Dave, whenever you're ready. All right, I just hit the go live button and we are good to go. I'll set Dave, not quite. Okay, excellent. Good morning. This is the convening of the Massachusetts Gaming Commission because we are holding today's meeting on a virtual platform. We will take a roll call. Good morning, Commissioner O'Brien. Good morning, I am here. Good morning, Commissioner Hill. Good morning, I am here. Good morning, Commissioner Skinner. Good morning, I'm here. Good morning, Commissioner Maynard. Good morning, Madam Chair, I am here. Excellent, we'll get started. Today is December 13th and it is public meeting number 411. And before we get started and turn to our general counsel, I'd like to make a few introductory remarks. For those of you who have already attended some of our social, I'm sorry, our sports wagering application evaluation discussions, they'll sound familiar, but I think it's important for us to reiterate these remarks because today involves a new applicant and new stakeholders. As we begin our evaluation of this application, we as commissioners are reminded of our principal responsibility to ensure the public confidence in the integrity of the gaming industry here in Massachusetts and the strict oversight of the gaming establishments and now sports wagering operators through rigorous regulation. We are reminded that the MGC's licensees will be held to the highest standards of compliance, including an obligation to maintain their integrity. As we have said in the past, the award of a gaming license in the Commonwealth is a pure privilege. And our laws require gaming licensees to be held to those highest standards on a continuing basis. 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. I've said this before throughout the week last week and I'm going to take the opportunity because I'm given the chance and I'm going to take that opportunity to thank again my fellow commissioners for your commitment to that MGC mission and for your thoughtfulness and diligence today and over the next several weeks as we continue to evaluate these applications. I feel very fortunate to serve with each of you, particularly as we work tirelessly to implement this new law with the public's interest in the forefront. And then as I've said to our team and I'll repeat this and I know my fellow commissioners join me in recognizing that the last several months and the months ahead have been demanding and will continue to be demanding with this team of excellence. We are all very grateful for your contribution each of 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 will 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 we will have WSI, US LLC, doing business as WinVet, present us with its application for category three, Heathered License, using 205-CMR-218.06 as guidance. After that presentation, we will 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. That will lead us to a section by section analysis of the application during which the applicant will answer our questions. Staff members and our legal team in addition to GLI, IEB and RSM will also be available to answer questions. To ensure that we have ample time to reflect, finalize any personal notes and memorializing our impressions and follow up with any unanswered questions. We may break for five minutes at the conclusion of each section. Then, after any further questions for purposes of review of the category three applications, I'll speak 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 the general counsel, did the applicant meet expectations or did the applicant exceed expectations? That 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 support in our agenda. Should we vote to go into an executive session? At this time, it is anticipated that the public session of this commission meeting will reconvene today. 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 group. With that all said, I now turn to the general counsel, Bruce, good morning, Todd. Thank you, good morning, Madam Chair, commissioners and to all who are joining us here today. Of course we're here so that the commission may evaluate the applications received for the category three, tethered sports wagering operator licenses submitted by WSI US LLC, which does business as WinBet and from American Wagering Inc, which is affiliated with Caesars Entertainment Incorporated. Prior to commencing the review, however, it may be useful to set the stage by walking through the legal principles and provisions that will inform the commission's decision-making. So with that, I'll highlight a few of the provisions of the Massachusetts Sports Wagering Act, which has been enacted as chapter 23 and of the general laws, and then a number of sections of the commission's recently adopted regulations. 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 in the rules and regulations of the commission. Provided, however, the commission shall issue no more than seven category three licenses that are not connected to a category one or category two license. In the present matter, the two applicants are each connected to a category one licensee, specifically WinMass LLC, which was awarded a license last week. We've used the term tethered to describe that connection. That means that the seven license limit does not apply to the type of licensure that the commission is evaluating today. Before we look at the commission's regulations that govern the licensing process for a category three applicant, let's establish what a category three sports wagering operator license is. 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 for a mobile application and other digital platforms approved by the commission. Just to place the present applications in context, it's important to recall that a category one license holder, such as WinMass LLC, is permitted to conduct sports wagering operations through not more than two individually branded mobile applications or other digital platforms approved by the commission. A provided that the mobile application shall be qualified for an issue to category three license. So the two applicants before the commission today seek to operate those two digital platforms that go along with Win's category one license. Let's have a look now at the commission's rules and regulations that have to be met by the applicant in order to be issued a license. And the best place to begin is with 205-CMR-218, which as you know, is the section that sets out the application requirements, standards and procedures. The process itself has of course already begun. An administrative sufficiency review was performed upon the submission of the suitability portions of the application. And then the commission convened a public meeting 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 to award the licenses. Prior to doing so however, 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 and considerations set out in the regs, but need not do so in any particular order or give any individual factor any particular weight and can in fact assign a factor no weight at all if deemed appropriate. Next to recall 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 evaluating the information provided in an application relative to a particular factor and you determine that further information is required, you may direct the applicant to provide it. Similarly, in the course of the commission's evaluation, if the applicant observes there is additional information that was not provided that may be of use to the commission, it may request an opportunity to provide that information. 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 format. That means a number of things, including that all deliberations 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 matters, 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 an operator license shall be public records under section 10 of chapter 66. Provided, however, the 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. 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 read 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 law and not the open meeting law, to require that the subject information be discussed publicly would nullify the whole purpose of the provision which is designed to protect such information against. Accordingly, application of the executive session provision I referenced is appropriate in this instance. 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 and an area in which a heightened standard is applied 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 evidence exists when the evidence induces in the mind of the fact finder here, the commission, a reasonable belief that the facts asserted are highly probably true and 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 the 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 will be in play during the evaluations before the commission here today. Now let me lay out the factors that are included in section 218. One way you may choose to work through the evaluation that will follow when we get to that part of the proceeding will be to take the application factor by factor and begin to draw conclusions as to the quality of the information supporting each one. You'll recall that the commission included some factors under each of the factors. Prior to engaging in final deliberations relative to any applicant may be helpful to outline each of these sub factors. So I'll not do that right now. The factors are included in section 218.06, subsection five. Each factor falls under the umbrella standard that the commission included in the regulations, which directs that in determining whether to award a sportsway during 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. But in reaching that conclusion, the commission provided that it will consider the following factors. And you'll recall of course that the application itself was designed so as to solicit information in each of these categories. The first factor is whether the applicant is to look at the applicant's experience and expertise related to sportsway during. The second is the economic impact and other benefits to the commonwealth that the applicant has awarded a license. Number three is the applicant's proposed measures related to responsible gaming. Number four is the description of the applicant's willingness to foster racial, ethnic, and gender diversity, equity, and inclusion. Number five is the technology that the applicant intends to use in its operation. Number six is the suitability of the applicant and its qualifiers. And we'll come back to this one momentarily. And number seven is any other factor that the commission in its discretion means appropriate. So those are each of the factors that will be reviewed as part of this evaluation. 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 for you today. So we won't get into those right now. I'd also, again, just like to circle back to the suitability factor for a moment. As you know, the commission adopted section 215 of the regulations to govern suitability determinations. And it included provisions allowing for two types of suitability findings. A durable finding of suitability, meaning the so-called final suitability determination and a preliminary finding of suitability. You may choose to award a durable finding if you conclude that the applicant in each of its qualifiers has demonstrated their 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 215.01 subsection two 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 a temporary license under the process that is described in section 219 of the regulations. The entity would not receive a full license at this juncture if they were awarded the preliminary finding of suitability. This process is intended to allow the customary full background investigation and a 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 the 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 the area may require to be supplemented with an appropriate condition. License conditions are described in section 220 of the regulations. And 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 the operator comply with chapter 23N and all of the commission's regulations. But there's also a provision that allows the commission to impose any other conditions that it determines appropriate to secure the objectives of chapter 23N and 20N25CMR. 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 applying for the license. Once that is done, the commission may decide whether to award the category three a license outright. It may determine that the applicant is eligible to request the temporary license while a complete suitability assessment is performed, or it may deny the application for failure to meet the requirement of the regulations or for having violated sections 6E or 9 of chapter 23N. And 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. It just permits for a tethered operation as to one of the category one or category two digital operators. At this juncture, after a decision is made, a written decision will be prepared and issued commemorating the commission's decision. And again, keep in mind that the award of a license or temporary license does not mean that the licensee has a green light to commence operations. It simply means that it would be eligible to work towards the award of an operation certificate, which is a prerequisite to conducting sports wagering operations. That process is described in section 251 of the commission's regulations and requires submission and approval of such things as the internal controls, including the house rules and compliance with any conditions that the commission may impose. So that's an overview of all of the rules, regulations and laws governing the award process and evaluation that you have before you're here today. I'll pause now and turn it back over to you, Madam Chair. Happy to entertain any questions that may come about as well. Any questions, commissioners, at this time? I'll set. Okay. Then we're going to go on to item number three. And this is the presentation that I referenced by Wendat and they're able, we are hoping too that they can provide us a demonstration of their technology. I ask that you introduce yourselves because I can't quite see your faces. So good morning. Good morning, Madam Chair, members of the commission and commission staff. Hello. I wasn't sure who was leading. So good morning, Jennifer. Good morning. I'm Jennifer Roberts. I am the vice president and general counsel of WinBet, which is WSI US LLC is the operating entity. And I am joined here today by Ian Williams, president of WinBet, as well as president of WinInteractive, which is the digital sports betting and eye gaming branch of its majority owner, WinResorts Ltd. and an affiliate to our sister company on Corvosten Harbor. We are also joined by Spiro Costopoulos. He is WinBet's chief operating officer who has just under nine years of prior experience with Caesar's entertainment, including serving as chief of staff. WinBet is honored to appear before you today to highlight our business and to demonstrate our commitment to being a great partner to the Massachusetts Gaming Commission and the Commonwealth as