's Entertainment Inc. Prior to commencing the review, it may be useful to set the stage by walking through the legal provisions and principles that will inform the commission's decision making. So with that, I'll highlight a few provisions of the Massachusetts Sports Wagering Act, which has been enacted as chapter 23 and of the general laws. And then we'll take a look at a number of sections of the commission's recently adopted regulations. So with that, allow me to begin with chapter 23 and and the first place to look at is section 63, which says that the commission may issue a category three license to any entity that offers sports wagering through a mobile application or other digital platform that meets the requirements of this chapter and the rules and regulations of the commission provided, however, that the commission shall issue no more than seven category three licenses that are not connected to a category one or category two license. In this present matter involving American wagering, the applicant is connected to a category one licensee specifically when mass LLC, which was of course awarded its category one license last week. We've used the term tethered to describe that connection. So what this means is that the seven license limit does not apply to this type of licensure that the commission will be evaluating today. Before we look at the commission's regulations that govern the licensing process for a category three applicant, let's take a look at what a category three sports wagering operator license is. And that term is defined in chapter 23 and section three to mean a license issued by the commission that permits the operation of sports wagering from mobile application and other digital platforms approved by the commission. Just to place the present application in context, it's important to recall that the category one license holder when mass LLC is permitted to conduct sports wagering operations, but not more than two individually branded mobile applications or other digital platforms approved by the commission, provided that those mobile applications are qualified for an issue to category three license. So the applicant before the commission today seeks to operate one of those two digital platforms that go along with wins category one license. Now we will take a look at the commission's rules and regulations that have to be met by the applicant in order to be issued a license. The best place to begin here is with 205 CMR 218, which as you know is section that sets out the application requirements, standards and procedures. The process itself has of course already begun and administrative sufficiency review was performed upon the submission of the suitability portions of the application. And then the commission convened a public meeting earlier in the week in order to receive public feedback on the tethered category three applications. Momentarily, we'll walk through the factors and standards the commission has set out for the award of a license. But prior to doing so, there are a few other provisions and principles that are important to keep in mind. First, the regulations provide that the commission shall analyze the factors consideration set out in the regs, but need not do so in any particular order, or give any individual factor any particular weight. And in fact, it can assign a factor no weight at all if it's deemed appropriate to do so. Next, you'll recall that the regulations provide that the commission may require or permit the applicant to provide additional information or documents as the commission deems appropriate in its review of the application. So if you're review evaluating the information provided in an application relative to a particular factor, and you determine that the factor that further information is required, you may direct the applicant to provide it. Similarly, if during the course of the commission's evaluation, the applicant observes that there is additional information that was not provided that may be of use to the commission, it may request an opportunity to provide it. It's further noteworthy that the present review is being conducted as part of a regular public meeting under the open meeting law and not in an adjudicatory proceeding. That means a number of things, including that the deliberations here must take place in public, and that if necessary, the executive session provisions of Chapter 30A may be utilized. As it pertains to the instant matter, Section 21A7 of Chapter 30A allows the commission to move into executive session to comply with or act under the authority of any general law. In the present situation, there is a general law that gives the commission authority to move into executive session. Specifically, Section 6i of Chapter 23N provides that applications for operator licenses shall be public records under Section 10 of Chapter 66. Provided, however, that trade secrets competitively sensitive or other proprietary information provided in the course of an application for an operator license under this chapter, the disclosure of which would place the applicant at a competitive disadvantage may be withheld from disclosure under the public records law. So in sum, if there is any specific information that the commission would like to discuss, but that the applicant identifies as falling within that provision that I just referenced, and the commission agrees, it may move into executive session to discuss that specific information. While the statutory provision in Chapter 23N relates to the public records line, not the open meeting law, to require that the subject information be discussed publicly would nullify the whole purpose of the provision which was designed to protect such information against. Accordingly, application of the executive session provision I referenced is appropriate in this situation. And finally, before moving into the factors themselves, it's also important to recall that any finding the commission makes must be supported by substantial evidence. This term is defined as such evidence as a reasonable mind might accept as adequate to support a conclusion. So when making a determination as to whether there is support in the application to find that a specific factor has been satisfied, or has not been satisfied, the commission will have to ensure that there is substantial evidence in the record to support the conclusion. The one exception to this rule in an area in which there is a heightened standard that applies relates to the review of an applicant's suitability. By the terms of Section 215 of the regulations, any durable finding of suitability must be supported by clear and convincing evidence, not just substantial evidence, which is a slightly lower standard. Our jurisprudence tells us that clear and convincing proof exists. When the evidence induces in the mind of the fact finder, which in this case is the commission, a reasonable belief that the facts asserted are highly probably true, that the probability that they are true or exist is substantially greater than the probability that they are false or do not exist. For evidence to be clear and convincing, it must be sufficient to convey a high degree of probability that the proposition to be proved is true, and it must be strong and positive and full clear and decisive. So those are the two standards of review, if you will, that are in play during this evaluation. Now let me lay out the factors included in Section 218. And one way you may choose to walk through the evaluation that will follow when we get to that part of the proceeding would be to take the application factor by factor and begin to draw conclusions as the quality of the information supporting each one. You'll recall that the commission included sub factors under each of these factors as well. So prior to engaging in final deliberations relative to the applicant, it may be helpful to outline each of these sub factors, though I will not do that right now. The factors are included in the Section 218.06 subsection five of the regulations. Each factor falls under the umbrella standard that the commission included in the regulation, which directs that in determining whether to award a sports wagering operator license, the commission will evaluate the application to determine whether a license award would benefit the Commonwealth. So that's the main standard that will have to be met in order to award a license. In reaching that conclusion, though, the commission provided that it will consider the following factors. And you'll recall, of course, that the application itself was designed to solicit information within each of these categories. Number one, the applicant's experience and expertise related to sports wagering. Number two, the economic impact and other benefits to the Commonwealth that the applicant is awarded a license. Number three, the applicant's proposed measures related to responsible gaming. Number four, a description of the applicant's willingness to foster racial ethnic and gender diversity, equity and inclusion. Number five, the technology that the applicant intends to use in its operation. Number six, the suitability of the applicant and its qualifiers, and we'll come back to this one momentarily. And number seven, any other appropriate factor that the commission in its discretion deems appropriate. So those are the factors that we will review. You'll recall that there are a few additional factors that the commission included in the regulations relative to category three evaluations. However, those considerations are specific to untethered applicants, not the tethered sort before you today. So I'd also just like to at this time, circle back to the suitability factor for a moment. As you know, the commission has adopted section 215 of the regulations to govern suitability determination. And it included provisions allowing for two types of a suitability finding. The first is a durable findings of suitability, which is the so called final suitability determination. The second is a preliminary finding of suitability. You may choose to award a durable finding of suitability if you conclude that the applicant and each of its qualifiers has demonstrated its suitability by clear and convincing proof after having undergone a probity investigation. Alternatively, you may award a preliminary finding of suitability to an applicant that has satisfied section 15.012 based upon a certification submitted by the applicant and an investigatory report submitted by the IEB. If you find an applicant to be preliminarily suitable, that makes them eligible to request the temporary license under the process described in section 219 of the regulations. The entity would not receive a full license at that juncture. The process here is designed to allow the customary full background investigation and supplemental suitability determination to be conducted by the IEB and the commission respectively. So those are the factors that the commission must consider in order to make a licensing decision. As you work your way through the evaluation, though, it may become clear that a condition of licensure will be appropriate in a particular area. For example, you may find that information relative to a particular factor is lacking. In that event, it does not mean that the applicant cannot be awarded a license. It may simply mean that an area may require to be supplemented with an appropriate condition. License conditions are described in section 220 of the regulations. You'll recall that there are a number of automatic conditions, like an obligation to obtain an operation certificate prior to commencing operations, and that an operator must comply with chapter 23N and all commission regulations. But there is also a provision that allows the commission to impose any other conditions that it determines appropriate to secure the objectives of chapter 23N and 205CMR. Once the commission has made its way through all of the enumerated factors, but before any final decision is made as to whether to award a license or a temporary license, the commission should shore up what those final conditions will be in the event that the commission is inclined to award the license. Once that is done, the commission may decide whether it will award the category three license outright, determine that the applicant is eligible to request a temporary license while a complete suitability assessment is performed, or it can deny the application for failure to meet the requirement of the regs or for having violated section 60 or 9 of chapter 23N. To be clear, receipt of a category three license in the fashion the commission is reviewing today, whether temporary or full does not permit for the untethered mobile operation, just for the untethered operations as one of the two category one mobile or digital operations. After the decision is made, a written decision will be prepared and issued commemorating the commission's decision. Pardon me, my home phone is ringing, which never happens, but I'm sorry for that. I don't know who's calling me. I don't even want to take it. I don't even know my home phone number, so I don't know who's calling me, but I'm sorry about that. Hold on. Okay. So the the award of the temporary license, again, does not mean that agreeing that the operator has a green light to commence operations. It simply means that they're eligible to work towards the award of an operation certificate, which is a prerequisite to conducting sports major in operation. That process is described in section 251 of the regulations and requires submission and approval of such things as the internal controls, including the house rules and compliance with any conditions that may be imposed as we just discussed. So with that, Madam Chair and commissioners, I'll pause and turn matters back over to you, Madam Chair, and happy to take any questions. Question is all set. Okay. So to our applicant, I know that you've exercised a lot of patience and as General Counsel goes from a little to you, you probably heard much of what was already set forth today yesterday because when you were waiting in the wings and so for your time, we are grateful that you've exercised patience. We're going to start though now with American Warring Inks presentation and we perhaps the demonstration of the technology that's proposed. I will be referring and commissioners, I think we can be comfortable given the application to either saying AWI or Caesars. The application refers to them. Is that fair to the applicant? Yes. Hello. My name is Jeff Hendricks, Assistant General Counsel for this entertainment.  