a category three sports wagering operator and vendor to on Corvosten Harbor. So I have a presentation to go through. And thank you to Seth Medman, our director of marketing who is helping that. So WinInteractive is a proud part of the WinResorts family, which is the parent company to WSI US LLC, which again does business as WinBet. And we will refer to our entity by our trade name of WinBet throughout the presentation. WinBet shares the same goals of our parent company and its domestic luxury properties, win and encore Las Vegas and encore Boston Harbor to bring a superior experience to our customers. This commitment to excellence is driven by an executive team with substantial experience in the US regulated gaming and sports betting industry. So prior to WinBet, Mr. Williams was the Churchill, was with Churchill Downs Interactive for seven years and recently served as president of its online gaming division and has also spent several years working in the online gambling space, primarily in the US, but also internationally. And I am honored to have spent 20 years practicing gaming law with a particular emphasis in sports betting and regulatory compliance, including in academia as a role at the UNLV International Center for Gaming Regulation on the regulatory side in Tennessee and as outside counsel to gaming companies. So through our experience together with the rest of the leadership team, we recognize the importance of being a collaborative partner with our regulators and we all benefit from a well-regulated transparent system and we respect the tremendous work that this commission has undertaken to commit to the sports betting industry. So WinBet had entered the market in July, 2020 and is currently live with mobile and internet sports betting in nine states. We are conditionally approved and looking to launch in several more states in 2023, including Maryland, Ohio, Pennsylvania and West Virginia and we have market access deals for launches beyond next year. Together with WinResorts, we are invested in the continued growth of WinBet across the United States, but are particularly excited about sharing a presence in the Commonwealth with our sister property on Corvost and Harbor. Another initiative that WinBet and its leadership embraces is that of diversity, equity and inclusion. And just as you heard on Corvost and Harbor last week, WinBet works closely with Glenda Swain, the vice president of diversity and inclusion for WinResorts Limited. She has time specifically dedicated to WinBet to help promote diversity and inclusion and hiring, community engagement and other parts of our business, as well as ensuring alignment with the initiatives of WinResorts. WinBet also has representation on the diversity and inclusion advisory council with our other corporate operators of Win Las Vegas and on Corvost and Harbor. And we greatly benefit from the overall corporate focus on diversity, equity and inclusion and are excited about the progress we have seen despite being a relatively new entity. As an operator, WinBet is committed to protecting patrons through our options for responsible gameplay. Our employees, regardless of whether they interact with patrons are trained on responsible gaming upon hire and receive ongoing training during their employment. We also have an internal group within the legal and compliance department that reviews any problem gaming concerns. When it comes to marketing, WinBet follows the American Gaming Association's responsible marketing code for sports wagering and is familiar with this commission's applying principles of the Massachusetts responsible gaming framework to sports wagering policy and practice. We are also active members in the national council on problem gambling. And during our product demo, we will show the variety of tools offered to our patrons, which includes self-exclusion, wagering limits, deposit limits, time limits and cooling off periods. WinBet also strives to engage in responsible marketing. We were one of the first operators to share publicly our slowing in advertising and to significantly reduce any irrational marketing spend. This included greatly reducing TV, radio and out-of-home advertising spend and unsustainable bonuses. This revised marketing approach has been beneficial for our business and long-term sustainability. Currently, WinBet primarily markets through the following channels, detailed affiliate marketing, paid social media, partnerships and field marketing and the WinRewards loyalty program. And WinBet will comply with any and all regulatory standards set by the commission in this area. As it relates to marketing affiliates, the WinBet team is responsible for ensuring that marketing materials have been pre-approved by WinBet. This language is included in our contract with each affiliate and can lead to a termination of that contract if not adhered to. Internally, we monitor affiliates to ensure that they are in compliance. Being part of a luxury brand means that our patrons can benefit from our shared loyalty program, WinRewards. WinBet patrons earn opportunities through gameplay for on-property experiences such as room stays and dining credits at the WinLos Vegas or Boston properties or they can redeem for free play within the WinBet app. We will demonstrate this during our product demo as well. WinBet is currently partnered with three NFL teams and NASCAR. We're excited to work with Encore Boston Harbor to support the local sports community and expand existing relationships with Massachusetts professional teams. So now we will give a brief overview of our product before we get into the demo. All of these tools and benefits are represented within our WinBet product which is offered through a variety of platforms, iOS, Android, desktop, and mobile. WinBet offers wagering on several sports with a wagering catalog that's tailored to what is permitted by the regulators of each state where we operate. And we're excited to be working with White Hat Gaming as our player and account management platform. They will be the provider for that system and GAN will provide the sports wagering platform. And these companies have been licensed in multiple states and are familiar with the US regulated environment. And this technology stack will provide an improved user experience with WinBet by operating within a single app and providing a streamlined back office that will allow our customer support, payments and fraud and trading teams more efficient service. And as our technology continues to be developed to integrate specific regulatory requirements of this commission, prior to the demo, we would love to show you briefly what the Massachusetts sports wagering patrons will be seeing while interfacing with the WinBet app. This includes the sports wagering screens, as you see here. The first introduction to our app for registration for an account, what a patron experiences upon login, what promotions they may be eligible to opt into, the WinRewards interface and finally account information. So that concludes this portion of the presentation and we would now like to move into a product demo of our current WinBet user experience, which will include a highlight of our responsible gaming tools. Does that work for the commission at this time? Okay, so Adam Harmer, our executive director of product management will now walk you through what a patron in New York would see with WinBet. Jennifer, thank you. Good morning, everybody. Very pleased to be here and showing off the WinBet product. I'm gonna be sharing my mobile device, so hopefully you all see this on screen now, everybody. If you give me a nod, it should be up. You should be seeing the WinBet product. Okay, great. So agenda for the demo, we're gonna start with registration. I'm gonna talk through the registration flow and all of the patron information we request to create the patron file. We'll talk through KYC Know Your Customer and the process we go through. We'll then talk through the sports book. We'll place some wages and show you how the navigation works. Then we'll focus on responsible gaming, as Jennifer alluded to, going through all the various tools that we have. I'd like to show you a little bit around maybe the different deposit methods that we have, how our page reviews their account history, and then we'll finish with win rewards and promotions. I'll stop frequently. So if you have any questions on the go, you can just jump in, or you can stop me yourself.  Okay, Palmer, I will encourage commissioners to perhaps ask questions during this operation if you think it's helpful in real time, rather than holding till later. So we've been holding our questions, hope this might be helpful for folks to jump in. Thank you. Perfect, okay. So I'm gonna start with the registration flow. As Jennifer said, that all of this is, this is the New York flow, but it's all very customized to meet whatever state regulations that you set. But I'll be giving you a general example of how this is currently configured with the New York version. So the Patreon file, there's three steps to our registration. We start with the username. So this is what they will log in with, along with their password. We have validation here. So for example, if I enter a username, which I know is already in use, there will be an error message for the Patreon. So this has to be unique then it can only ever be a unique username. So let me set something which I know is not in use. And we'll move on to the password for. The passwords are again configurable with this configuration, it's a minimum of six characters, max 20, at least one number one letter. So if I enter something such as this, it will be rejected. If I enter without a number, it will be rejected. If I had a number, it's now within the valid combinations, that is allowed. As I said, that would be configurable based on your specific regulations. Email, again, this validation checks. So if I enter something which is an invalid format, that will be rejected. Again, this needs to be unique. So you can't enter the email address of someone else, of an email that's already used somewhere else. I can quickly show you this because my email is active. Okay, so that's already in use. If I take this out now and we'll be able to proceed. There's a responsible gambling logo and the localized help number as well, always in shell on the registration flow. So moving to the second stage, this is where we request personal information from the patron. In this case, I will enter some information, the date of birth. So the date of birth is validation on the basis over 21 years old to be wagering. So if I enter a date of birth, which is less than 21, that will be rejected. That's invalid. If I correct it to something which is within the allowed range, it will now be green. And we'll move on to the cell phone. This is not my cell phone, just to be clear. And the last four digits of an SSN. And again, this is not my information. I do not have an SSN. So that's the second step registration. Most of the personal information for the patron, we start to build the file now and there's one more step which I'll go on to if there's no question so far. So third and final step is where we'll take an address. We do have a search capability where you can lock up your address. I'm gonna enter the encore. And the patron could manually edit this form if they need to. Sometimes auto search doesn't always exactly match your personal address. They could enter an end of field if they wish to. There's a promotional code areas. This is where we would offer a welcome offer to a patron depending on where they've come from. And there will always be terms and conditions as you can see. So this is for this particular welcome offer of bet 100 receive five and all the relevant terms and conditions are always accessible to the patron with one click. I wasn't gonna scroll down and talk through these terms and conditions. This is specific to a New York offer. So any Massachusetts welcome offer will have terms. They will be submitted to you for approval. Okay. So the end of the registration process is the checkboxes. So we have one which is optional which is the first one which is marketing opt-in. That one's optional. And then we have three mandatory. So the exact wording and copy on these again would be based on your regulations but we have that ability to show this kind of information except in terms of use, various statements that the information is accurate and they're over the age of 21. So without accepting all three of the mandatory they cannot proceed. As you can see the complete registration will now become available again since I've tapped all three. And when the registration is completed we'll talk a little bit next about KYC in quite a lot of detail, know your customer. I'll pause here again the terms of use. So these are obviously accessible and readable. These are the account terms and conditions which would then be customized for Massachusetts. So that's the page of information we collect. Does anyone have any questions so far? I'll ask a question with respect to the RG language down below. If you click on it, does it get bigger? Like the terms and conditions are just as static. That's on this is just static. Yeah. Thank you. It looks bigger on your own device. I've got my phone here. When you screen share it can look a little bit smaller. Okay. Thank you. If we needed to change the font size that depending on your regulations, that could be done. That would be trivial. This is what was approved, yeah. Thank you. Thank you Madam Chair. What does it say? I can't read it. So the response for gambling or we'd like to read through the check boxes or all of it? No, the responsible gaming bottom. Sure. So this says for the purposes of responsible gambling this website provides you the ability to set limits on your activity. If you're interested in implementing responsible gambling limits such as deposit loss and time limits as well as cooling off periods or self-exclusion from online gaming please look for the responsible gambling logo or the responsible gambling page for additional information. So that's only accessible once you've logged in. I will show all of that a bit later. Yeah. And that text could be customized to any word that you require. And the hotline information is provided at the bottom as well. Yeah. 187-8 Hope, New York. That's the New York version. Yeah. Very helpful. Thank you. Other questions? Will you pause? Thanks. Okay, shall I continue? Yes, please. Thank you. So the next stage is what would happen? This is a production New York so I'm not actually going to complete the registration. Okay, I'm just going to talk over what would happen when that was completed. Because there's lots of checks and balances which will now occur in real time in the background the moment the potential patron presses that button. So to start with first of all all of that patron information which we've just collected is all put into a file and it's sent to a KYC provider. Now the exact provider it will use fair is state by state. It will depend on vendor registration and your regulations but they all operate very similar process. So we send the information to the provider. They will then first of all try to return a full SSN-9. Okay, so all that information, the SSN-4 come back with the SSN-9 for that particular patron. That's the first step and that could be successful or not. Not really relevant for the next phase. I will explain why, but that's the first process. Then we go through our automated checks. So these can happen in different orders but generally the way we set it up with other state regulators is it starts with a duplicate account check. So generally the regulations will only allow a patron to have one account with that state. So all that information is checked. If it's a duplicate account that already exists, you know, the patient will be told and the registration doesn't proceed. Let's assume that's negative. There's no evidence of a duplicate account. And the logic on how we do that will be in our internal controls. By the way, again, it's kind of customizable. Next we go through the band person's list. So we'll look to do a PEP check, we'll do a sanctions check, search for deceased people with those details, search for prohibited people and a self-exclusion check. So we kind of go through all of these checks all in real time. And if any of those match, then depending on the match, there'll be a slightly different action, but in short, that patron will not be able to deposit or wager. Okay, it would basically put a block on that account because of a failed check. Do you have any questions so far? I can continue talking about the actual KYC itself assuming all of those were negative. Okay, so next now is the KYC provider again. So how it works is they come back with a score. You know that, I just want to make sure you know, we are seeing the same screen. It has a search, you know that, correct? Yeah, because everything's happening in the background. Maybe it's better if I just stop sharing my screen for a moment. Yeah, that would be better. Thank you so much. That's better, I apologize, of course. So next after this is the actual KYC score check. So a bit like a credit check in that state by state will depend, we will come back with a score from the KYC provider. If it's over a certain threshold, that account is classed as verified. They can then proceed to deposit, wager, unrestricted. If it's below the threshold score, then that is a fail. That means that the KYC provider was not confident enough with the information provided that we know who this person is. In that case, they are blocked from wagering and they will be requested to upload documentation. Generally, two pieces of documentation are proof of address and a proof of ID. Generally, the ID would be a passport or a driving license, photo card driving license. Proof of address can be a bank statement or a recent utility bill. I mean, there's various combinations. They would again depend on your regulations as to what you accept. The patron uploads these documents. One of our fraud and payments officers reviews that and they then make a decision based on our internal controls. Do they, are they now happy that we know this customer? Can we now approve them for wagering? Do they need to request more information, et cetera? Obviously, there's many things which could happen operationally. And that's the end of the KYC process at the end of the day. That's how it works. Questions, commissioners? I'll ask a practical question in real time. How long is that process? I'd like to say less than a second. The patron won't notice. I mean, instant, almost, yeah. Okay. One thing I'd like to add as well is that, again, that this scorecard, if you can call it the KYC scorecard, as to what is a pass and what is not a pass, all configurable, you know, based on the state. So each state we operate in, you know, some have slightly different scorecards, but it'd be configurable based on your requirements. Madam chair, I don't know if this is for now or for an executive session, but what percentage of people do not make it through that are trying to get on that do not make it through that's something I'm interested in? I think we would like to discuss that in an executive session and provide that information where we can discuss it freely, if possible. And if possible, we could reserve that for after the completion of the demo and any public forum questions. Commissioner Maynard, are you okay to bring a pen in that one as we've done in the past? Absolutely. Okay, thank you. Thank you. Any more questions? And I will continue. I'll set commissioners. Thank you. Thank you. Okay, let me go back to the screen share now. So we're now going to jump in. I'm actually going to log in to an account. It's a test account. So there's a test account process in all states where certain test accounts can be approved to Wager. I'm going to log in first of all and you may have noticed I just logged in with Face ID. So again, state by state, this particular state has allowed us to use Face ID login. So I'm now logged in. So this is the home of WinBest. You can see at the top where we have the balance, it's a $95 and a few cents. If we tap on this, this allows takes us to the wallet area and the cashier. This is where the patrons can deposit funds. So because this is a production account, I'm not going to actually make a deposit, but these are the some of the methods that we offer currently. And again, based on vendor approval, based on your regulations as to which methods you allow us to use online, but we have many options. The most common are shown before you, debit cards, online banking, a PayPal, generally the top three. We also offer ACH, Play Plus, and we can do wire transfers and things like that, but it will depend on the internal controls. So they're the methods that we'll be offering if we go back to our homepage sportsbook. So working from top to bottom, you have the search area. We have quick links. This is where patrons can quickly jump in. Let's say they want to jump in direct to NBA. This is now all the NBA content which they can waiter on. We have promotional banners and information banners. So this is a carousel, which I'm just scrolling. We'll provide information to patrons. And then scrolling a bit further down, this is still the sportsbook homepage. Now you're starting to see events which patrons can wager on. This is obviously the 49ers game. They can see the odds. So these are the main markets we're offering. We offer more, which we'll go into. But if I just tap on this, you can see I'm now choosing to add this selection to my bedslip. I'll keep scrolling, I'm gonna add the Kings as well. And you can see in the bottom right corner, the total odds for the number of picks is increasing. That's showing them the parlay odds. So if we parlay those two together, the total odds would be plus three to nine. So it just updates in real time as they can select or deselect. If I now tap into that on the bottom right corner, this will actually open up my bedslip. So now we can see reconfirming to the patron. This is what they chose so far. These are the total odds. And this is where they can choose their wager amount. So if I can edit this, so I can make this $1, for example. It will show me very clearly the two win amount and the total odds. I can remove selections here as well. Let's say, for example, I just want to place a straight. I remove one, everything updates it. And this is the place where they would then place the wager, which I'll go and do now if there's no urgent questions and then we can pause for a moment. So $1 straight on the 49ers, the wager's now been placed. So this is their bed confirmation screen. This is where they see the receipt. So we showed you before what your wagering on. Now it's confirmed the bed is struck. Your balance just reduced by $1. You may have seen at the top and the bed's now been placed. So that bed's on. So I'm gonna exit the bedslip and then just show you where you can then confirm again that the bed was placed. There's two more places. There's a bed history. So that was the wager we just placed, $1 on the 49ers at those odds. So there's a record here for the patron and a historical record as well. So they can go back and view previous bed history if they wish. The second location that we're gonna quickly talk through is your account history. So again, this is almost like a bank statement record. Every deposit withdrawal, every wager placed, any adjustments made to the account, everything will be shown here in an account statement. And we can see the $1 sportsboard wagers in progress. We also on this configuration have a profit and loss. So you can see on here in the last, this is in the last 30 days, this particular patron, this test account had wagered $17, returned $18.23, so they're in profit of just over a dollar. And you could filter different dates and look over a day, a week, a month. Can we go back last six months? Is the maximum within this configuration? Okay, I'm gonna go back to the homepage of our sportsbook. I'm just gonna show you another betting journey that we offer at something that's really popular with patrons. And let's maybe go into the Kings and the 76ers game itself. So now we can see more betting options for the patron. All of these are menus with grouped betting options, shall we say, all the player props are in here. The sports catalog as Jennifer already alluded to will be obviously fully customized to whatever your regulation state. But yeah, this is the New York version. And we have a product we call Build Your Own Pets, which is commonly referred to as the same game parlay. Very, very popular patrons allows you to pick multiple outcomes within a single game, event, match. And if all of those outcomes all win, you get a bigger price. Basically they're very exciting and very popular. So if I choose, for example, the Kings to win, let's pick some overs on the total player points for Melton and Harden. We get the price again in the bottom right corner. As you can see, if we tap that, we go into the bed slip. Again, we can change the wager amounts. It's confirmed, and we can place the wager. So that's a Build Your Own Bed, same game parlay, again, incredibly popular. And here's our bed receipt. Okay, that's a very high level view of just sports betting and the bed placement process. I'll pause there, but next I'm gonna go into all the responsible gambling tools that we have and talk through them one by one. But yeah, if anyone has any questions, please do ask. Pressure is all set. Thank you. Okay, so responsible gambling. So we have multiple ways for the patron to view the tools that wherever the RG logo is, wherever you see that, that's always clickable. So if you look in the top right corner, we've got a logo there and that will open the responsible gaming menu. There's multiple routes in, that's just one. The second route is from our side menu. Again, you've got a large RG logo in the bottom left corner. Again, that will take us to the same location. The third location to get responsible gambling is in the deposit and wallet area, which you saw earlier. Again, there's the RG logo down in the bottom. All of them take us to the responsible gambling menu. So I'll now run through each of these one by one, explain what they are, how they work and yeah, any questions, very welcome. So the patron protection area, obviously all of this content is customizable to meet your requirements, but this is a place where we explain the problem, the risks of gambling, some of the warning signs that you may have. There's lots of resources here as well, which can link out to New York Council on problem gambling, gamblers anonymous, lots of really interesting resources for the patient and again, the helpline number for that specific state. So it's kind of like a Wikipedia for responsible gambling information effectively and fully customizable. Next up is player limits. So there is three types of player limits that we currently configured to offer. The first is a deposit limit. So this account already has some set and I'll talk through and explain them all one by one and then we can change some of the limits and show you the message to the patron when they try and go over a limit. So deposit limit means depositing funds into your account. So if I have a limit of 200 a day, this is calendar day, calendar week, calendar month. Okay, so midnight to midnight, or Monday to Sunday, et cetera, and then it resets. So if you've got a limit of $200 per day, if you deposit $100 in the morning and you try and deposit $101 before midnight, it will be rejected. Okay, so it's like a cumulative amount you can deposit in that time period and then it could be weekly or monthly. The spending limits, so they are not connected to deposit connected purely to your wagering amount. So if it's again, daily, weekly, or monthly, it's the same logic, but if you go, if you place, if you cannot wager more in that time period than the limit you have set. So interestingly, this is already, we've already sold me placed some $1 wages earlier. I have a $200 daily limit and I will set a weekly limit as well shortly. It's already deducted to $4. Okay, that's why there's $196 remaining for me today because I placed $4 in wages today on this account. And then the time limits, this is to the amount of time you can be logged in. We only offer daily and weekly currently on this, not monthly. So if you set your limit to three hours per day, that's the, it's calculated from the second that you log in, start of a session until you log out. And obviously all sessions in the day are cumulative and added together. So it's a hard limit. You cannot be logged in to WinBet for more than this time period that you set. And as I say, that's done in hours. Sure. Is there a limit to the preset every time? So what's the minimum, what's the lowest? The minimum is in hours, the minimum is one hour. You can't go below that. Again, that could be a configuration we look at, but currently it's set that way. Max is 24 hours a day, Minis is one hour. Yeah. Thank you. And that's, you can preset them as determined by each jurisdiction, correct? Yeah. In other words, does your software have the capability to go below an hour? I can't see the reason why it couldn't. We've never been asked before.  