That's all very fair. My note that we might also refer to the business of Caesar Sportsbook or Caesar all of which would refer to the applicant. Okay. Thank you. So thank you again for your patience and now we're looking forward to your presentation. My pleasure. We're going to place the presentation up on the screen here. Thank you very much, Lisa. Chair, commissioners, before I begin, can you see the presentation in front of you? We can. It's not completely, but if you want to get, it depends on how you want to present. It's good. It's good. All right, great. Well, then we will most likely use this format. We might expand it as we move forward. By way of introduction, I just introduced myself. As I noted, I'm Assistant General Counsel for Caesar's entertainment. I'm in charge of our regulatory and compliance functions. With me today, I have a number of colleagues who I'm going to introduce and describe the sections that they're going to present in our application requesting approval for a temporary category three license for American Wagering Inc. doing this Caesar Sportsbook. Before I get into the introductions, I do want to note at the very front, we very much appreciate the opportunity to be in front of you today. I know there's been a lot of work and a very short amount of time to get us here. So thank you to the staff. Thank you to commissioners for reviewing our materials. And as we present, we intend to address each of the elements that Mr. Grossman described pertaining to our application for finding a suitability. If you have questions about any of those materials as we go, we will be happy to answer them during the presentation or at the end, we endeavor to hit all of the high points of our application. But if there's anything that would require some additional information, we're happy to discuss at your convenience. If we'll go to this next slide. As I noted before, we have designed this presentation to address each of the core elements of finding a suitability. With me today, my colleague Eric Hessian, our president of Caesar Sports and online gaming, will provide information pertaining to several sections. Most predominantly, our applicants experience an expertise related to sports wagering. Additionally, my colleague Ken Fuchs will provide additional information on our advertising and operational plans. My colleague Heather Rapp, our senior vice president of corporate social responsibility, will give some insight into our willingness to foster racial, ethnic and gender diversity, equity and inclusion. And then my colleague Floyd Baroga, our vice president of product compliance and Nick Arcuri, our technology product leader, will lead a product demonstration to show you how the platform works and describe some of the regulatory components related to our KYC geolocation and ITL certifications. So with that, I'd like to introduce my colleague Eric Hessian to begin walking us through our applicants experience and expertise related to sports wagering. Thanks, Jeff. Good morning, Madam Chair and Commission members. As Jeff mentioned, I'm Eric Hessian and I serve as the president of our digital operations, which includes the online sports book. I'll take a few slides and go through our general background as to how our company got to where we are and how our experience has been growing over the number of years that the product's been in the market. But please feel free to stop me at any time if you have additional questions or anything that you'd like to have more information on. So we operate as American Wagering, which is a city area of the public company, Caesar's Entertainment. I know in your remarks earlier we go back and forth between them, but we're essentially a division within the company. We have the largest footprint of any sports betting company in North America with sports betting operations and 27 different jurisdictions. We offer retail sports betting in over 180 sports books across 22 of these jurisdictions and mobile sports betting in 19 of the jurisdictions. We own the majority of our core sports betting technology platform and control the development of the few parts that we don't fully own. Our newest and most advanced platform is referred to as Liberty internally and we use that in nearly all of the jurisdictions in which we operate and that's the version of the platform that we plan to use in Massachusetts. So it will be our most current and updated and advanced product that we'll be planning to roll out. We have over 1,750 employees in our sports and online division and included in that are a number of dedicated teams in areas such as technology, marketing, trading and risk management, customer service, compliance, financial reporting and responsible gaming among others. In terms of general background, American wagering was operated as a subsidiary of William Hill PLC which was a public company traded in the UK for approximately 10 years. We acquired William Hill and closed on the transaction in April of 21 and subsequently divested all of William Hill's international operations. William Hill had been developing their own technology platform which we then accelerated the development and invested in to roll it out across the United States. Just 100 days after the acquisition on August 2, 2021 we launched a nationwide upgrade and rebranded the William Hill app in eight states to become the Caesars Sports Book app. It provided a highly elevated experience for customers and incorporated the Caesars Rewards program. Since the acquisition we've significantly increased our investment in technology, customer service, payments and other areas that are important for our customers. We plan to continue to invest at an elevated level for the foreseeable future and in addition we've earmarked resources so that we're able to launch our product in new states as they come available such as Massachusetts. From a platform perspective we plan to offer the platform in coordination with Encore Boston Harbor as you mentioned earlier. We have a strong working relationship with that company and we've partnered on similar arrangements in other states and we don't have any concerns with working with them. We also intend to limit participation in sports events based on the regulations that you set forth. Our systems have the capability to restrict any markets that aren't permissible and to do custom offerings based on the regulations. Currently we do that in other states where there are some state specific requirements or limitations and it's managed out of our trading team here in Las Vegas and they're able to manage that across all the different states in which we operate. So I'll pause there and see if there are any questions before we move on to the next section. I think that we've been typically holding all of our questions till later in the day so thank you. Okay, sure. Yeah, that's fine. Then I will charge ahead here then. So in terms of the economic impact and other benefits to the commonwealth starting out as I noted we're a subsidiary of Caesars Entertainment. If you looked at our last quarterly report from the third quarter we had roughly one billion dollars of cash and two billion dollars of availability on revolver so totaling approximately three billion dollars worth of available liquidity. From a sports book and online business perspective earlier in the year as our technology advanced we were able to reduce our nationwide spending and we shifted our focus really to Caesars promotional spend and it allowed us to fine tune our investment levels and focus more on high value customers. We're also able to offer the Caesars rewards loyalty program in a much more integrated way and what that's done is it's created additional customer value and it's improved our retention abilities. We plan to continue to refine our marketing and operational strategies to adapt to the market dynamics. From our history in the retail casino space we've established a protocol of testing control where we test certain actions and then evaluate them and continually refine our approach to marketing. It's been very effective on the retail casino side and we are employing the same approach on the online and digital side as well. In addition to the strong corporate balance sheet and cash position we're in a solid position to whether any downturns that we could see in revenues however we haven't seen any indications of that at this point and of course if you'd like additional information we can obviously answer it in the Q&A but we also provided links to our 10 Q&A and last quarter's earnings release. In terms of maximizing the revenues to the state we plan to use a variety of media sources to reinforce the quality of the Caesar's experience of brand, our commitment to responsible gaming, and to provide unique offers to the sports fans and betters. Our approach to forecasting and spending media is highly data-driven and optimized. As I mentioned we trial things, take the feedback, recalibrate and make modifications to further refine how we approach marketing. We'll leverage our experience from other states as well to successfully launch in Massachusetts, acquire the new customers, shift current sports betters from unlicensed competitors and sustain engagement over a period of time. Although we don't have a finalized marketing plan at this point we're in the process of putting that together. Our plans typically include TV radio and billboards and we use those to create awareness and provide education about our product. We often do direct response media where there's a call to action and that's typically from email, direct mail, affiliate programs where allowed and then we use the Caesar's database of customers that have established accounts with us on the retail side and that's also some social media and some search components of that. We plan to have some grassroots partnerships which are commonly in local bars venues and other events throughout the state to provide a local engagement and to drive further affinity with our brand. We have media and league partnerships as well and our marketing materials are regularly reviewed to ensure that we're treating everyone respectfully offering a healthy and responsible sports wagering experience. In terms of the surrounding states are effectively all legalized for sports wagering except for Vermont at this point and so we believe that the biggest opportunity is to convert customers that are currently using the illegal markets and get them to participate in the online legal sports betting market and so if you go to the next slide Lisa in terms of the legal market what we believe and what we've seen in other states is that you know people want to do the right thing and I believe and we believe that they want to convert to illegal offering as long as the product is competitive and it is close to the quality that you can get from the illegal books. We believe that our product the wagering experience that we've cultivated for the customers the customer service that we provide and very importantly the reputation and the regulatory structure that we're talking about today does exactly that. We offer a wide variety of options for people to bet including sports markets all around the world 24-7 there's something going on. We offer an in-play product that with very minimal downtime and suspension of markets so that customers can get the same experience for better than what they can get from an international legal operator. We offer a wide variety of count on funding options and the ability for customers to receive their withdrawn funds quickly which is very important to a customer feedback. We also offer attractive promotions and bonuses as a way to retain the customers after they sign up and we've integrated the Caesars loyalty program into our app so that customers earn Caesar's rewards which further enhances the retention capabilities of our product and finally we provide excellent customer service. We have live agents available via phone which is very unusual right now in our industry. We also have email chat and then we have kind of an automated. Did we lose? Did I lose? Okay, I thought it was me. We all lost him. We all lost him. It's very interesting even with the sidebar to see everybody's expression saying this is me. Let me call Eric right now and we can either have him redial in or we'll pick up his slides for him. Am I back on, Jeff? I'm back on and we have no problems with these kinds of technicalities. I laughed because we all had the same expression wondering if it was on our end. We can't see you. Oh, I can see him. I can't see him so maybe. He has to scroll down, commissioner Skinner, if he pops up on your sidebar. Yeah, now it's completely black. Maybe when he speaks again, it will come back. Eric, you, let's see if we can hear you certainly and I can see you, but you just finished with the excellent customer service statement. Okay, great. So yeah, one of the areas that we really focused on in the last year is our customer service program where we offer live, we do have a it's funny because nothing's changing and commissioner Skinner, did he never pop up visually for you? He never appeared visually. Okay, so I don't know if I can see everyone else, but I'm chairing commissioners. It appears he may be frozen visually. He's also black on my screen as well. The screen is completely dark. So I think he just needs to turn off his video and stop his video and re-enable his video in order to see him visually. If he's on a Wi-Fi connection, then he might just need to do audio. Would it be acceptable to the commissioners if we had Eric turn off his videos to limit the bandwidth? That might help on his end and then we could present those next two slides. Yes, I think we do like to see if it works visually and Katrina was just offering that, but otherwise we'll be fine with audio. Did you hear her recommendation, Jeff? It was, I think, I heard it correctly and correctly commissioners, but maybe he basically reboots and tries. No, not to reboot, Madam Chair, but to just turn off his video if he's on a Wi-Fi connection. The bandwidth maybe consuming both. Yeah, that's what Jeff was recommending, but that means we'd go without video altogether, correct? Of the individual, yes, but the presentation should still work. Hello, I'm back on. Can you roll here? There you are, Eric. Yes. So yeah, while I'm talking, I'll just have my screen off as you suggested. So I apologize for the Wi-Fi issues here. I believe I've finished the slide a few times. Were you able to hear it? No, you stopped at excellent customer service and we really haven't moved on. So that slide is still up. Okay, great. That was my final point was that we do provide and focus on customer service and make sure that we're available. We have phone live 20 hours a day and then live chat 24 hours a day. So customers are always able to get in touch with us should they be having a problem. And then from an employment perspective, we're predominantly located in Las Vegas. However, we do have operations in Jersey City, New Jersey. And as such, our base in Nevada in New Jersey is where most of our employees are located. We do have an option for a number of employees to work remotely where that's applicable. And so we have seven full time employees in Massachusetts currently. And depending on some of the local strategies that we deploy, we may end up with with more employees doing local activations. So I'll pause there. And I guess turn it turn it back over to Jeff, I believe. Thank you, Eric. And thank you commissioners. I'm going to begin a discussion of our proposed measures relating to responsible gaming, our commitment to responsible gaming and our advertising plans. Now I apologize. I'm getting over one of the many bugs that's out there right now. So I have to mute during this presentation to apologize. So I want to begin with noting that responsible gaming is a core part of our culture here at Cedars. Our long standing position is that we want customers to be playing with us for one reason. And that's to have fun. We also sponsor various public awareness education and other campaigns regarding problem and under each game. Within this section, I'm going to walk through a number of elements of our responsible gaming program. We're going to discuss the responsible gaming program that will apply specifically to the product that will be available in Massachusetts. We'll talk about some of the features within the product that will allow guests to self select various responsible gaming options. I'll also discuss Cedars corporate responsible gaming program, which will also apply to all of our advertising and marketing within the Commonwealth. And then we will get into discussion of the principles that we apply to our marketing programs in general and various sponsorship agreements that the company participates in. Following that, I'm going to turn things over to Ken Fuchs, our Chief Operating Officer of Cedars Digital to give us some insight on what those promotions will look like and advertisers will look like specifically if we're able to launch in the Commonwealth. One element that we think is unique to our responsible gaming platform and that will be available to customers in Massachusetts is the availability of our responsible gaming ambassadors. Cedars has a long standing tradition of taking certain team members and giving them additional training to interact with customers to provide information regarding responsible gaming issues, have conversations that might be more difficult to have in a broader context and give it additional and specific information to our customers about how they can address responsible gaming issues. When Eric described the integration of our two companies earlier and one of our major objectives following that integration was to train new team members as responsible gaming ambassadors that are able to interact with our sports betting customers and provide that unique service to customers across the country and that will be available if you're able to launch in the Commonwealth. Also, as I noted, there are various responsible gaming tools in the application to provide resources to customers informing them of the risks of problem gaming and tools that are available to them if they want to limit their experiences in certain ways. I'm not going to spend too much time at this exact juncture because during our product demonstration we'll show you exactly how those features work within the application and walk you through each of those tools that are all available to our customers. I also want to note at the outset the Caesar Sports Book will be a full and unequivocal partner with all of the agencies working in Commonwealth to support responsible gaming, whether that is the commission or any other agencies that provide support to customers within Massachusetts. Additionally, Caesar's has memberships with many councils that provide problem gambling support across the country and we're proud to support the National Council on Problem Gambling and the International Center for Responsible Gaming amongst many other organizations. When we look at our demonstrated commitment as a company, I hope you'll see the Caesar's really stands alone with the amount and breadth of commitment that we've made to responsible gaming. The list in front of you describes various responsible gaming milestones that the company has accomplished over its long history and we're eager to continue to add to this list. Within our application, we've taken several steps to ensure that we can prevent wagering by prohibited persons including underage persons and problem gamblers. One of the predominant ways in which we do that is ensuring that only individuals over the age of 21 are able to access to create an account. So as we look at ensuring that the right sort of customers use our product, again as you'll see in the product demonstration, only individuals over the age of 21 can create an account and all of those individuals have to go through several controls including reviewed by a third party KYC provider before an account can be created. So as we look at our marketing efforts and our customer engagement efforts, all of which is driven under the corporate principle that only individuals over the age of 21 can use our product. Additionally, and while this presentation is predominantly focused on our mobile offering in our retail environments, we also take numerous steps to ensure that only individuals over the age of 21 are able to use our retail sportsbook services as well, including carding anyone who looks under the age of 30 and providing substantial and repeated training to our team members on the importance of only allowing individuals over the age of 21 to use our products. Within our application, we submitted two different policy documents for your review. The first is a document that will be specific to this sportsbook application within Massachusetts. And within that document, you'll see numerous controls that describe a lot of what we've spoken about here, the sorts of self-exclusion options that will be available to our customers. The steps that we'll take to make sure that anyone who is identified as self-excluded is prohibited and banned from using our platform. And then all of our cool off and other tools available in the platform. Additionally, we provide information to our customers explaining how they can reach out to a third party. They have questions about responsible gaming, if they're seeking treatment, or if they want to speak to someone independent of the company to obtain additional information about approaches to safer gaming. So that's the first document. The second document that you see is Caesar's overarching responsible gaming program. And this document applies to the entire enterprise, as not just specific to our sportsbook platform. And again, ensures that we offer a number of tools to our patrons to provide a safe responsible gaming environment. So within our program, we ensure that if any patron wishes to restrict any of our company's services, they can sign up for self-exclusion. They can do that through the application. They can also reach out through any of our properties or reach out to the corporate office and request a limited or lifetime self-exclusion. And if they choose to elect that option, then that exclusion would prohibit them from using Caesar services across the portfolio at our Brick and Mortar properties and within our mobile platforms as well. Additionally, we train all of our team members to be on the lookout to affirmatively identify signs that might indicate to our team members that a customer is dealing with a responsible gaming issue. If a team member does identify such information, we have a mechanism in place where they can refer that information to what we call a responsible gaming committee. That committee will review the patron's comments, information relating to the patron's play, and make various recommendations that can range from reaching out to the patron through a responsible gaming ambassador, provide them information on resources that are available to them locally, resources that are available to the company, or in some cases, the company can choose to self-exclude or choose to exclude an individual rather based on the company's discretion if we think that that individual is not using our products appropriately. And then lastly, as we noted, this policy applies to all of our businesses and would support the responsible gaming policy that is specific to Massachusetts. Should we be able to receive a license? Within our responsible gaming program, we also adhere to a document that we refer to as the marketing and advertising code, which I might call the MAC or the code. And this code is very similar to other documents you may have seen in the space, like an AGA code of conduct. Our MAC is specific to Caesars and really is kind of the guiding principle for how we look at our relationships when it comes to marketing and our relationships with other companies. So when following the MAC, Caesars Sportsbook first ensured that our initial launch campaign included a responsible gaming advertisement, the initial one used actually the Manning family, the primary ambassadors for our company, the reminded users of the responsible gaming tools available within our application and reminded our customers to always use our products responsibly. Additionally, we adhere to all of these following principles. We do not promote gambling at any event where the majority of the audience is reasonably expected to be below the legal age to gamble in a certain jurisdiction. Our advertising does not depict, encourage, or condone excessive or irresponsible activities. We never imply that gambling is a right of passage for young adults, nor do we imply that gambling or gaming is acceptable alternative to or means of satisfying work or family commitments. All of our advertisements and all of the advertisements that will be displayed within the Commonwealth include a toll-free help line for popular gamblers and their families. All of our materials, regardless of a sponsorship agreement or a marketing approach are focused solely on reaching individuals over the age of 21, including partnerships with third parties like major sporting programs. When we look at our partnerships in a certain location like a like a stadium in our arena, we also ensure that the marketing materials are confined specifically to those locations that the average age of an attendee will be well in excess of the legal age to wager in that jurisdiction. And then lastly, as we mentioned earlier, we have a zero tolerance policy for directing marketing materials towards anyone under the age of 21. And further, we have a zero tolerance policy for ever allowing anyone under the age of 21 to use our products. So we have applied all of these sorts of responsible gaming controls and marketing and advertising commitments as we looked at all of our sponsorships and third party relationships. So I'm about to turn this over to Ken as he's going to walk through the advertising plans for the Commonwealth. I know we mentioned the questions might come at the end, but I would certainly be welcome to answer any questions about responsible gaming before we proceed. With that, Ken, please take it away. Good morning, chairwoman, commissioners. I'm Ken Fuchs. I'm the COO of Caesar's Digital and I appreciate the opportunity to talk to you today about Caesar's license. You know, from an advertising standpoint, Jeff touched, of course, on responsible gaming as a core pillar. We really feel that our advertising is a representation of the Caesar's mission in our brand. And ultimately, our DNA is centered on hospitality. It's fun. It's aspirational. It's about trust. And it's, of all things, customer-centric. And so the narrative of our advertising since our rebrand last year has tried to envelope that those qualities in our creative. It's less about giant checks. It's more about the story around sports betting and why it's additive to the sports experience for the sports fan. As we think about our advertising, we really center on three different components to it. The first, as Eric mentioned, is we've really shifted and learned a lot as we've launched in the last year and a half or so, launched or migrated about 10 different states and jurisdictions. And we've honed our strategy with every single one. As we've done it, we've recognized that as we've built a national brand that local activation often provides the best return and the highest quality customers you get to know the local markets. So we spend a lot of time understanding the local market. As Caesars, we have customers including many, many customers in Massachusetts already. And so we leverage our knowledge of the local market and our local customer. And we've provided in the application examples potential media breakouts by channel in terms of how we might think about Massachusetts market activation across a variety of methodologies. We also are very data-driven. We establish KPIs up front that we are trying to hit in terms of brand awareness, number of new customers, which we might refer to as first-time depositors, revenue and market share targets. And then we model our media spend based on our targets and the quality of the execution. We build targeted marketing journeys thinking about the funnel of conversion of people into our product and then retention over time, which is getting them exposed to our product understanding what Caesars offers in the space. And then providing promotions and opportunities for them to sign up and incentives to sign up as well. We continually assess the quality of the marketing and the results.  