So the daily limits, they all have cool-offs. Again, these will be based on your regulations, but for example, I will increase one of the limits, okay? So let's do a fresh limit. Let's use the weekly limit, which has not been set. So if I start this at $500, okay, that will take effect immediately. And again, it's retrospective. So this week I have waged $9 already, which is why there's 491 remaining. Let's say I now want to increase that limit. So if I wanna increase it to 1,000, which is basically making it less restrictive, that will never take effect immediately. So there'll always be a delay in that increase. Again, configurable as to how you need to do it in Massachusetts, this particular stay is 24 hours plus the rest of today in Eastern time. So that's why that's taken effect at midnight on the 15th effectively. So that's to protect the patient. If you wanna increase it, you can't do that immediately. You need to take some time and before that would take effect. But if I go the opposite way, if we now drop this down, for example, to 200, that's instant. Yeah, so if you're making it more restrictive, it's instant. If you're softening it, there's always some form of delay before that will take effect. And then I can show you that it's actually in working in practice. So let's drop the daily down all the way to 50, which means 46 remaining, because I do have enough balance to do this on my test account. So now if we go back to the bed slip and we try and wage a $50, for example, that's no longer allowed, okay? Because we've reached the limit for that particular day. At midnight, that will reset back to zero. We'll have up to $50 to play with again, okay? I'm gonna come back to the main menu. I can just do one more thing in the limits as well. So we do have, we do record the history change as well. So again, based on certain state configurations where you can see all the history of how you've been increasing or decreasing limits. Okay, I'm gonna come back to the main menu and then we can continue with cool offs. So the cool off is like a temporary break in your play. So these are the time periods we have configured here for this day. Again, these could be, they do vary. There's other states which have shorter, longer minimums or longer maximums. It really is up to what your regulation state. For example, if I chose four days, this one goes up, excuse me, to four weeks is the maximum here. So if I chose four days, what this is going to do is saying I just wanna take a break for a short period. They will need to continue and confirm. And if I action this, if I confirm and log out, I will be logged out immediately and I will not be able to log back in for that four day period until next time in exactly four days. So I can't log in whatsoever. If I want to withdraw funds, they can still go and contact our support team and they will help them. They can withdraw their money at any time they want, but not through the application. It's like a hard break in their game play for that period which they selected. So that's what we call a cool off. Next is self-exclusion. So a little bit different to the cool off. I mean, the periods are generally much longer. So you can see this example here. We have one year, five years or indefinitely. That's the three options which have been configured for New York. So you would need to choose your exclusion period. Because this is generally irreversible, we do put strong authentication on this in the form of last four digits of SSN and the zip code. So I will put these in now. So on this test account, that is the SSN. And I'm deliberately putting a typo in the zip code just so you can see, right, there's validation there. And that would be on the SSN as well if I now correct this. And there can be customizable content with regards to these, whatever we ask them to accept and acknowledge. And similar, I won't actually action this, but if they press the confirm and log out, then that account would be self-excluded immediately, removed from our marketing and based on the state regulations and the process they have for the statewide scheme. This could be two-way, this could then be sent off to the state regulators to go on the statewide exclusion list and then be excluded from all other operators, or it could be when that only self-exclusion, that depends on the regulation, how you would want that to work, but either is fine. I have a question, Madam Chair. Yes, if you will. So, Adam, on the cooling off, if you have, what's the periods again, how long did the period run? Sure. In New York, of course. Sure. Let's say that I have a really bad day and I decided to set a two-week period, but then I'm convinced that my University of Kentucky Wildcats are going to beat UCLA on Saturday, and so I want to uncool off. Is there a process for that? I hear that it's very restrictive on the one end. Is it on the cooling off? Is it as restrictive? Jennifer, I mean, there's nothing in the product which would allow them to uncool off as it were. Jennifer? Usually what happens is that they would contact customer support and then that is escalated to our compliance team for review to determine whether there's good reason to eliminate the cool off, but we generally take a position that the cool off periods remain for their protection. Thank you. But it does, any request is reviewed by the compliance team. I'll continue. The tax center is not really responsible gambling, but it is a way where people can download tax forms, that's all. So I wasn't going to go through that. We can have a look if you wish. The responsible gambling information is just an additional resource page. Again, there's more content on here. Again, it's fully customizable from your perspective. It goes into a bit more of an explanation, for example, the warning signs of problem gambling, how to identify and reduce the risk. Again, there's quite a lot of content within here which can be edited based on your needs. Explains how all the limiting works as well. So the cooldowns which are applied when you increase limits, for example, is explained here. That's our core responsible gambling section completed. With through most of the demo, obviously we can throw it open to the floor if you want to see specifically. There's a couple of things I'd like to definitely finish on from my perspective, if you don't mind. And then, yeah, it really opens to the floor if you want to go deeper on. So a couple of items. One is, first of all, promotions. So we have on, you had all these promotional banners which you saw at the top. We also have a promotions page which lists them all. And what we've done on Wimber, we think this is really important from our point of view, is obviously every promotion will have terms and conditions which have been approved by yourselves, attached, which explain in detail. But we always also summarize, trying to be as clear as possible. Normally in a one, two, three style, make it very clear for the patron, how do they opt in and how do they get this promotional offer? Okay, rather high, of course, it's in the terms of conditions, it's there, but also let's try and make it super clear. So in this example, you just need to opt in, bet $100 between these dates, you're going to get entered into a prize draw for the Jets for next season. And specific example, if you waited a thousand, you'd get 10 entries. And when is the prize draw? So we're trying to do it on every promotion we create from a marketing point of view, is always trying to make as clear as possible to the patron, but also we have the full terms below in all instances. So that's our active promotions section and there's a range of promotions currently available. Last, but not least would be win rewards, which Jennifer alluded to earlier. So the win reward scheme is fully integrated into WinVet. This is my test account, but it has a red card attached. So the key here is that it's two-way integrated. It's a single reward account, whether you're on property in the encore in Boston or in the Vegas properties, or you're playing online, all of your wagering, all of your spending gameplay will earn you free credits, comp dollars, tier points, and it will all add to one single account. So then you can earn your balance on both in property and online, and then you can redeem those for rewards as well. So on WinVet, you can redeem for free bets. Whereas on property, you can redeem it for free play within the machines. You can also earn comp dollars, which you can redeem for upgrading your room or going for dinner or whatever you wish from the property side. So a single account. So if you already have a card, there is multiple tiers, there's red, there's platinum, there's black.  So you then have the same account online. If you don't have a retail, a card on retail, you can enroll through WinVet, when you go to property, you can use the same card. So again, your points have been accumulated on both sides, mobile and on property. Madam Chair. Yes, I will. And I think this probably may be a pin for executive session as well. If we can talk about it now, it'd be great. But in regards to the Win Rewards and in terms of giving people free bets and things of that sort, how does that mesh with responsible payment? So as far as the free bets that are offered, those are generally promotional offerings that we provide. If there's any indication of responsible gaming problems, we will not offer any free play to a patron. If there's any indications, language activities that have been revealed by the patrons play, we will, and legal and compliance will often give direction that free play cannot be offered. Okay. If you can, can you give me an example of a red flag that might go up? It could be a red flag such as asking for free play after indicating that they were stretched in for paying bills or something along those lines, asking for free play, but after making a comment that alerts to any issue with problem gambling. And I think I heard you say you have the technology to be able to identify that and then not forward anything to that individual. Is that what I heard? Pardon me, but can you repeat that? Yes, I think I heard you say that once you've identified an issue with a patron, that you have the technology not to offer any free plays and things of that sort. Yes, we advise our team members, our, whether it's host or customer supports to put a hold on any free play that's offered. Oh, very good. Thank you, Jennifer. And we certainly would not offer free play to anyone that's excluded or subject to any of the limits or the cooling off periods. Of course, yep. Thank you. Thank you, Madam Chair. Thank you. Other questions, if this is the right time for other questions? From my point of view, Jennifer, the room, that's the end of the demo. If there's something, apart from a question, if you want to see something specific, you're welcome to ask me as well and or questions. I have perhaps a platform question, two questions, that the application prompted me to think about. One, am I right that for geolocation, just like KYC, if I'm not in the commonwealth, I'll just get an alert that says, you're not where you need to be. Correct, it will not allow you to place a wager and will indicate that you're outside of the boundaries. And am I right though that a patron, a new patron could establish an account outside of the commonwealth? Did I read that? Yes, it is common to be able to even set up an account and place a deposit, but no wagering activity can take place. Limited to wagering activity. And then the other question I had from a technology point of view, and then probably a follow-up later in our discussion would be if a patron alerts your platform that they're in distress, what does that technically work? There's a communication that they can, is there some kind of a page on that that will alert a communication to you folks and then you take steps? I wondered if there is a page on the platform itself, Adam, that we didn't see. So there are multiple pages within the app or on the desktop that provide resources to seek assistance for problem gambling. And if we do receive any communication, whether it's through internal chat or through email or communications with our customer support, any distress that displayed by a patron is escalated immediately and handled by legal and compliance or even referred to any proper authorities. So on the app that it would, it's not necessarily artificial intelligence that I bought, but an actual individual. I suspect that maybe there's a combination on that. A combination of a representative from WinBet or perhaps some kind of a robotic answer. But is there for somebody in distress would they reach somebody, a person? Our live chat is with an actual customer support individual. So it is not a response to AI or a response by AI. Very helpful, thank you and it's nice to see you. Thank you. Other questions, commissioners? Adam, this is our first chance to actually see an app. So you've been very helpful on some of these ordinary questions for someone who has been able to explore it because of the position that we have. So thank you. Commissioners, other questions? Okay. So without seeing any other questions, I just wanna emphasize that other than a change in creative, the user experience will be relatively the same in Massachusetts. And so this does conclude our affirmative presentation. We really appreciate your consideration of our license applications and we're here to answer any questions you might have. Jennifer and Adam, I don't know if Adam will be staying on but I assume your team, Jennifer, everyone must be staying on throughout the course of our evaluation. Correct. Ian Williams, the president and Spiro-Costopolis, the COO will be staying on and Adam is welcome too as well. Great, thank you, President Williams. Can you raise your hand there? Thank you so much. No, I know. Thanks. Okay. Then as I had mentioned, I think it's probably a good time for us to take a brief break. It's 11.25, if we could return, perhaps for 11.35 commissioners, does that make sense? Okay. And then we will go to the presentations and analysis by our members of our inside team. So thank you very much. Appreciate it. Thank you. Thank you. Thank you. Okay, Dave. Thank you. Also. Okay. So this is a reconvening of public meeting number 411. I want to make sure all my fellow commissioners are here and because we're holding this meeting virtually, we'll just do a quick roll call. Again, good morning, Commissioner O'Brien. Good morning, I am here. Good morning, Commissioner Hill. Good morning, I am here. Good morning, Commissioner Skinner. Good morning, I'm here. And good morning, Commissioner Maynard. Good morning, I'm here. Okay, so we'll get started. Now we're turning, thank you again, first to Winbeth for the presentation. And now we're turning to presentations and analyses from our GLI and of course, Katrina DeGroote-Bolmes, who is our CIO, as well as the report from Heather Hall, our IEP Chief Enforcement Council. And then finally, RSF, who is helping us with our financial and economic impact analysis. I'll introduce GLI. GLI is 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 feel confident that they are providing a safe, responsible method of revenue generation for their stakeholders and preservation of integrity. We have Kevin Mulally, who is the Senior Vice President of Government Relations and General Counsel for GLI. Has 40 years of diversified leadership in moral regulatory policy, outcome measurement, economic analysis and organizational administration. As GLI's primary liaison to elected and appointing officials, Kevin regularly interacts with regulatory agencies, key organizations devoted to developing gaming policy and senior level executives of gaming equipment manufacturing companies, casino operators, slide of boundaries, eye gaming operators, parametral wagering facilities, sports betting operators, and all related vendors. And we have Joe, one of the Director of Client Solutions, as Kevin will know, our engineer, over 16 years of experience in the gaming industry with extensive experience in developing fantasy sports online