Then lastly, education is a major component via responsible gaming education about the product itself. We want to make sure that people understand what the product is and we want to be very clear and concise about what we offer. An anchor around around our advertising and marketing is Caesars Awards. Caesars Awards is a connective tissue for any customer of Caesars, regardless of what vertical, regardless of what location you're in, regardless of what digital product you're in, you can be a Caesars Awards customer, enjoy the benefits of a best in class, the best in class rewards program in our space. We have over 65 million members worldwide and for us, we really view Caesars Awards as a component that provides the enticement for customers to be loyal to Caesars and provide them a great experience beyond just a sports betting experience. It's part of a wider environment with tickets, restaurants, experiences, and other types of rewards. For Caesars Awards, it really has several components it has personalized offers and with every bet you make, you also you also achieve reward credits that you can turn in to use for various promotions or for those experiences. It also has a tiering system as you can see here on the slide with six different tiers with progressing benefits for every single tier that include personalized offers, birthday bets, hotel discounts, and other things as you elevate your tiers. Caesars Awards also has a number of partners which allows it to have truly the broadest array of potential value for the customer including with the NFL, cruise lines, Hursts, Windham, Vivid Seats, and others. So it's not just about Caesars experience, it's an ecosystem for customers to truly leverage a reward system that provides benefits across both Caesars and its partners. It also has an app in the App Store. The app has 173,000 ratings and has an average rating of 4.8 stars. So we very much integrate this throughout our experience and we're very proud of the program. And then lastly, part of our marketing effort is not just about media, it's about leveraging our partnerships and high touch opportunities out in the local markets. So as Eric touched on, we have a field marketing team which consists of both local vendors that are licensed as well as employees that can activate a variety of different types of experiences for customers to both learn about the Caesars Sports Book to sign up and to recognize our loyal customers. We often work with partners around those in other states. Those can be sports teams, they can be movie feeders, they can be suites at games, it can be bars and taverns, it could be other types of fan-based gatherings. But we're very well established in terms of running these events, running them under type regulations, training the staff appropriately around responsible gaming and around our products. And it's a great way to educate the fan around sports betting because it can be a complex journey to sign up. And it is a new industry and we think it's very important to have that concierge type service with people that are well trained as ambassadors to be able to talk to customers, explain the app, take them through the sign up process as they might need help or have questions. And of course, answer questions about sports betting and the vernacular of something that can sometimes see feel complex. See, we also have partnerships. I mentioned the NFL. We also partner with CBS Sports and ESPN. We have integrations with both of them across a variety of their media properties both digital and on air. We power all of the odds that you hear on ESPN and on their site and we're integrated into products like their websites, their articles, fantasy sports and other parts where you can click and sign up or you can click into markets to bet from their various properties and states where we are regulated in sports betting as they go. These are some examples of the creative and promotions that we offer. We offer a variety of different types of sign up and retention offers. For example, we might in previous iterations we might say first bet on us up to $1,500. So if you lose your first bet you get another chance at it. It might be after your first bet you might get $100 bet credit or you might get rewards points of a certain sort. But we also are shifting and focusing quite a bit on retention. We want to make sure that the people who have invested their time and their money and their experience in us have a great experience on an ongoing basis. And a lot of our promotions are geared towards introducing new products as well as introducing people to different parts of the application. We typically have two different types of reinvestment strategies. One is open to the public where everybody can access a certain type of promotion and it might be based on a certain game or a certain product type. We also have segmented and personalized promotions based on the type of player you are which is really tailored to you as an individual sports better with us as Caesars. We've made a big effort over the last year to become more and more data-oriented and more tailored around those types of promotions so that we're offering the right type of promotions to the right customer at the right time. Sometimes we also offer contests as well. So it's not just about bonuses and promotions but we have a lot of experiences through our partners. So we offer contests and ways to access to Caesars universe beyond just the sports betting promotions. And with that I'll, unless there are questions I'll turn it over to Heather Rapp who's our SVP of Corporate Social Responsibility. I'm not seeing Heather but I only see a portion. Let's just see. I'm looking now. I see Heather as I scroll. Heather, do you want to see if we can hear you? Sounds like. Can you guys hear me? No we can. Yes. I apologize. I've had some technical difficulties this morning and have I had to reboot a few times. Good morning Madam Chairman, commissioners and staff. As Ken mentioned my name is Heather Rapp and I'm the Senior Vice President of Corporate Social Responsibility. As part of my role I oversee all things CSR and ESG related for Caesars Entertainment. At Caesars our Corporate Social Responsibility philosophy is built around our people, planet play framework. And today I'll be sharing more on our work within the people pillar. As you can see below our focus on people centers on supporting the well-being of our team members, guests and local communities. Beginning with community engagement. Our community engagement efforts stretch across civic engagement, strategic philanthropy and team member volunteering. And we strive to be an integral part of the communities where we are privileged to serve. Caesars supports vulnerable and underserved populations through education programs, tools and platforms and facilitating equitable opportunities to participate in economic life. If we move into diversity, equity and inclusion the way that we look at DEI is across five pillars of commitment. Team members, guests, communities, suppliers and advocacy. And we strive to embed DEI into everything that we do. I wanted to take a moment to highlight two of these pillars for you here today starting with our responsible procurement practices. Caesars Sportsbook and Caesars Entertainment we participate in our DEI initiatives and overall and specific goals pertaining to minority-owned, women-owned and veteran-owned business enterprises. We strive to lead fair, equitable and inclusive procurement practices and processes that apply key principles such as welcoming fair competition, supporting diverse female veteran-owned businesses and obtaining relevant certifications and helping support them and growing their businesses overall. While Caesars Sportsbook is primarily managed out of the centralized services function in Nevada and New Jersey, it will be applied the responsible procurement policies to vendors in the Commonwealth wherever possible. Moving into our team member practices I'm very pleased to share our efforts to embrace diversity and create an inclusive environment that celebrates our team members as individuals. We've set very aggressive targets to achieve 50% female leadership and 50% people of color leadership by 2025. As of our performance in 2021 we reported 46% women in mid-level leadership roles, 32% women in senior leadership roles and 43% people of color in leadership roles. Our work to achieve these goals is woven through all facets of the organization beginning with talent acquisition and recruitment to talent development once team members are within the organization and throughout our day-to-day operations in all of our properties. While we do have one additional slide prepared with information on the work within our play pillar which focuses primarily on responsible gaming I believe Jeff covered that at length within his presentation earlier. I with that I know you said you're holding questions until the end so I will happily pass that on to Floyd Baroga to speak on our technology. Thanks Heather. Can everyone hear me? So good morning Madam Chair and commissioners thank you for having me. I'm Floyd Baroga Vice President of Product Compliance. It's good seeing everyone today and today I'll be highlighting our Liberty Digital Platform. I'm just walking the commission through the technical requirements and regulations that our platform meets or exceeds and also outline the architecture as far as how does the architecture meet the technical standards and the evaluation of the product say through GLI or the regulatory test labs. Also to note the system has the ability for daily financial reporting and to meet any responsible gaming and self-exclusion requirements has required by our current jurisdictions as well as the requirements that Massachusetts will plan to incorporate. So there's really two aspects of this system or in what we call the Liberty Digital Platform covering our website and our mobile apps. So the first aspect is operational support the back office if you will. Our player account management system incorporates a number of tools as far as marketing, email tools, customer service and payment processing. And also we have 27 support through our IT data centers. We will incorporate if licensed data centers within the state of Massachusetts to cover the wire act. Also have 24 seven development operation support. So engineering support available at any time. And also we incorporate a stringent change management policy that identifies any changes any modifications to the system for auditability of the MGC. And then later in the presentation Nicarcury will provide a user experience demo. Our digital platform provides three different verticals an iOS application an Android app and the website as well. And just to note you know the Liberty Platform has been live in New Jersey since 2019 but Caesar's Digital or Caesar Sports Works also operates our legacy platform in number of jurisdictions. So we can leverage that experience across the board along with you know the having the product fitted out by a number of regulatory markets. At least the next slide please. As far as the Caesar's technology advantage goes Caesar's utilizes the latest and greatest technology tools to allow for to allow for modular updates to the system whether it's incorporating new states such as Massachusetts or if the industry incorporates new security enhancements our team can go through and incorporate those updates into the system as well as testing and provide support for data retention. Also the betting engine and if you can go back also the the betting engine and all of our experience within you know US and previously Europe as far as offering pricing odds that experience as far as our traders go that is also incorporated within our system. Next slide Lisa. And then here are some screenshots of our mobile application iOS and our website so it provides a similar look and feel across the board so that the user whether they go within Massachusetts or say New York New Jersey and some of our other markets you'll have that same look and feel and allow that familiarity with all the players. And right now I'm going to hand it off to Nick or Kerry our product lead he's going to provide a demo of our mobile application in New York walking us through the various features of the of the mobile app and the system. Hi everyone. Thank you madam chairwoman and commissioners for allowing us to present happy to be here. I'm going to share my screen please let me know if you can see should be a mobile iOS this works one second. All right. I'm going to have to restart. I'll be right back. Sorry. It's giving me a hard time sharing my phone. Give me one second. I'll be right back apologies. There we go. I'm here. Okay. Can you see okay great. All right. Sorry about that. So what you're looking at right now we are in a logged out state. So I'm not logged in at the moment. I'm in the state of New York at the moment and I'll show you a couple of features before I log in. I'll also go through a registration process. So you guys can see the journey for a brand new user and see some of our controls around legal age KYC etc. So just taking you guys giving you a familiarity of the app at the very top we have the welcome information which tells you you know you're here it's the home of usage rewards you have information around which games and and leagues that we have here. This is all customizable by our editorial team. We like to obviously put NFL and World Cup at the top of that list because they're the most popular sports and leagues. Further down you have some of those promotions that can took us through and we also have a promotions page down at the bottom like you can see the promos and then you have our basic events sports and all the different markets that we offer right within the home page. So as I'm scrolling down here you know you can see all of the NBA games that we have some college basketball and then finally the NHL these are kind of our featured markets that use allow users to find the most popular events quickly but they can always go into any sport or league to find more information of what they're looking for. So I'm going to first go in and log in and the next thing I'll show you guys are some of the responsible gaming controls and then we'll do some bedding to actually trigger some of those so we can see them in action. So when I click the top right it looks like a profile picture I'm actually going to use face ID to log in because New York has that set up. I can show you the other way to log in as well but you'll see a quick face ID show up give me a check and now I'm logged in. It does say Michael this is a test account registered with the state of New York fully whitelisted to allow for this. This is not real money it's all test money but as you can see the very top has changed it says hi Michael it shows my gold membership for Caesar's rewards and on the right top right corner you can see my balance of 10,600 and a dollar and a one cent along with my 10,100 reward credits. I can also go into my profile MT and it's going to show me a little bit more information. So again cash balance and bonus balance I don't have a bonus balance right now but if I did have a bonus balance it would show there there's a difference between a cash balance and a bonus balance. Cash balance cannot be withdrawn sorry cash balances can we be withdrawn and bonus balances cannot be withdrawn. You can see my Caesar's rewards information account preferences bonuses responsible gaming support and the ability to log out plus we have any information this is what New York controls we have our that with your head not over it to support hotline and any other information required by a particular state and jurisdiction we have that on every single homepage in our footer that way it's always available to a user no matter where they're navigating within the application. So I'm going to go into responsible gaming here I have a couple options within responsible gaming I have our gaming limits which are around time spent deposit amounts and spend for daily weekly and monthly I have our ability to cool off which does not it suspends your account for three to I mean three to 30 days it does not allow you to deposit or make bets it does allow you to withdraw in that state and then self exclusion this allows you to self exclude and and completely suspend your account for one two or three years depending on the state and jurisdiction we can adjust that setting no matter what the jurisdiction is asking for there and that also allows you in certain states to self exclude across all operators there so you're not tempted to go to another operator if you have a gambling issue that you're you're working on then you have your history of any changes so first going to go into gaming limits so you're going to see a few here so it's going to tell you about the information from the particular state and then we have three on this from New York we have deposit limit both daily sorry daily, weekly and monthly so I've had it set for a monthly limit of a thousand so I don't want to deposit more than a thousand if I try that it will block my deposit and that's obviously additive so it's not a one time deposit of a thousand if you deposit 500 one day and try 600 the next day obviously that's going to block you because you're going over your limitation for the month you have betting limits so we have a weekly betting limit of 500 a monthly of no limit and a daily of no limit I'm actually going to change this the daily here going to open that up it's going to give me a drop down some options certain jurisdictions we allow the user to actually type that in but most control usually drop down to allow for easy access for the user so I'm actually going to put a daily limit of 100 here and I have a daily time limit right now at four hours I'm going to try to reduce that to one hour and you'll see a kind of a different approach here when I hit apply the one hour reduction anytime you're reducing a limit it will not let you do that right away for that particular day or if you're trying to increase a limit on your spend it is going to delay you either a day week or a month for that to happen so you can't right away say oh I need to put more deposit more or spend more that day you have to take a full day week or month depending on which limit you're changing before you can actually adjust a limit in the I would say the more aggressive direction either less time you know we go less time spent on the site or more time spent on the site actually so I actually did the wrong thing so I want to go six increasing apologies yeah now when I hit apply here you'll get a kind of confirmation screen and key key thing you can see here my daily spend limit since I'm adding a spend limit there's no there's no issue with that that'll go right away $100 for the daily spend but since I increased my time limit it won't happen today it'll happen tomorrow and they'll say 12 15 2022 is when that will happen and today it'll be still four hours so I can hit confirm here and it tells you also at the daily time limit it will increase to six hours on 12 15 2022 so that tells you that you know you have four hours today but tomorrow in this case you can go up to six hours if I close that down I'm going to go into the history just to show those changes in your history that way you know what changes you made so the two changes I made you can see the daily spend limit is at 100 the daily time limit is at six hours and the due date is when that's due to take effect you can see that 12 15 at 11 35 a.m. Eastern which is the time it kind of turns over for us it's for yeah that's right and you can see a few other things I was testing I was testing on Monday you can see I made some changes on Monday and you can see all of those those changes there go right ahead question thank you my chair just a question if I wanted to reduce the time limit rather than increase it does that also not take effect until the following day it will take effect right now so if I'm saying hey I only want one hour now it will change to one hour and I'll confirm that and it's actually at one hour immediately because you're being more conservative with your time and we want that to take place right away and is that is it the same for the betting and spending limit so it'd be the opposite for betting and spending so if you want to if you want to sorry sorry if you want to reduce spending if you want to reduce spending or your deposit limit same thing it would take effect immediately so if I change my weekly limit from 300 to 500 you see there's no change there it's no no warning saying it's tomorrow or next week it's immediate 300 and that's now now my weekly limit is at 300 thank you okay I'll quickly show the cool off I'm not obviously going to go through cool off because I want to show a few more things here but you have the ability to cool off you'll see the number of days that we have options here this is customizable and it tells you everything you will not be able to bet deposit may changes but you will be able to withdraw during that that time of cool off the share of withdrawal and you have a withdrawal process is pretty instantaneous right depending on the way with we withdraw so if it is for a debit card it is instant some other methods you'll pay pals is very very quick but there are other methods that take a little bit longer ACH and others need approval and they may take up to you know 24 48 hours just depends on the provider and our approval because a lot of the times we do manual checks on most of our withdrawals we also run it through some automatic checks to make sure there's no fraud or other things going on and if there is it gets held up but we do have an instant withdraw around debit cards that that we've implemented in the last few months and I'll show you the few options the options that we have for deposit withdraw in a moment self-exclude just I will quickly go through this this is in New York so you have two options self-exclude just from Caesars or the entire state of New York we have different options for different states all customizable here but anything else on responsible gaming on this screen I'm going to trigger that hundred dollar limit that we just put in there so you guys can actually see it in action and what actually happens okay let's go and do that all right so I'm going to take a bet here that the world cup coming up at 2 p.m I think this is going to go into extra time so I'm going to take the draw you're going to see that information come up this is our quick bet area allows you to quickly make a single bet and at first I'm going to bet $50 which is under our limit so this bet is going to go through going to place that bet and it's going to give me a receipt oh I'm being reviewed by our trading team there we go it's approved so we have a success here it gives me my wager of $50 the total payout of $197 tells me exactly the bet I'm placing here it's telling me like processing my rewards and tier credits that's fine it'll it'll take may take up to 24 hours for that to appear so I can also go into my open bets and you can actually see that bet there so you have the draw I have a cash out price which allows me to take I bet $50 I can immediately take out $4750 if I want during the game if you know Morocco goes up and I want to take out some of my money or France goes up and I want to take out my money or it's a draw through 85 minutes and I want to take out my money I can do that and I have a price that instantaneously updates based on the state of the game and what's happening and then coordinated with the bet I've placed and now it is showing my you know 29 reward and 29 tier credits which I've earned from a rewards perspective for that bet and here's some other bets that I've placed in the past few days and you can also look at settled which are bets that were placed and have been settled so the game has ended and here's one that I've won on the Monday night football game with the Patriots winning that game and then here's a parlay that I lost you can see I won two legs but I lost that Atlanta Hawks leg it gives me that information and if I have like a void or here's one that I cashed out it tells you that right above in that little you can see the green box there tells you kind of the status of the bet we do a little you know more special thing on the on the win so when we if you want to share that to your friends you know you know it's Caesar's and you know helps promote the fun all right so now let's take an NBA game and I'm going to try to put over my hundred dollar limits I already have 50 today so on the pistons I'm going to take and try to put 60 on the pistons here and right away it tells me this bet would exceed your previously set gaming limits so that means I'm trying to go over a hundred dollar limit that I have today so if I want to place this bet it has to be $50 or less so I'm actually just going to place a dollar bet just to show you guys that it will go through and that dollar bet on the pistons has gone through because now I'm at $51 of my hundred dollar total spend for the day I do also want to show you guys quickly how to create a parlay it's very easy and simple so I'm going to bet again I really like that pistons game I want to actually add more bets so instead of clicking a wager amount I'm actually going to hit add more bets it's going to show me I have one straight add more bets to build that same game parlay which is SGP or I'm actually going to go in and do a three game parlay I want the hawks and I'm going to take the gold state warriors and you can see at the bottom of that screen it's telling me I have a three leg parlay and it gives me the price and if I open that I can see the three leg parlay I can put a bet in just on that three leg parlay or I can choose those games separately as singles and I can bet that all in one click or I can click one at a time so I'm just going to put a dollar bet on this parlay here you can see when I put a dollar in it tells me it pays out $6.96 and I'm just going to make place that bet there so I've placed that bet there it is instantaneous that bet is in there and now it's now also in my open bet let's see any other I'll show you some same game parlay information very quickly and then we'll get into some of the customer service some of the payments withdrawal process and then we'll finally do kind of registration at the end of a new of a new customer so if I actually click into one of these events I'm going to go into this Pistons Hornets game at the top I have these tabs here and one of the you know things that operators and our customers love the most is the same game parlay you know I'm a big Pistons fan I'm going to watch this so I want to I have a really good punch that a few things are going to happen in the game so I think the Pistons are actually going to cover this I think it's going to be over 226 points and I think let me see I think Mason Plumway is going to go under nine and a half so now I have a three legs same game parlay here and I'm going to be able to place that that and that's you know a three legs that are all kind of related to each other in the same game so I've placed that that that's a great feature that I think you know our customers love and we also love is as sports fans and then let's any other questions on betting before I go into some of the the other features and functionality that we'd like to touch on I can always go back if something comes to mind you didn't cover last night's game I didn't all right here we go I'm going into I'm going to go into deposit first and then I'll go into withdraw so really big call to actions here with for deposit and withdraw so if I click deposit you'll see a few different methods and these are methods that have been approved by this particular jurisdiction in New York if a jurisdiction says hey credit cards are not allowed like in New York you will not see a credit card option you can see online banking debit paypal a ch pay near me or our play plus prepaid card but if we have credit cards are allowed you'll see credit cards as another option we're working on apple pay then moe and a few other items that depending on the jurisdiction and approval we can mix and match of what is allowed and what's not allowed Richard do you want to ask you a question about secondary credit here or do you want to wait I'm going to put it on the spot I can ask it now if you want I mean I was going to circle back to it at the end it's the same question I had the other day which is and the answer we got yesterday for your application since you guys probably weren't watching the entirety of yesterday's hearing had to do with not only the statute of Massachusetts bars credit cards we're having another conversation about the one step remove use of credit cards and it's my understanding some jurisdictions do ban that as well that there's a mechanism to stop that and I'm assuming the answer is the same from you guys that if the statute and the regs in Massachusetts say no credit cards either directly or one step removed that there's a mechanism for you to make sure that that's not going to be a deposit method on your app correct so something like PayPal through a credit card we can you can turn off the credit card option within PayPal or we can't do that we can turn off PayPal in general and only have the direct non-credit card options that's good I can supplement that answer as well so Nick is right if credit cards are not permitted we turn it off in the primary instance then the secondary instance PayPal doesn't even accept credit cards at this point so it's a it's a non-issue everywhere actually and then poor things it doesn't accept credit cards you mean in this setting in for sports betting it does not of course that not their policy that counts and then for site line anything that is a credit card we reject immediately regardless whether it's primary or secondary we also work with the teams and our processors around regular audits as well to make sure they're they're applying their processes and protocols appropriately yeah so we have we have controls in place around around credit both direct and secondary as well so I also follow up questions in terms of the the failure that happened in Iowa I think it's some other places so but I can save that for the suitability and compliance discussion that would be great but for me that's really helpful on the PayPal I just am not familiar with all of these mechanisms like so if we were to adopt we by statute credit card is is prohibited so if we were to you know delve into the secondary credit card issue how many would be would there be any exclusions from just this New York list here we wouldn't so what would be excluded would be for our player plus card which is powered by site line at the bottom there we would only allowed debit cards to fund those as opposed to any credit cards cards to be prohibited but otherwise in this list and I just know it's not exhaustive but in that this list here there would be a range that could be made on the secondary credit it's nothing else would have a secondary credit card none of them have it okay excellent PayPal at some point may change its policy in which case we will take all required protocols to make sure we that nothing goes through my spouse wishes that applied to Christmas shopping so thank you very helpful Madam Chair may I have a follow-up question sure Ken I know the answer but I just want to hear it from you so if I choose to do an online banking and I have three or four accounts and I try and sneak in my credit card there is technology that will recognize that's a credit card and not a debit card correct we know based on the bin that it's a credit card and we will reject it excellent thank you so for me it was really helpful to see this visual Commissioner Hill that all of these could be still options for the patrons but just not through the credit you know okay correct thank you okay I'll click in I'm not going to actually deposit but I'll just show you kind of what this looks like here for debit card right I can add a new one the same normal you know controls that you would see on a any payment screen across the web and it allows you to kind of choose your amount at the bottom and and continue and give that information and then we save that