gaming platforms and over 16 years of product management and operations management experience, recognized for demonstrating a natural aptitude for overseeing all stages of the product development life cycle. Thank you, Kevin and Joe, good to see you this morning. Thank you, Madam Chair and good morning, commissioners. Good to be with you again. I'll turn it over to Joe in a minute, but as requested, I'll provide a high level overview of the risk control framework that we have recommended in most of which you have adopted or will be adopting and give you assurance that we are familiar with the technical solution that Wynn has proposed and just did a very good job of demonstrating. It has been approved in other jurisdictions that have very similar regulatory requirements that you have adopted here, most notably GLI 33. It will be subject to additional testing for the Massachusetts deployment. So we will test the most recent version of the global solution that they deploy along with the local integration. That will be laboratory testing and that will be augmented by field testing where we'll look at the local servers, we'll examine the geolocation solution, the KYC solution, the security controls, the responsible gaming controls and all the other features that are specific to Massachusetts. And then we will also, as I've explained, technology is only one piece of sports wagering. There's also operational risk control that is ongoing. So it will involve a review of their internal control submission and an evaluation of the process they have for ensuring compliance with those internal controls. And so if there are no questions for me, I'll turn it over to Joe Budovit so you can get it directly from an engineer in our lawyer. I can give you assurance that from a regulatory risk control perspective, we feel like all the boxes either have been checked in other jurisdictions and will be checked before launch. Thanks for having us, Madam Chair. I'd also like to note that Matthew Toler, Senior Compliance Engineer from GLI is also gonna be on the call today for technical support. Matt has over 20 years experience in the deployment testing of applications for the entire gaming sector. Thanks for having us. And Madam Chair and members of the commission, my name is Joe Spone, Director of Clive Solutions, GLI. I'll give an overview of the submittal certification verification process regarding mobile applications and other digital platforms approved by the commission. Before the test lab can take submittals, the Mass Gaming Commission will have to approve 205CMR 138, 238, 247, and 248. After those approvals, the operators can prepare to submit their code bases for the entire sports wagering systems they intend to deploy. That preparation will include, if it's a platform we are familiar with and what Kevin alluded to just earlier, a modification list from the last submission to one or more US jurisdictions will be requested and reviewed to set the project plan for Massachusetts, taking into account any changes to the platform and all specific Massachusetts rules and regulations. If the product is new to the lab, an architecture review, which is a complete, comprehensive, technically accurate description and explanation of the sports wagering systems, this includes a description of all hardware devices and virtual servers, a description of all server and client software modules, including the software versions, the layout of all network communications between the various software and hardware modules, an explanation of all third party integrated systems. If the product is new to the lab, post the technical documentation review, the critical files regarding compliance will be identified and documented. A full project plan is put in place, taking into account the unique architecture and design of the platform and the specific Massachusetts rules and regulations. The lab will run a supervised compilation of those source files, the signature of those files and the compilation steps and the signatures of all the compiled code. Once complete, the source code can be submitted for testing in a lockdown environment. The lab will review the player account management system or as referred to as PAM for registration, age identification and verification, account controls, payments, reporting, responsible gaming controls, required disclosures and geolocation. The geolocation test commenced in two parts, a field test to verify borders through sampling around the entire border while the completion of edge case and technical tests. The field tests will also cover any restricted areas as defined by the mass gaming commission. The second part of the geolocation test is a submersive workaround detection test that'll commence in the lab, which will include, but it's not limited to, VPN proxy usage, GPF spoofing, code manipulation and man in the middle tax. The lab will verify the sportsbook in total if not tested previously for retail deployment or other mobile deployment or review the integration of the sportsbook into the PAM for events, market, point spread, point spreads, bet acceptance and corresponding time stamps and logging, verification of the enforcement of betting limits in all edge cases. We'll also verify pre-event and live data feeds, post-event bet settling, corresponding time stamps and all logging and reporting of those elements. The lab will also review all change management process and procedures. Then the post, so post-testing all those checkpoints, the certification can be issued. The lab will verify that the change is made for Massachusetts specific deployments and this will include source code differential and change testing to the last reviewed version. The lab will evaluate the product to all the Massachusetts specific requirements and at that point, the lab can issue certifications to which the Massachusetts gaming commission can approve for operations. A field verification will be conducted in conjunction with the MVC. The procedure will be finalized in the upcoming weeks. During that time, verification of the production server and verify all critical file signatures will commence a review of internal controls for procedures to operate the sportsbook, check technology for configurations such as proper setup of roles in user rights management and potentially interview key personnel to ensure they know and will follow procedures from the approved internal controls. And that is the high level broad summary of how a mobile and or digital product would be approved for the mass gaming sportsbook operations. Thank you, John. Any, are we going to hold our questions, commissioners? I see a nodding on the head. Okay, we'll continue in the same process that we've done and hold questions in terms of the next presentation. Oh, I just want to acknowledge our Chief Information Officer Katrina Gomes. Katrina, did you have anything that you wish to add at this time? I do not, Madam Chair, she elected a fantastic job of giving a high level overview of the technical components required. Excellent, thank you so much. And we will turn to our next presentation and report. And that is Heather Hall, our Chief Enforcement Council. But still good morning, Chancellor Hall. It is good morning. Thank you, Chair and good morning, Chair and commissioners. With respect to the IEV side of the presentation on the preliminary suitability, the IEV submitted a report regarding its review for preliminary suitability of WSI US LLC doing business as WinVet. As you know, this applicant is seeking a category three sports wagering license to be tethered to Encore Boston Harbor's category one license. The IEV performed this review for preliminary suitability in accordance with the standards and criteria set forth in 205CMR 215.01 subsection two. The IEV did not perform a full suitability investigation at this time. As a precursor to this review, the licensing division in conjunction with the IEV performed a scoping review of the applicant under section 5B of chapter 23M and identified four entities and two individuals that it designated as qualifiers in connection with WinVet's application. Those qualifiers are listed on page one and two of the IEV's report. The licensing division has also performed a review of the submission for deficiencies and there are no substantial deficiencies. And I would just note that there have been ongoing communications between the licensing division over some pieces and the applicant and the applicant has been responsive and there is nothing significant that is outstanding with respect to deficiencies on the application. Our team was comprised of contract investigators including former members of the state police gaming enforcement unit and contract investigators from the firm of RSM all with the collaboration and oversight of the IEV. The review for preliminary suitability included a summary of WinVet's licensing status and other jurisdictions as disclosed in its application. Its compliance history and other jurisdictions also as disclosed in the application and pending litigation valued over $100,000 as disclosed in the application. It also included a summary of an open source review of the applicant and individual qualifiers but not necessarily the entity qualifiers. And the results of those sections appear in the IEV's report. And with respect to that part of the review we do have contract investigator attorney, my thanks here available for questions if the commission has any as well as I will be here as well. And with respect to the financial suitability we had a team from RSM prepare a report that appears as exhibit one to the report. RSM worked closely with financial investigations division chief Monica Chang and other members of our financial investigations team. RSM review disclosed financial information of the applicant and in this case reviewed supplemental SEC filings of the publicly traded ultimate parent company when resorts limited. And they presented financial ratios in that exhibit as well as also reviewing forecasting submissions submitted by the applicant in its general application and the summary of self-reported history of judgments. And we also have members of the RSM team here available for any questions if the commission has. And with that, that would just conclude my prepared remarks. And as I indicated, we are certainly here to answer questions the commission may have. Any questions at this time or shall we hold them? Just a point of clarification and process. We got this last night. So are we gonna be discussing this in more detail at the end? Or do you want questions now? I would like to talk about some of the things in the four corners of the IEV's thing in terms of particularly sort of the some of the conduct or consequences in some of the other states just to get a better understanding. So what's the timing on that? Council, how are you available this afternoon? If we are, I'm assuming it's gonna be this afternoon because it's the same. Can we get to that section of the application on suitability? Yes, absolutely. Does that make sense? Sure, Brian. Are you comfortable? Sure. Yep. Council, thank you. Thanks. Any other questions on process or otherwise? All right, then thank you, Councilor Hall and I am hearing that. Attorney Banks is available as well as the folks from RSM if we have questions in addition to any for you at IEV. Okay. So then we're going to turn to RSM who's also been helping us in our review of the evaluations. RSM is the, RSM US LLP is one of the leading providers of audit tax and consulting services in the United States. RSM, as I mentioned, has been working with the Massachusetts Gaming Commission to provide insights and analysis to help the commission as we evaluate certain sections of the application. Like introduce some of the individuals who will be presenting during this meeting and the team changes. So perhaps it makes most sense for me to allow you to self-introduce but I should say that our request has been for RSM to really limited to a few sections. And again, I can be corrected but it's my understanding that RSM has been asked and will provide insights based on the experience and research in the following sections. B2D, which is the sports wagering experience. RSM has been asked to focus on applicants' estimated market share within each jurisdiction. C2, projected revenue. RSM has been asked to provide insights into all aspects of the applicants' projected revenue. GS, financial stability and integrity. RSM has been asked to provide insights into all aspects of the applicants' financial stability and integrity and to the extent any of that addresses issues that the applicant feels is confidential. There is the option of course of an executive session pending our counselor's advice and review. So again, still good morning. Greg, I'll have you, you're launched and it's good to see. Thanks, yeah, good to see you as well. I'm actually gonna have Teresa kick off because I have to leave in short order, but Teresa Merlino's on the call as well. And so is the team. Nice to be here with you. Thank you very much. Good morning, Teresa. Good morning. Oh, good. Yeah, good morning. It's nice to see everybody here today. My name is Teresa Merlino and I'm a principal on our gaming and hospitality practice and have been involved in gaming since the late 1990s. Yeah, to the commission and we understand the importance of the licensing process and the importance of these meetings. We did a diverse team of professionals to present on the topics as requested by the commission and as they kick off their portion of the presentation they will introduce themselves in their experience. As commissioner Judd Stein has indicated, RSM team has been asked to join the meeting to make a presentation related to very certain aspects of the applications. Please note RSM is not presenting on all aspects of the application specifically we've been asked to provide insights based on our experience and on our research into the following application sections. Section B with a focus on the estimated wagering activity. Section C with a focus on the projected revenue and section G with a focus on the financial stability, liquidity and the scenario analysis that the applicants were asked to perform. Please note that the presentation is based upon documentation received as of November 21st, 2022 and the discussion is prepared by the team is on our preliminary research to date and is subject to change if new information becomes available. Questions posed to our team may require further research and if we are unable to respond to a question before the end of this meeting we're happy to circulate a response to the commission as soon as practical. Also note some of the much of the financial information is noted as confidential by the applicant. So if appropriate we'd be happy to move into an executive session as directed by the commission. So starting here, Jeff would you like to take over at this point or Connor or should I continue to present? Yeah, I can take over here. Thank you. Thank you. Hi everyone, Jeff. I lead our strategic finance and FNA group here at RSM and so we helped with looking at the market share revenue projections and some