information for you know ease of use the next time it's very you know familiar interface for anyone that's bought anything online and withdrawal this might get blocked because it's a test account yeah so it's blocked we have but you would have the same you would have different options or you know a reduced set of options for withdrawal sometimes we have deposit only options and then withdrawal options but it would look very similar to the last screen since this is a test account there's no way to draw that money because the money's not real okay want to quickly look at the Caesar's rewards so as mentioned earlier in the presentation this is one of our you know really great features that our customers love and provide not only you know rewards within within you know online or retail sports betting but also at hotels events and merchandising you can see all that here so I can redeem it right away when we first start I have gold membership by 10,102 credits it's telling me how many credits I need for that that next level of tier and if I hit view tier benefits I can see exactly what I get with golds and platinum and diamonds diamond plus seven stars etc and then here you can see all the different options for redemption so you can book a hotel or go to an event like a Dell in or buy some merchandise from your favorite teams all through your reward credits or you can redeem it at the top you can see that 10,100 rewards actually applies to 101 dollars in bonus cash so you can redeem it direct to to use within you know the application if you're not planning a visit to one of our properties and want to use it for hotel or events or dining or whatever you might use it on property for us but it does give a very kind of broad and I said extensive kind of options for using those rewards when you do travel to one of our many properties across the US and information about earning credits and FAQ right there and as mentioned if you want to download the separate rewards app it's right there at the bottom with the link to the iOS app store because I'm on a iPhone here and if you're on Android it will take you to the Android that's the Google Play store on Android I'm going to go over to some customer service here and I'm going to click in the account on the top right and we have an entire support section so as Eric was talking through and unfortunately got connected disconnected a few times here are all our customer service options I'll take you through most of them so you can see so you have live chat contact us help your feedback which gives us feedback on the application or anything else betting 101 which is kind of like I'm brand new to betting give me some examples doc upload might be needed if you have if you failed know your customer and you might have to upload a document and you don't have it right at the moment you can get back to that that page and then close account which we in some in some states is necessary part of you have to actually close the account instead of either suspending or cooling off or or self-excluding there's also a close account option I'm going to show you the live chat quickly when I click in this it's going to take me over to you a live help page and this is going to first go to an automated chat bot which we hope can kind of help your problem and get you an instant answer but if not you could then go to a a live person for chat so I can go in here and say hey I'm located in New York I'm going to auto fill my information here can hit submit now it's telling me Betty is listening greetings emperor what information can I help you with so maybe I want to ask about responsible gaming so if I click that and hey how do I set my limits I can click limits you can click here to learn more and that'll take us back to the responsible gaming page that you that I showed earlier or you can say hey I want to go into my spend limits and then it tells you exactly how to do that go to account and gaming limits and then you can set your maximum spend limit for a daily week later monthly do you need help with anything else and if I wanted I could type like account and hit send and it'll give me a few options related to account and this is all automated chat bot this gets I think it's about 60% of our users that use the live chat get their answer you know get their question answered immediately with the chat bot without you know using a live agent on phone or chat and that allows our live agents to spend time with our customers with the more complex questions and inquiries and can do a better job in giving them that customer service and through the chat bot if you can't get your answer you can always get a representative and we'll go through to the live chat person who can actually give you more information or you can give us a call a quickly go back into the app Madam chair can I ask you very quick question I know we save them to the end but I think this is quick sure during your presentation I think I heard you say that your phone or to contact someone live is only 20 hours a day whereas the chat was 24 hours a day so this is an issue that this commission cares deeply about that if someone's having an issue getting paid or something pops up that you're able to contact somebody immediately so did I hear you correctly if I did what are the hours of operation for a live person Commissioner this is Eric question again you did hear us correctly we're getting very little volume on the call side and so we shut it down between 1 a.m. and 5 a.m. Pacific time and then the chat bot is or not the chat bot chat ride agents are 24 7 I would say that we are one of the only if not the only operator offering voice at this time I don't think that's true I think that's right no there our applicant yesterday offers 24 7 and it's a U.S. based group yeah I apologize I said one of the few there are only a few offering a voice right now oh thank you thank you so can I ask sorry Commissioner Earl no I said thank you for the clarification so I have a follow-up to that which is the the metrics that would have you shut it down from 1 a.m. to 5 p.m. Pacific standard time do those line up with a drop in usage on say the east coast I mean it wears your support so that it's you're using that time as opposed to what might be a drop in usage on say eastern standard yeah those those were pacific times so it would be what is that four to eight eastern and there is yeah there's just there's very little wagering activity going on and low contacts in addition our old tech platform from a retail standpoint goes down for two hours so there's no volume coming in during that period it's certainly something that we continually look at and review because as I mentioned it is very important to have top customer service and we make sure that you know we're answering the phones very quickly and that we're answering texts very quickly and it could certainly change based on you know as more and more states legalized and as the volume grows so can I ask Eric if I can there are going to be a mechanism that allows for it's not just say if somebody's account has been hacked which was in the paper from you know some other operators and people had difficulty getting a hold of anybody to try to rectify a close the account the the close the account function on the app is there a way that somebody immediately suspends activity even if they can't get a live body because the phones are down yeah you can you can close the account at any time was that your question could you have run not particularly no if someone's hacked your account would you have any issues trying to get into your app and closing your account through the app so you need to get a live body right so even even if you are logged out if you don't have your login say in a you know in one of those those cases where your your account has been taken over and maybe they've changed the password on you you still have access to the live chat functionality through your app even if you're not logged in and that will if you know if it does happen five a.m eastern time you will have a live chat option with an agent and I believe you know that would be an escalation I don't know if Eric and Ken but if it's if the live chat's not available it's an AI chat right it's available 24 seven the live chat with an agent but just not on the phone to speak to the person right is that it is that the what shuts that's yes that's the difference it's always available only important clarification I'm so you're saying a live person is always available through the app but not necessarily to voice to for yes yeah there's not an AI chat there's a body on the other end of the chat that's really well that's really helpful to understand and also on you know one of the concerns we well I have and I imagine my public commissioner shares also if someone's in distress they have a live person to reach so in that you'd have some kind of process to address that person yes that's correct there's always a live person available as Nick mentioned the first step to screening a lot of the inbounds that are very simple is through the chat pot but there's always 24 seven live chat and then there is a period of four hours where we don't have live voice but otherwise it's live voice yeah it may be said said differently so if it's seven a.m in Massachusetts and a user is a account issue that's potential lockout or any other issue they could reach a live individual through the chat function during that time a live individual is available thank you commissioners are you all set on this thank you help them sure clicking on contact us contact us you'll see this information here our customer support is seven days a week quickest is live chat here's email for New York and our phone number there so immediately you can get the user to where they need to contact us that information there done here help is kind of your help pages your FAQs you'll see this loading up and you know you can type in a support or choose a topic this is kind of self-help a lot of people find this very valuable they don't want to talk to anyone they just want to find the answer quickly so they can use this and if you have problems with the self-help you can see that chat bot in the in the bottom right where you can click and get right into that to that that agent or the AI bot to solve your answer solve your problem we have feedback which is basically we can give feedback on the app it's less about your account it's less about you but you could say hey there's you know it's the app is refreshing or I like something that's happening here you know this is specific feedback around either the page you're on or generic feedback so that helps helps us as the developers and the technology team kind of know if we're doing something right or wrong and can make improvements and we we actually have a channel that we get those immediately so I actually can see in my slack right here in my laptop but I have I think about 10 or 15 feedbacks that have come back in the last 24 hours that I'm going to take a look at all right anything else on on support okay great lastly I am going to go and log out here and I'm going to go and switch states so I hit this question mark at the top and so at the very top you can see New York Sportsbook I have information here again that you know this is in the logged out state you can see the live chat contact us that's there you're not logged in you still have that access if I hit change the location at the very top I'm changing out of New York because I already have account registered there I'm going to try Maryland and it's going to switch over you can see at the top switch to the Maryland Sportsbook and I'm going to click here now here's our normal sign-in but if I don't have an account it says don't have an account register now underneath that sign-in button and click on that and it's going to take us into our registration flow so I'm going to go through this flow with my real information and then we're going to see if it's going to KYC I'm going to try to fail it once or twice and then give my real information and hopefully it will pass through so email address I'm going to provide my home email address promo code I don't have one at the moment so I'm just going to skip that and hit next now it's going to ask me for a password I'm just going to put in see it tells me that it's green if I you know I need more characters or I need a you know a different number it's going to tell me that information very quickly to know that my password is good enough and then I can hide it and then phone number phone number there it says you're almost there right okay and this is we put this here because this is where we're asking a little bit more deeper information personally and you know some people that sign up for online accounts they never expect to give this information so we kind of give you this this warning here to say hey you know we need to make sure we confirm your identity and verify your over 21 and we won't share these details with anyone so please go ahead and confirm your identity this helps people feel more comfortable with the process and understand why we're asking for the last four digits so your social security your date of birth and things like that that sometimes most accounts online don't need for your normal kind of shopping experience or any other account creation so once I hit confirm identity I'm going here put my information in date of birth so I will give a bogus date of birth obviously not only maybe three months old I'll put in my information here home address is going to be this is going to do a look up so it's actually going to look up a proper address this helps with the KYC process so you're not typing an address and you have kind of a mismatch just gets an exact address and really helps there so if I agree to terms and service and hit submit what's going to happen right now it's not going to let me go forward because you know three months old in this in this scenario it's actually going to repop the birth date picker for me and you can actually see behind it says you know please update your birth date so you're something correct so I'm going to go in here guys are going to all know my birthday not September 20 actually you know what I'm going to do a mismatch birthday which is over 21 and then we're going to see what happens then and I'm going to change my birthday to the real one and you'll see it go through so we're verifying that we couldn't verify because my birthday I gave the wrong one so I'm going to go here and put my real birthday in and hit submit there is so KYC passed luckily I have you know good know your customer my account's verified it shows me my season rewards and you know a really nice kind of confetti hey you're in gives you deposit now option sometimes there's a sign-up bonus attached depending on how I come in and that would appear in that blank space there or I can explore odds which would take me right into the sports book now since I'm in the Maryland sports book I'm actually located in New Jersey you will see that red bar at the top says we cannot verify your location so I can hit view details you know first