of the other financial information provided by the applicants. As instructed by the MGC we conduct a plumber review of each category three applicants market share submission materials in tandem with other investigators involved in this process regarding the category three temporary license process. Much of the information shared is likely confidential including market share projections but we're happy to discuss those items in detail in the executive session, as Teresa said. Jeff, I'm going to pause here. Councillor Grossman, I'm wondering if we are going to be able to have the fulsome discussion that we expect on this way. I'm not sure how the applicant was just to proceed but I also know that the nature of the material might not be as confidential perhaps as maybe they intended because we do want to have this information on the commission to digest. Yeah, I mean, Bernie, I don't know if you have any questions so. Yeah, I mean, Bernie, thank you Madam Chair. Obviously, while we can't speak to some of the specific numbers in our application because of confidentiality and being part of a public company we do understand the financials of Wimbit are consolidated with Wynn Resorts and those are available through publicly viewed SEC reports. And so I'd be happy to provide broad overview but we would like because of the confidential nature of some of our financial information provided would be happy to fully address these in an executive session. And for note from the RSM perspective we have crafted a discussion that doesn't reference specific numbers but provides ranges and context with the intent that at least the initial discussion could be held in a public forum. And then possibly if there are specific questions related to some of our analysis that maybe that are very clearly appropriate in executive session, we may be able to define those similar to how we defined certain carve out discussions last week, but we are prepared to at least provide an overview to the commission without explicit reference to the items, confidentially noted. Councilor Grossman. Yeah, thank you Madam Chair. I think as Ms. Merlino just outlined if we could begin with a high level overview without getting into specific numbers and that makes a lot of sense. We can perhaps invite Attorney Roberts to jump in if we are getting too close to the line and then we can evaluate the actual information to ensure that it falls into the parameters of the exemption. But if everyone is comfortable with that approach I think that makes good sense. Commissioners, we want to proceed as we've had, okay, thank you. Please, I think Teresa and the RSM team has been quite sensitive around these issues. So I think we'll turn to Jeff then to proceed, but okay. So in RSM's preliminary market study the jurisdictional rules and what other nearby markets are doing may impact any of these applicants market size in sports book composition in a given state. For example, when Massachusetts goes alive it is probable that neighboring states will see a decrease in sports wagering activity as patrons will stay home and place their bets rather than crossing state lines to do so. If all applicants currently pen review are ultimately granted a license Massachusetts would end up with an above average number of sports books operating in the market. And that is broadly associated with a larger ultimate market size and a lower hold percentage that benefits the consumer. And just for reference hold percentage equals percentage of total wagers or handle kept by the sports book. This of course is still developing. And then just for reference in jurisdictions where sports betting is legal there are between one and 25 sports books operating in individual states. It is anticipated that we are already seeing some consolidation that will occur in the industry both through merger activity and operators exiting the business unable to sustain losses. According to market analysts economies of scale are a major factor. And given the evolving nature of the online sports wagering and the varying number of platforms in different jurisdictions it is difficult to predict the ultimate composition of the marketplace even after conducting extensive market research. But what we can say it is being viewed as a lucrative long-term growth market by operators and industry analysts. Speaking broadly the online sports wagering experience of the Massachusetts app can pool has varied levels of industry experience. They are represented by both domestically and international players. Some have decades of experience others are still in the process of building their platform. The commission has received IEB's report addressing the suitability review led by the IEB that was spoken to. That review is that report is a review of the applicant self-disclosed financial submission looking at a select few sections of the application those being section C2 and G3 broadly. Now moving on to WinBet the applicant has provided a view into the historical sports betting operations of WinBet as well as an intermediate holding company. WinResorts the ultimate parent company has previously been issued a determination of suitability and our view is limited to select public filings. Broadly speaking past financial projections the applicant are generally in line with what we have found in our market experience. In terms of projections the applicant makes a grounded estimate for future operations that is in line but we would expect from a successful launch. However, without possessing a crystal ball we must caution successful launch for this or any applicant is not guaranteed. And then I would like to move to the revenue projection. So we reviewed the applicant's revenue projection information compared to market analysts with Deutsche Bank and Truist Securities that were both issued in October of 22. Market share estimates for the OSB market were not shared by the applicant. However, based on comparisons to noted research and WinBet's revenue projections we noticed that their performance is higher than it was in other markets based on published state data. However, we do understand that WinBet is associated with Encore Boston Harbor which has certificate market share in the state of Massachusetts. The revenue growth. And just a comment on that the commission may wanna better understand some of the differences between the applicant submission for their market share compared to what they're performing in other states because we did notice a significantly lower percentage of market share in other states compared to what they presented in their application. Yeah, looking at gross gaming revenue growth it is in the range of different analyst projections. However, we're gonna acknowledge there's difficult to direct growth as the industry is dynamic and it's unclear when the saturation point may occur especially as more markets come online. As the commission is aware revenue is closely tied to hold percentage. And it's important to note that WinBet's revenue projections are based upon a conservative hold percentage from what we have seen in other markets. So for instance, New Jersey has a 6.7% hold average and then states such as New York, Delaware and Louisiana are greater than 10%. And then Pennsylvania, Michigan and Arizona are roughly around 8% for hold. I'll pause there for market share and revenue to see if there's any questions. I guess my question goes back to I'm trying to gauge how I'm not really seeing the redacted version of some of this. So I'm trying to gauge how much of this we can ask to go in and potentially discuss an executive session and how much we can't. So I'd love to hear more detail in terms of what was just flagged for us in terms of a delta between what they've seen historically and maybe what's in the app. Todd, I don't know if that's something that we can discuss in executive session. Well, that's certainly on its face sounds like competitively sensitive information that would potentially place this perspective licensee at a competitive disadvantage. And if the commission as a whole is comfortable with that conclusion, then it can be discussed in executive session. Okay, I'm going a little bit out of order. If I could just go back to some of the individual qualifiers entity qualifiers for Heather. Are we going to have a redacted version too in terms of what is appropriate to sort of query in public and what would potentially be an executive session? And if we have it, I have, I just haven't seen it. I'm sorry, if you can direct me to it, that'd be great. I actually would refer to General Counsel Grossman on that. And I will say Commissioner O'Brien that when we submitted the report, we did ask the applicant to identify specific areas in the report that they would request redaction on and to work with the legal unit on that. So I'm going to stay in the IEB lane and defer to General Counsel Grossman on that piece. Yeah, I think that it certainly again depends on which specific information we'd like to discuss. And if we can identify that again, if it fits into the parameters, then we can certainly move into executive session. Under Ms. How to Raise It in this forum without, where I shouldn't be maybe raising it in this forum. Commissioner O'Brien's point is that we did receive the IEB report and I think we understood that, I understood late last night that the redacted version was coming. But I don't believe we've received it yet, Commissioner O'Brien and our file. Okay, so they didn't miss it. I don't think I've missed it, but clarification from counsel. I haven't seen a redacted version myself, which I don't know if that leads to a conclusion that everything is fairer game, but- I don't imagine that it does based on something that I want to talk about. I cannot imagine that it does. Madam Chair and the commissioners, Jennifer Roberts, again, I do want to clarify that we are still in the process of the redaction. So I apologize for the delay on that. But be happy to address any issues in the report in an executive session that are sensitive and confidential personal information. So- Sorry, Councilman, maybe I can make a suggestion for Commissioner O'Brien. It's that you have some questions for RSM and questions for IEB. We've got questionators question. Would it make sense for us to continue through RSM's report and then if it's appropriate, look to see if we'd vote to go into executive session, tend to these items and then go through our section by section analysis. Does that make sense? Because it might give us context. It may. It may mean going back, having to go back- Yeah, absolutely. We would convene for another one, but it might make sense rather than putting it off to the end of the day or the end of this evaluation. In terms of RSM's involvement, yeah. And then that would wrap up for them, yeah. It could wrap up for them, although I think they know that we might have questions that could come up as we go through the application section by section two. But it might make sense rather than as we've done earlier, wait to the end of the process. Yeah, I mean, part of this is, you know, and I'm not faulting staff at all, but I didn't think we were going to be doing the deep dive in suitability today, given the fact that we didn't get the report until yesterday. So I'm just trying to deal with how to make sure that this is covered, but covered in a way that protects the relevant privacy interests and exemptions. What I might suggest, Commissioner Brown and all, is that all of this sounds like it fits within the parameters of the exemption. So we can move in to executive session and monitor the discussion to ensure that it stays within those boundaries. If we start to realize that we're moving into information that should be discussed publicly, we can stop that part of the conversation and reserve that for the public. And I think that's a fair approach, as long as we're very careful and meticulous about the way we go about it, I would be comfortable with that approach. And I may actually talk to you offline in terms of one area that, again, I can't raise it publicly. And the question is, can we, or can we not go into executive session on it? But we do have to vote on it. So you've got to settle a little bit of quandary. Or what, you know, in terms of- Well, we don't have to vote today necessarily. So if there's a question still out there, you know, it may be that we can, if we don't have an answer today, we may have to wrap it up tomorrow, depending on how we are. I suspect there's a way for you to generally ask to see if it gets into the nature of, I mean, I'm hoping Commissioner O'Brien is a way to generally ask the question so that we know if in fact we could move into executive session. But it sounds like right now there's been already some things, points that Councillor Grossman thinks that we could appropriately move into executive session. And I do think commissioners, I think I want to emphasize Todd's point. We are very, very careful about this. So Commissioner O'Brien, you know, I'm with you, you know, in terms of you're being very cautious because we do have to have an open transparent process. On the other hand, this is a tool that allows us to have that full sum discussion. And that's why it's parked up in the agenda. Can I again, just suggest though that we allow RSM to continue and again put a pin in these two requests and then consider at the conclusion of RSM's presentation returning to this discussion about whether or not it is appropriate for us to go in on separate issues. Does that sound okay, Councillor O'Brien? Yep, that's fine. Okay, thanks. All right, back to Jeff and Teresa. Perfect. And then, you know, the applicant has provided information regarding its marketing and go to market plan. So this was spoken to in section 4.1 of the submitted report and these plans will impact ultimate market capture and success within Massachusetts. As has been publicly reported, WinBett has reduced its marketing spend during 2022 in other markets. And the commission may wish to discuss WinBett's marketing Massachusetts plan with the applicant. And then moving to, you know, liquidity. As of the third quarter of 2022, WinResorts, the publicly traded parent of the applicant has $2.8 billion, comprising of $2 billion in cash and $800 million in an undrawed revolver. So credit line. $546 million is payable in the next 12 months on its long-term debt, providing a capital cushion in which to fund operations. Win generated approximately negative $160 million in cash operations for the last 12 month period ended September 30th. Win should have enough liquidity to fund its Massachusetts operation based on the filings. It is ultimately up to the applicant's parent on how to allocate its financial resources if faced with future losses. There is no guarantee it will continue sports-waging operations in Massachusetts, but it has the resources to do so if it desires. Our sum will remain on the line to answer any questions the commission may have about this presentation or our written submission. If there are further specific questions on the contents of our report, we are happy to discuss those in an executive session. Thank you, Jeff. So Commissioner O'Brien, perhaps it makes sense for us to take a short break and then you could speak with Council Grossman about your question rather than putting, maybe having it another day. So you could speak with him about that and then you'll bring it back to us in the proper fashion so that we can be informed for any boat that we decide to take. Does that make sense? Yep. Commissioner, is there any questions you have for RSM at this point? Thank you. Okay, then it is 12, 17. So, Commissioner O'Brien, it's 12, 25. And after, should we do 12? Oh yeah, I would think so. Todd, if that works for you. Yeah. Okay, well, we can be in at 12, 25. Thank you. Thank you. I'll set. Thanks so much. Thanks, everyone. We're reconvening meeting 4-11 of Massachusetts Game Commission because we're doing this on a virtual platform. Go ahead and take a roll call. Commissioner O'Brien. I'm here. Commissioner Hill. I'm here. Commissioner Skinner. I'm here. Commissioner Maynard. I'm here. So we're all set to proceed. So I want to thank both GLRI, IAB and RSM for their presentations and insights. Some questions have arisen that we believe might be appropriate for an executive session. And I'm going to turn to Councillor Grossman for some guidance here. So, Madam Chair, we may have a bit of him needing to clone himself because after the conversation, I think he followed up trying to resolve the issue. So I don't know if he may have muted and not aware that you're looking to have him chime in right now. Well, I don't think we can proceed without Councillor Grossman. So Executive Director Wells, can we, but should we pause another? So let me call and I'll get, I'll get. Maybe if we pull him back here to deal with sort of the one known area from RSM and executive session, we can get moving on that. And also we have Commissioner Maynard's question. So we'll need to. That's the area I was talking about that area that we clearly know falls within the executive session exemption. Thanks, I understand. So why don't we come? That's very strange. He's not picking up. Just give me a minute. Let me text him as well. We're going to just pause for five minutes. So that will give everybody a chance to do stuff and then we'll convene right back. Okay. That's good. Thank you. Perfect. Thanks, Dave. Kathy, Todd's just checking in on one thing and he'll be right back on. Okay. So we'll wait then. Thank you. Yep. Wait. Why don't you just let me. I could toss the screen back up. We're still waiting. Yes. Why don't we do that? Thanks. Okay. Sounds good. Thank you. Thanks, Dave. Karen, are we all set? Kathy, I just tried to call Todd. He didn't pick up. I had a text from him at 1235 that he needed five more minutes. So I'm thinking he's all set, but let me just text him again. I just texted him. Can we reconvene? So he must be on the phone with someone. So if I could give you a little clarity. It's 10 of one. Dave, if you could pull down the slide, please. And let's remember we are still. Oh, there's John. We're all set. We're all set. There he goes. We're still streaming, I believe, correct? Yes, we are. Thank you. But I will now do a roll call. Let's see if Commissioner Hill joins us. Let's turn to my camera. There he is. Okay. Commissioner Bryan. I am here. Commissioner Hill. I am here. Commissioner Skinner. I'm here. Commissioner Maynard. I'm here. And I just took a roll call because this is the return of the Massachusetts Gaming Commission meeting number 411. And we took a short break in because we're holding this on a virtual platform, I needed to do that roll call. So here we go. So I had started, I had returned earlier with an idea that Councilor Grossman, you would give us some advice as to the request that my fellow commissioners have asked to address some issues that we understand should be addressed more appropriately in an executive session. You can advise us on that. Absolutely. So there were three potential issues to be addressed. The first pertains to the market share projections and the revenue projections and some of the historic revenue figures. That matter appears to neatly fall within the confines of the exemption set out in chapter 23N. And I'm comfortable moving into executive session to discuss that subject matter that was just discussed recently by the commission. So that one I think is okay. There's another issue relative to a case in the state of New Jersey. And there were a few details that were of interest. And I thank you to Ms. Roberts who just sent over the complaint. I haven't had a chance to open it or look at it yet. But those documents may alone resolve the issue. So I'd like to share them with the commissioners so you can see them. Those are public documents. That's right, Ms. Roberts. So there's no harm there. So you can all look at those and see if that satisfies the question that came about. So I'll send those over shortly. And we'll be sending them in our emails. Is that what you're saying? Or will it be a matter of public discussion? I think in the first instance, I feel forward to the email, I had the question. And then it should satisfy the question. It may prompt other questions for my fellow commissioners, I don't know. Or a question that we all had anyway. So I'll get commisioned by it. The last one. You said can I ask the documents that are coming to us, documents of public record in New Jersey? I believe so. I mean, Ms. Roberts can speak to it. I haven't even had a chance to look at them, but I think they're just court filing. So yeah, so there are public records. And I'll get those over to you momentarily. There's a third issue that I'm still kind of wrestling with and it involves Mr. Cohen in a matter he was involved with in Turkey. And so we're just trying to determine whether there are privacy interests that need to be protected. And if so, whether we can go into executive session to talk about those or whether those issues were discussed in a public forum there. Not being familiar with the laws of Turkey. I don't at the moment know the answer to that question. And I just want to be very careful that we get that right before we talk about those issues publicly. Mr. Cohen is available to discuss the matter whether it's in public or an executive session. So that part is all ready to go. It's just a question of whether it would be done in public or private. And I think we'll be able to hopefully answer that question shortly. I just need another couple of minutes. Did Ms. Roberts have any documentation that would address that issue that's been shared in the past or not in a public record? I don't have confirmation that it is public record. There's just a, you know, a guess. Unfortunately, I'm not versed in Turkish law either. But we did provide with his application the documentation, but we marked that as confidential not knowing whether it was public record. So why don't we go into executive session on it? Is there a reason why we just don't go into executive session on it? Does it not fit? That's the question. That is the question. If it were in the United States, it would not be something that you go into executive session for because criminal matters are resolved in public. And I just don't know whether that's the case in Turkey So, I mean, certainly if we can't answer that question, we could go into executive session. You could talk about it. And if we happen to be wrong about it, the remedy would be that the information we talked about in private would become public. So that's the exposure, if you will. And it's not really for me to say whether that's a risk the commission and Mr. Cohen are willing to take. So that's why I just wanted to try to get a better answer on that question. We can, for certain, go into executive session to talk about the first issue. And we could do that now while we try to resolve these other issues. Right. And then Mr. Maynard also, Commissioner Maynard, I'm so sorry. Commissioner Maynard had a question as well that seemed to fit nicely into the executive session. I would agree with that. That's the, if I understand that issue correctly, essentially the percentage of individuals who don't get through their KYC process request. Okay. So it's that. And then the question of the potential disconnect between RSM's review of the market share and the application, that would be, that was the other area that I think also does neatly fit. Yes, I believe those are the two issues. Okay. So, commissioners, we have in order for us to go into executive session, I do need to read the language into the record. I want to make sure we are very clear on the precise issues that are before us. So even though we just kind of said them, Todd, if you could just say them precisely, that would be helpful. And then, you know, this is only anticipated commissioners. You have to be comfortable with this decision. We move and we move with an affirmative vote. Okay. And if we don't have that affirmative vote, we will just continue on in the public forum. All right, Todd. Okay. So just to be clear for the record, both of these issues fall under section six, I of chapter 23 and by way of chapter 38, section 21 is a seven, I believe. I don't have it right in front of me. And in that, they all, they both relate to competitively sensitive or proprietary information that was provided in the course of an application for an operator license, the disclosure of which would place the applicant at a competitive disadvantage. As such, they are appropriate topics for discussion in executive session. Okay. So I understand, Todd, is that you thought you said something about a criminal issue, is that? That one is not on the list at the moment. That's for, that's a separate issue as is the New Jersey matter at the moment. Those are both, if you will, relate to suitability and are certainly appropriate for discussion when the commission begins evaluating that part of the application. But the two issues, again, before the commission are, first, the percentage of individuals who do not or get through the KYC process. And second, any discrepancies in market share projections and revenue projections relative to WinBet in operation, WinBet's operation in Massachusetts, as opposed to other jurisdictions? So the commission anticipates that it may meet in executive session in conjunction with its review of the WSI US LLC doing businesses WinBet application in accordance with GL Chapter 30A, Section 21A, Subsection 7 and GL Chapter 23N, Section 6, Subsection I to consider information submitted by the applicant in the course of its application for an operative license that is a trade secret, competitively sensitive or proprietary in which a disclosed publicly would place the applicant at a competitive disadvantage and or general laws, Chapter 4, Section 7, 26C, the privacy exemption to consider information submitted in the application materials relative to named individual posts, the disclosure of which may constitute a warranted invasion of personal privacy and or GL Chapter 4, Section 7, Subsection 26N, certain records for which a public disclosure is likely to jeopardize public safety or cybersecurity to consider information submitted in the application materials relative to the security or safety of persons or buildings, structures, facilities, utilities, transportation, cybersecurity or other infrastructure located within the commonwealth and the disclosure of which is likely to jeopardize public safety or cybersecurity public session, the committee meeting will reconvene the conclusion of the executive session and I understand that for the two matters before us it relates to the first Section 6I of 23N, is that correct? That's correct, it's not the privacy exemption or the security exemption. Right, I read it online because it's in our agenda and I wasn't sure not to but it is all in with the understanding of these two relate to Section 6I. Do I have a motion? Madam Chair, I move that we go into executive session for the reasons stated by the Chair on the record and more specifically, reason 6I. 23N. Of 23N. Thanks. Second. Good. Any questions or edits? Thank you. Can we show Brian? Aye. Wish. Aye. Mr. Skinner? Aye. Mr. Schreiner? Aye. I vote yes. Thank you so much. So the way that this will work, first off, Crystal, if you're able to hear, we wanna make sure that Matt Bowser of A&K receives an invitation to the executive session, please. We should have a link in our calendar for the virtual room. Once we arrived in that virtual room, we can assess if we need to invite additional guests. Todd and team, I imagine that Crystal has done her best as two guests. So we will see folks in that virtual room and then please stay tuned and look for invite. May we may send you in connection with these executive sessions. This is a discussion, my apology. I will send the link over to the, well, Ms. Roberts, I'll send that over to you. And if you can circulate it to your team, if you don't mind. Great, thank you. Thank you, everyone. We appreciate it. Thank you. Okay, Dave. Okay, we're all set. Thank you. All right. Waiting just for a few. Okay, we're all here. So we are reconvening public meeting number four. Love and thank you. We are meeting virtually, so I need to take a roll call. Good afternoon, Commissioner O'Brien. Good afternoon, and I'm here. And so is your cat. Good afternoon, Commissioner Hill. Good afternoon, I'm here. Good afternoon, Commissioner Skinner. Good afternoon. I'm here. Commissioner Meiner, good afternoon. Good afternoon, Madam Chair. I am here. Great, thank you. All right. We just concluded, about a half an hour ago, our executive session addressing two questions that arose that were more appropriate for that forum. And now I think we can turn to item five on our agenda, which is actually the section by section. Analysis and just reminder, commissioners will call on you for questions as we go through each section. And then at the conclusion, we'll take our temperature and find out how we feel about the quality of the applicant's response to each section and whether it met our expectations generally or not. So, and I welcome any reminders of that process as we go through. And should anyone need a break in between, we'll pause. I wanna make sure everybody has a chance to take their notes and review their notes from their review and make sure they get all their questions answered. All right, so we'll start with, I think that they met the section A, they submitted their executed version of the application. So we'll turn right to section B. Missures, do you have questions? Missures, getting? Yes, thank you, Madam Chair. Could you tell us who some of your other retail partners are in other jurisdictions? And I apologize if I missed that in the application. Yes, of course. We have retail partners or market access partners that have retail operations. We are partnered with Caesars Entertainment in New Jersey and Full House Resorts in Colorado. The Salt St. Marie tribe within Michigan and we've partnered with NASCAR in Virginia and then the San Carlos Apache tribe in the state of Arizona. And then Louisiana is also a Caesars Entertainment property. And I do see some of those in your answer to B1B. And I do recall seeing that. Who's your