it's going to say hey you know allow precise information allow precise location that way they can geolocate you if that's not the case I already have it on but I'm going to show you guys now that I can't make a bet or I can't deposit because of this now I'm just put it in my bed slip here um and it's also telling me at the bottom please allow precise location because I can't not only do I not have money in my account so it's not a place bet button it's deposit because I have zero dollars that's also telling me to allow that precise location if I view details I can allow it here it's not going to do much but so I have precise location on because I'm not in the right state now it's going to recheck me and it's saying you know you're still having a problem here and to you can you can call us you can figure that if you're actually in the state and you're still not you know getting that location check properly working you know you can you can reach out to us and there's a couple steps in that process so I won't be able to bet here but you saw the registration process you can you can see you know we have errors in there it's pretty simple to change them and then you can see that with my mismatch information even being above 21 it's not letting me through and when I actually put my real information I did get a KYC check and if I travel to Baltimore later today I'll be able to deposit and bet on this if I was a real customer obviously I'm not going to deposit because that causes a lot of problems for our compliance team to say hey a real person is deposited and a real employee is deposited and they shouldn't I'm actually going to tell them to delete these accounts out because they're they're not tested not real accounts later on but as long as I don't deposit there's no major compliance issues and I might just add one point to next demonstration so I named this example Nick signed up for an account in Maryland if Nick was a member of the self-excluded list offered in Maryland he would not have been able to sign up for this account so we during that KYC we would check the Maryland excluded list and how to prevent him from signing up for an account those same controls will both of course be in place in Massachusetts as well okay and that's what I had on my list but if you guys have any other questions I'm happy to run through any other pages or show you anything else within the application commissioners anything else that you'd like from Nick I think we can take that down then please okay thank you so much I appreciate it thank you okay and and Jeff does that conclude your presentation or do you have more we have more we'll go to present our our deck again we have a couple more items that we want to cover compliance matters and then we will resolve our presentation thank you thanks Nick for the great presentation there so yeah it was excellent thank you agreed so the the mobile platform that Nick provided as well as our back office that identifies critical components for gaming you know that system is live in 19 different jurisdictions and you know Caesar's not only incorporates a digital platform but our retail platform with shared components that is also live in 22 jurisdictions so incorporating this platform you know would allow the MGC to incorporate a platform that's been vetted out across you know multiple markets the systems compliant with all the GLI standards covering eye gaming kiosk sports wagering as well as a IT audit and also since the system is live in Pennsylvania Maryland New Jersey Nevada Illinois Ontario Mississippi Nevada has our legacy platform but our platform itself also complies with those unique requirements so it literally is covering you know the vast majority of any technical requirement in the sports waging this industry as well as the federal requirements such as you know the federal wire act and all the features regarding our gene self-exclusion and as far as the evaluation right there's a number of third parties and regulatory test labs that evaluate the product as well so GLI of course New Jersey Ontario West Virginia and Nevada as reviewed certain aspects of the system and you know we received approvals in all those those markets and as well as geolocation testing so prior to going live in Massachusetts you know we would have the mobile app the website evaluated for geolocation within the borders and you know the surrounding borders because massachusetts is the area is close to a number of states and there's a dense population the system has ability to identify whether a player is say they're they're sports waging and on the train and they go into Connecticut there are checks and balances within the system that identify if that person's on a train and they pass into the state of Connecticut as soon as they attempt the wager the geolocation check will block them from placing that attempt with a massachusetts account. I'm excited so please so just you know as far as our regulatory approvals go it's been approved by lotteries tribal commissions and other gaming commissions and control boards as you can see here whether it's in a number of states where we incorporate our retail brick and mortar platform and our mobile and a website as well as some of the other markets where we only have retail sports wagering and you know such as a market like Kansas or New York where we have just the digital platform and then just to close out as far as the features go you know like our system encompasses all the features that allow for a great customer experience all the features that are identified within the regulatory realm and also we incorporate third party systems such as geocompy which allows us to review and audit anything related to geolocation across every single market those 19 jurisdictions as well as that product is also offered to our competitors so it's not only vetted out against a Caesar sportsbook but it's also an offering that is incorporated across the industry. Here's another look at our wagering catalog so on the right is our website and on the left is our iOS platform so it has that same look and feel and also there is you know with a number of operating platforms there's a dark mode so you know you can have that that different look and feel and to highlight some of our cybersecurity and operational audits we do contract bulletproof to conduct assessments against July 33 and our operational audits so within July 33 there is vulnerability and penetration tests so that third party evaluates any access point to the system whether it's you know customer facing users facing or it's the network for our servers and you know access to our data center also there is a review of the information security management systems those policies so say if we have an update in for a policy in Arizona and there's a security enhancement we would incorporate that security enhancement across all markets so that you know we raise the bar across the board so that our IT policies would be you know migrated to a state such as Massachusetts and with that I'd like to pass it off to to Ken Fuchs. Thanks everyone. Thanks Floyd it's Ken I'm back just very quickly I wanted to touch on Nick walked through the registration process and you know that system for us is obviously a critical component to onboarding and protection of both customer and business in most of our jurisdictions for know your customer we work with Lexus Nexus there is two jurisdictions well one one current one pending where we work with geo comply where we pass the information to them and they do all the proper validation including age social security number date of birth last name as exact matches as well as fuzzy matches around address and first name to ensure that the person signing up is a person that is intended to be signed up should there be any issue in terms of the information that has passed back for the customer we do have a secondary waterfall in the app where they can provide a selfie picture as well as a valid identification such as a driver's license that can then be matched in certain jurisdictions most of our jurisdictions that is powered by a partner called on Fido and that provides a secondary opportunity for the customer to be validated as a valid customer we we also have a final check which is manual with our customer support team where a customer can provide additional documentation such as tax utility financial banking information to verify that they are who they say they are so we have multiple checks Lexus Nexus is obviously a a world-class company but we also have other companies we work with that are are well validated in this space around KYC and as Nick walked through we've made a lot of efforts to improve our registration flows to make it as simple and communicate very clearly with the customers they go through that sign-up process and well obviously we touched on payments of wallets you know we know from our research that this is one of the most critical components it's the ease to get money in and out for customers we've we've spent a lot of time improving both the options we have but also the team itself we've grown the team substantially over the last year and a half and we add 24-7 capabilities and and and oversight with people so that anybody who wants a withdrawal processed can do so 24 hours a day we process almost all withdrawals within an hour or two on our side and then depending on the method that you've chosen to withdraw that governs when the dollars would hit your bank account so we talked about real-time debit card withdrawals that's the fastest it's it's fairly instantaneous once we approve and then the other ones are really dependent on the institution so online banking typically takes a few days for the bank the process paypal is is fairly immediate and so on and so forth we're working through a lot of our our designs you can see here these are designs that will launch you in q1 we want to be very transparent with the customer around the timing for when they can expect their funds based on on the the choice they've made in terms of withdrawal and also be clear obviously on the deposit side the various options they have and their ability to toggle between different options and lastly from an operational standpoint i wanted to touch on our trading team we showed the betting catalog and nick touched on on some of the bet off and and other components of trading you know it starts with people this is a 160 170 person team that we've been building out we're very proud to own this function i think it's a critical function to have in-house because it is the beating heart of what we do so it's a team that works 24-7 with operations mostly out of las vegas and we have we're organized by sport leadership so that we have subject matter expertise across various sports and a very clear kind of career tracking so that we have strong experts and experience at the top and a lot of training in fact in the last year we built a trading academy specifically for onboarding and trading there is you know quite a bit of change that happens around around trading in terms of how we approach matches we handle almost 200 000 different events a year with millions of different markets we take hundreds of millions of bets coming in every year the team really does two things it does odds making and risk management so they are managing what i would call our book of liabilities understanding all the bets coming in where we sit in terms of those bets around a variety of different markets they're pricing actively pricing they're managing all of our data integrations with our partners they're making limited adjustments they're managing our futures markets so will the red sox win the world series next year we keep those markets live up until almost up until the event itself so they're constantly changing in terms of their odds they're working with our our analytics team around the models we use around pricing and we do a lot of integrity monitoring in a partnership with us integrity as well and then they're also managing all wager acceptance so much of this is seamless and automated it's extremely fast as you saw with nick making a bet there are bets that might exceed a limit a published limit or and it's not a published limit but exceed a set limit those are sent for special approval by a trader that that is all recorded so we know who does what in terms of the auditing around those decisions and we obviously want to make sure that the customer has funds in their wallet and then it's a bet that that we want to take thank you that's all i have for this part of the presentation i believe i'm turning it back to jeff hendrix thank you ken we just have a few more slides before we get to our summation i wanted to note that we have also over the past several years since acquiring our digital business grown an anti-money laundering team in-house to scale with that business we're very proud of that team pardon me so our in-house team provides all applicable federal AML requirements that will be ready to do so in massachusetts those will include CTRs KYC reporting and SAR reporting that team applies industry best practices and follows an integrated enterprise-wide program we believe is on par with anything in the industry the last main section i want to touch on is the our review of the suitability of america wagering ink and our key qualifiers as applicants we hope that through this presentation and through any additional questions that we can answer for you in the next sessions that we have provided sufficient information demonstrating that we have been found suitable in multiple jurisdiction we possess all attributes of integrity honesty good character reputation that the business is financially stable operates with integrity provides substantial benefits to the commonwealth that we have grown our sports wagering operations in multiple jurisdiction and that we have provided all relevant information within our applications including that relating to ongoing litigation none of which would have any impact on our ability to offer high quality operations within the commonwealth so with that i just want to briefly summarize to state that we hope that we have addressed each of the key elements within the commission's consideration here today i also want to note that i appreciate all of my colleagues time on this you've heard us mention our colleague lisa several times on this call she's been managing this presentation she's our director of licensure we could not do this without her so i just want to express my appreciation for some of our remarks so with that we thank the commission very much for its time and we respectfully request uh in accordance with all relevant regulations and after evaluating our license application this presentation and any additional questions if the commission find american way during ink it's key persons in any affiliate companies suitable in accordance with relevant regulations and grant us a temporary license so with that we've included our presentation and i thank the commission and staff very much for its time church don leader thank you thank you to all the presenters very very helpful very clear