partner in Tennessee? Who's your partner in Tennessee? That was notably absent from this response. And I'm just curious. Sure. So also New York. But I thought you said you're not in the New York market. But we are in the New York market. It was through a bid process. So we are independent of a retail tethering. We successfully acquired the license through the bid process. And Tennessee is an open market and they don't have any retail sports books. Okay, thank you. Other questions on section B? I have one that, oh, did somebody, or somebody? I did, but you go ahead, Chair. Oh, go ahead, Commissioner Skinner. Oh, there's reference throughout the material to a new product launch at the beginning of 2023 significant product feature rollout. Did you cover that in your presentation? Yes, we discussed our product partners within the presentation that we will be moving to a single app, which is a product feature that we're excited about. And then we demonstrated some of the new creative that we have within our product. Okay, so that was the new product that you displayed today? Not the demo, but the on the slides. Okay, thank you. Commissioner O'Brien, you probably have the same question, but I just wanted to understand a little bit more about the options for deposit. We have, of course, a prohibition on credit card use. And I think Commissioner O'Brien in the past, you've raised a question also about kind of that. A secondary credit card use, if you will, for making your deposit from a credit card, you go over those options that are extensive and how a state like ours would deal with that? Yeah, we comply with the regulations that are set forth in this state. We do have some states that have limitations on credit card use as well as secondary use. So we are able to tailor our payment processing and platform provider. They're able to tailor the payment system for each jurisdiction to make sure that it complies with the requirements in that state. But you would allow secondary, if we didn't have a regulation, you would allow secondary credit card use. That would be, that's something that you provide. We do provide that in some states that where it is permitted, if it were not permitted, obviously we would prevent that from being offered in the state where it is prevented or prohibited. Commissioner O'Brien. Yeah, can I follow up on that? Because I noted that PayPal was one of the options. How is it that, can you point me to a jurisdiction that does prevent the secondary use of the credit card? And if you can generally explain to me how that would work? I believe Tennessee has previously indicated, concerned about the secondary use of a credit card. And we have worked with the Tennessee regulators to make sure that that isn't in place. And so what we would do is there may not be payment providers that we would offer. However, I would say that PayPal specifically does require a bank account. And so in, but in the states that where it may be limited, we would just notify the payment provider to restrict the funding method. I have a question on something else. I can go after commissioner Skinner who's already in line in front of me. I think commissioner O'Brien, you're next, right? Commissioner Skinner, just fine. Thank you. Okay. There's a comment I think in B3, where you say that you prevent the patron from having a negative balance on their account. So can you describe that to me a little bit more? If you're going to wager where the loss would put you into a debit, are you barred from putting the wager in or how does that work? Correct. One, we don't offer credit to patrons from which to wager. And then also if they do not have the amount that they're allowed to wager, then they are not allowed to put themselves at a loss. They're only limited by what is in their account balance. And I did want to just say something that I did like, which was the 24-7 customer service with people in Vegas and Jersey City that are reachable given some of the headlines that people had about their difficulties getting into accounts when certain things got hacked. I did want to say that I liked to see that you guys had that. Yes, we're excited that we're continuing to build our customer support and payments and fraud teams to have 24 hour coverage. That's great. Thank you. Other questions for section B, Commissioner Maynard. So I have a question about the classification of changes and the levels of reporting to the regulator. There was one that was called the emergency situation that basically said, hey, we're gonna make the change right away, right? Can you give me an example of an emergency situation where you would move forward without talking to the MGC and then do it on the back end? That would be a technology change that would go through our product compliance department. And that would be something, for example, let's say that a change, a new classification of prohibited patron designation was issued. We would need to make an emergency change to cover that and make sure that that prohibited patron was no longer able to wager. So I'll try to, maybe a geolocation provider update if we were to, if there was a necessity to enhance our geolocation services, that might be another reason for emergency change. Again, it would be more to either protect the patron or to protect our ability to be in compliance with regulation. So a follow-up question, Councilor Roberts. Any time that you possibly could notify the MGC staff, of course you would wanna notify them first, when practical? Yes, absolutely. Our goal is not to classify any change as emergency. It would only be when necessitated as an emergency. So our product compliance team is in constant communication with our regulators to make sure that any updates to our system go through the approval process. Thank you. Other questions on section B? I think that we could take our, find out if we have a consensus on the quality of this response. Thanks, Commissioner Maynard, you're nodding your head. I believe B was met satisfactorily. Yes, so do I. I do too. Yeah, Commissioner Maynard, I didn't mean to put you on the spot. Yes. And you'd be a B of the same way. It meets, yeah. It meets. Okay, great. Thank you. Yeah, I thought it was very thorough and I appreciated your explanation around the shift in the business model. So thank you very much. We'll turn them to section C, questions for the applicant. Now, if I know correctly, every single entry is marked confidential.  And so I would like to be able to have the commissioners explore this section comfortably. So, Councillor Grosman and Attorney Roberts, perhaps we need some guidance here. From our perspective, there are certain items in here that would speak to operational business intelligence. We labeled it confidential generically, but we also submitted a redacted version, which we are currently reviewing for resubmission. But if there's a topic that we're not comfortable speaking about publicly because of the confidential and private nature of it as it meets your standards, then we will flag that as it's being raised. I think I would just add that certainly all of the information discussed in executive session was appropriate to be discussed in executive session. So to the extent that the commission would like to talk about that information as part of the evaluation, we should consider moving back to executive session. If there are high level conversations that can be had as was done in advance of moving into executive session, then we could do that, or certainly as part of a hybrid. So I think it depends what level of detail the discussion will take. I don't think we're speaking right now about the items that got brought up in the executive session. This is just that all of section C, which we're reviewing is marked confidential, that's all. So I guess we'll proceed then, right? And with our questions and we'll get an alert from either Councilor Grossman or Councilor Roberts. All right, we have questions. I do, Madam Chair, I can get it started. I believe it was in section C where they talk about employment opportunities and there was a reference to field marketing partners, saying if allowed in Massachusetts. So when I listened to it, it almost sounded like local junkets, going out and drumming up business. So we talked a lot about responsible gaming, marketing, things like that. But if you can't talk about this in the setting, let me know, but I'd like to know what that is exactly. So field marketing is a group, whether internally or externally through a licensed vendor that might engage in activities to help register patrons. They might go to certain events and we have a directive to any field marketing activities. If they are permitted in a jurisdiction that it's only targeted to those events where patrons are over the age of 21. But if they do go into certain areas, then their directive is to help with brand recognition and registration questions. But the reason that we qualify that if permitted is because it would be a policy decision of the commission on whether those activities are restricted in any way. And we would follow the guidelines of what is restricted or by regulation. And can you point me to any jurisdictions that prohibit the kind of field marketing partner you're talking about? Off the top of my head, I can't think of any jurisdictions that might prohibit activities. They might just have limitations. I think New York may have some restrictions on the ability to market within the field. But if anything, it would be restrictions through regulation. Okay. Could I have a follow-up on that, Commissioner O'Brien? Please. Of course. A little bit of a twist on what you were asking about because when I saw that, I did know that there's an expectation that could generate perhaps 70 jobs, jobs in connection with marketing outreach and if it's really boots on the ground, that would be perhaps 70 jobs here in Massachusetts associated with the launching of online sports wagering, which is exciting. With the concerns that Commissioner O'Brien's notes, it sounds like there might be opportunity to regulate, to ensure the issues around frequency, intensity of marketing and all of the responsible gaming concerns we might have. I also wondered, this is a little bit delving into the next topic, but when you have those field marketing representatives going out to local establishments, venues, events, what is the, that is a two-part question, what is the benefit to the local establishment? Is there some kind of revenue that goes to them? Some benefit. You can elaborate on that and then I'll do my second question. Sure, that would depend on the arrangement. You may have an arrangement with a certain tavern or a type of business where you pay some type of benefit, but if that's the case, then we do require that that business be licensed and properly vetted through the regulators, but that may be an arrangement that is permitted for field marketing. So my follow-up is that I think I thought about, we have a study that's going to be conducted on how sports wagering could impact beneficially those establishments that are minority owned. And when, before I read your application, I had imagined that perhaps there might be opportunity for these kinds of partnerships with the new licensees coming in to see if there would be a chance for you to partner with those establishments, look for those kinds of partners where your marketing efforts are directed to bring in new clients, new patrons, and at the same time, perhaps enhancing the local establishments, and particularly those that are minority owned, of course, women owned and that owned we love too, but I am thinking about that in an opportunity here for you to think about. No, we appreciate that. And we do always, as part of our diversity, equity inclusion initiatives, we always do consider vendor opportunities as well. And we do see that there are opportunities for field marketing, again, if permitted. And I do want to clarify that when we do any such activities, whether it's through a partnership or kind of a one-off type of event, we undergo licensing, not only licensing, but they undergo a vendor registration through win resorts where they have due diligence performed on them, and then they undergo responsible gaming training as well. So our expectations are high for any such partners that we engage with. Thank you. I know that Commissioner Hill, you might be leaning in because I know you think a lot about community ties, so. So I actually wanted to maybe further the discussion, and maybe you can talk to us about your experience in engaging with communities, working with nonprofits, volunteering in the community, in other jurisdictions. Can you enlighten us what you've done in your experience? Yeah, we have worked with several vendors in all of the jurisdictions that we partner with. We have our partnerships with local teams in some of the jurisdictions. I mentioned those in the presentation, for example, the New York Jets and the Detroit Lions. And so we try to engage with the sports vetting community through those activities. Win resorts, and as you know, Encore Boston Harbor are significantly involved in local community processes and engagement, and our staff are part of those initiatives as well. So we do work with not only helping identify what opportunities there are for our staff to engage in, but work within our Win Resorts family on community engagement and volunteer opportunities. And then if I can just follow up since we're in this particular section, Madam Chair, your experience in tourism. Massachusetts, one of the biggest industries we have is, excuse me, is the tourism industry. So can you talk to us of your experience in that field? Well, so clearly that Encore Boston Harbor, our sister property has the most experience with tourism and hospitality because they'll have the retail location. But as mentioned, the our executive team is heavily involved or has been heavily involved in the online gaming industry as well as the retail gaming industry and has knowledge about the interests of players. And so what we do is we use hospitality activities as a way to draw on players. I think in the demo, you saw win tickets to a sporting event. We actually have sent players to our land-based properties where they now become accustomed to our brand in the retail setting. So there's a lot of opportunities to increase tourism through what we do, even though we're in the mobile and internet space. Thank you, Ms. Robertson. Thank you, Madam Chair. Can I follow up on that? Looking at, there was a discussion about the nonprofit leadership fellows program that Wynn does in Vegas, where they pull in the leaders from the local nonprofits in Vegas and they basically try to give them, help their business acumen. If they've done anything like that in Everett and or you guys planning on doing something like that for the businesses in Everett, I know you're the mobile, but you'll be tethered to EVH. Again, I think that was an Encore Boston Harbor, initiative that they work with the Wynn Foundation on offering. I participated in the one in Las Vegas and it was really amazing. But again, that is something on the retail side th