commissioners we held our questions it is 12 30 and normally we take a short break um and then here from gli uh iab and in our sound i'm wondering if we take a lunch break come back here from our internal team and then go into our section by section analysis how's that sound i think it makes sense since we really started at nine this morning instead of 10 right right i know the presenters but well i suspect that they they may feel the same need to take a bit of a break after their their comprehensive presentation it was excellent so that's um uh plan to reconvene at one one p.m. and then we'll go more straight through without a sort of a second intermediate break thank you i don't respectfully aren't ma'am i may need that still madam chair but i do think it makes a sense to break for lunch now oh no i'm just saying we may take intermediate breaks during our our um our review before i had a break to that after the presentations by the three so we'll see yeah see how we go of course commissioner brian thank you so much um we'll reconvene it at one p.m. thank you thank you very much next day all set thank you i was getting some good technical support prista thank you missus i hope you have a nice break we'll do our um our check-in this is a reconvening of the mass choose this game commission um public meeting number four 11 because we're holding this on a virtual platform um i will take a little call commissioner brian hi i'm here thank you commissioner hill i am here good good afternoon good afternoon thank you um mr skinner you move thank you good afternoon i'm here and commissioner maynard good afternoon madam chair i'm here and thank you for the popcorn during the break going it has a little chocolate in it and i'm feeling like it's i feel like it's all over my face um so good um okay we'll get started we um ended with the presentation by the applicant thank you so much now we're going to turn to the presentations and analyses that are offered by first gli our own i eb and then rsm providing services for us on gli was the first to write and set gaming technical standards which are now considered to be the industry benchmark worldwide gli has continuously responded to the industry by innovating new standards and testing allowing regulators to build confidence that they are providing a safe responsible method of revenue generation for their stakeholders and preserving integrity and i will let you um gli introduce yourselves and we also have um our very own jibu gomes who is our chief information officer who is available for questions as well thank you good afternoon madam chair members of the commission it's going to be with you again kevin malale senior vice president of government relations and general counsel for gli um we we are familiar with the platform that has been presented to you here today having uh tested it for uh other jurisdictions with similar uh requirements uh as you have before you in massachusetts including gli 33 the technical standard that you have adopted um in addition to that experience and and confidence level the platform is capable of meeting uh your requirements there will be essentially three phases of testing one it will be tested and evaluated the the actual local deployment in massachusetts will be tested and evaluated against the technical standards and other regulatory requirements for online platforms and it will be certified and that certification will go to your lab in addition to that there will be extensive field testing that will validate the functionality and compliance of the geolocation solution the kyc the responsible gaming uh features the security and other related um technical requirements that need to be tested in the field and finally uh there will be a review of the ongoing operational internal control standards and their capabilities for compliance with all your operational risk control uh compliance requirements and so with that i will turn it over to joe buniveth who you have been quite familiar with over the past few days and he could go through the details of the testing plan for the platform thanks for having us madam chair and members of the commission uh my name is joseph buniveth director of client solutions for gli i'll give you a view of the submittal search certification and verification process regarding mobile applications of the digital platforms to be approved by the commission before gli could take submittals and mass chooses gaming commission must approve 205 cmr 138 238 247 and 248 which redrafted in consultation with your staff in and outside law firm after approval the operators will prepare to submit their code bases for the entire sports wagering systems that they intend to deploy in the commonwealth the submittal preparation includes the following if it is a platform we're familiar with a modification list from the last submission to one of more one or more us jurisdictions will be requested and reviewed to set the project and and reviewed to set the project plan for massachusetts considering any changes to the platform and all specific massachusetts rules and regulations if the product is new to our lab we will review the technology architecture documentation which is a complete comprehensive and technically accurate description explanation of all sports wagering systems this includes a description of hardware devices and virtual servers of a description of all server and client software modules including the software versions the layout of all network communications between various software and hardware mod modules and an explanation of all third-party integrated systems post the technical documentation review the critical files regarding compliance will be identified and documented then a complete project plan is put in place taking account the unique architecture and design of the platform in the specific rules that were approved by the commission the lab will run a supervised compilation of the source files the signature of those files and the combination steps and the signatures of the compiled code once complete the source code will be submitted for testing in a lockdown test environment gli review the player account management platform known as the pam for registration age and identification verification account controls payments reporting responsible gaming controls required disclosures and geolocation the geolocation testing commits into parts a field test to verify borders through sampling along the entire border while completing edge case technical tests the field tests will also cover any restricted areas as defined by the messages this gaming commission a subversive as the second part will include a subversive workaround detection that will commence in the lab including but not limited to VPN and proxy usage gpf spoofing code manipulation and man in the middle attacks gli will then verify the sportsbook in total if not tested previously for retail deployment or review the integration of the sportsbook into the pam for events markets point spreads bed excess acceptance and corresponding time spans and logging of those events we also verify the enforcement of all betting limits and run against all edge cases we'll verify the pre event and live data feeds post event bed settling the corresponding time sense and logging and reporting of those instances we'll then review the change management process and procedures after all the technical checkoffs are met certifications can be issued when gli verifies the changes made for massachusetts specific deployments including source code differential and change testing to the the latest review version and gli has evaluated the products has met all the massachusetts specific requirements after certifications are issued and mgc accepts them field verification will be conducted in conjunction with the mgc this procedure will be finalized in the upcoming weeks during that time the following will commence verification at the production server and verification of all critical file signatures reviews of all internal controls for procedures to operate the sportsbook we'll check technology for configurations such as proper setup of roles in user rate rate assignment and potentially interview key personnel to ensure they know and will follow procedures of the internal controls at this point when they have met the technical requirements for the operations of the sorry they will have met the technical requirements for the operations of a sportsbook in the commonwealth that's it Kevin and joe seven are you also are you trying to maybe you're trying to unmute there we go yeah and that concludes our presentation and we'll have to answer any questions you or the commissioners might have I should only hold questions until our review or any questions now okay I just have one basic overarching one which is given their presence in the market and your presence in the market is there anything that raises concerns at all for you in terms of technological capacity of their platform or their product um now I mean um talking about because there are so many locations I'm assuming you've crossed paths with the company and their technology in your work and so I'm assuming that there's nothing that you're raising in terms of the presentation to us the process that you're going to follow there's no reason to have any bells and whistles going on from that regard right now in every jurisdiction where they've launched we've been able to complete the testing on time and before this stated launch date of that particular jurisdiction thanks yeah thank you okay thank you uh Kevin and joe and and Matt thank you so much okay then um there are no further questions for right now anyway we'll move then to uh our IEB and I believe is it director lilios or is it hi chair it's myself it's um loretta uh I'll be doing the presentation today okay thank you it's nice to see you director lilios thank you so I'll jump right in and the IEB submitted a report regarding the preliminary suitability of this applicant uh american wagering ink or caesar sports book in connection with their application for the category three license to be tethered to the category one licensee on core boston harbour the IEB performed our review for preliminary suitability in accordance with the standards and criteria set forth in 205 cmr 215.01 subsection two a full investigation for durable suitability has not been performed at this time as a precursor to our review the licensing division in conjunction with the IEB performed a scoping review of the applicant under chapter 23 n section 5b and we identified one entity in five individuals to designate as qualifiers in conjunction in connection with the application and those qualifiers are listed on pages one and two of our report as explained in footnote three of our report we inadvertently omitted the parent the ultimate parent company caesar's entertainment ink from the list of qualifiers and that entity's application is forthcoming I'll have a few more things to say about that but for for right now please note that the company is working on an expedited basis to complete the parent company's bed despite the omission because caesar's entertainment is a public company investigators were able to rely upon sec information for this preliminary financial review and that is consistent with the process that was used for yesterday's applicant as well and also I wanted to note that the individual qualifiers associated with the ultimate parent company were identified and are part of this preliminary review so the licensing division has performed a review of the existing submission for deficiencies and there is some ongoing communication with the licensing division in the applicant but the applicant has been extremely cooperative and responsive and that is including preparing this additional submission for the ultimate parent company on an expedited fashion and there are no substantial deficiencies to report again other than the the ultimate parent company which was my error and and not the not the applicants so as I said we're performing we perform the review in connection with the in conjunction with the reg and that reg is reproduced on page three of the report we utilize the same team of investigators for all category three applicants we are using them and the team is comprised of contract investigators including former members of rgeu and contract investigators from the firm of rsm and their work of forces being performed in collaboration with the ieb and under the oversight of the ieb the review for preliminary suitability is summarized in the report and it includes a summary of cesar's licensing status these are sportsbook's licensing status as disclosed in its application a summary of their compliance history and other jurisdictions as disclosed in their application summary of their pending litigation over a hundred thousand is disclosed in the application i think there is was non reported where the applicant was listed as a defendant an open source review of the applicant and the individual qualifiers although pursuant to the reg this did not include the entity qualifier and those are summarized in the report and there are some me links to media articles also the team from rsm prepared a report on preliminary financial suitability that appears in exhibit one and that report summarizes the review of disclosed financial information and in this case again as i mentioned those disclosures are supplemented by the financial filings of the publicly traded parent company also rsm presented financial ratios and reviewed the forecasting submission submitted by the applicant in its general in the general application i did want to note two different areas of the report um orally for my presentation now the first is i wanted to bring your attention to page eight of the report and the applicant's self report of its withdrawal of its application in massachusetts in 2013 at that time cesar's entertainment corporation uh the predecessor ultimate parent company uh at that time and some of cesar's top executives were qualifiers in connection with an application for a gaming license in massachusetts and at that time the iv performed a full suitability investigation over the course of many months and identified four areas of investigative concern as self reported by the applicant here today the iv recommended in 2013 that the commission holds an adjudicatory hearing to determine suitability because of those um four uh areas of concern and cesar's withdrew its application before the hearing occurred so no determination on suitability was ever reached so that's an important point right they were never found suitable they were never found unsuitable uh in massachusetts now for purposes of this preliminary review for a different the 2013 investigation and i have spoken to uh executive director wells about this matter and of course she was the iv director uh at the time but i want to point out that the iv recognizes that 2013 was almost a full decade ago and the company has significantly evolved since that time they have evolved financially and uh financial concerns was one of the identified concerns in 2013 since tha