291 River Road, Sault Ste Marie, ON CANADA P6A 5K9 Tel: +1 705 759-1832 The Casino Gaming Control Section Department of Justice, Equality and Law Reform 2nd Floor, Bishop's Square, Redmond's Hill, Dublin 2 Attn: Dermot Ahern, D.T., Minister of Justice, Equality and Law Reform November 20, 2009 Dear Minister Ahern, Re: Making a Fully Informed Decision on Ireland’s Options in Blocking Unauthorized iGaming Please consider with some urgency the following information in your review of gambling in Ireland. We have market access control technology for internet gambling (iGaming) that is unlike any previous ‘solution’ for managing the iGaming market. Our technology system is extremely precise, designed specifically to restore total market control of iGaming to a government authority. It is capable of page specific URL-blocking as well as blocking existing play and massive revenue outflows by currently active players in Ireland. It gives the government central real-time control of the Irish borders to fit with Ireland’s gambling laws and policies. The result is that with our technology, Ireland is fully in charge of its iGaming framework, licensing approach, taxation rates and regulatory compliance. In other words, it lets Ireland treat iGaming in exactly the same way it manages any other form of gambling in the country. This technology is the turning point for iGaming decision-making in governments. We have presented the technology to GREF (Gaming Regulators European Forum) and are in discussions with several European countries for its use in their iGaming models. It is critical that Ireland understands the empowerment our technology brings to their future iGaming management. /…2
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291 River Road, Sault Ste Marie, ON CANADA P6A 5K9 Tel: +1 705 759-1832
The Casino Gaming Control Section
Department of Justice, Equality and Law Reform
2nd Floor,
Bishop's Square,
Redmond's Hill,
Dublin 2
Attn: Dermot Ahern, D.T., Minister of Justice, Equality and Law Reform
November 20, 2009
Dear Minister Ahern,
Re: Making a Fully Informed Decision on Ireland’s Options in Blocking Unauthorized iGaming
Please consider with some urgency the following information in your review of gambling in Ireland. We
have market access control technology for internet gambling (iGaming) that is unlike any previous
‘solution’ for managing the iGaming market.
Our technology system is extremely precise, designed specifically to restore total market control of
iGaming to a government authority. It is capable of page specific URL-blocking as well as blocking
existing play and massive revenue outflows by currently active players in Ireland. It gives the government
central real-time control of the Irish borders to fit with Ireland’s gambling laws and policies.
The result is that with our technology, Ireland is fully in charge of its iGaming framework, licensing
approach, taxation rates and regulatory compliance. In other words, it lets Ireland treat iGaming in
exactly the same way it manages any other form of gambling in the country.
This technology is the turning point for iGaming decision-making in governments. We have presented
the technology to GREF (Gaming Regulators European Forum) and are in discussions with several
European countries for its use in their iGaming models. It is critical that Ireland understands the
empowerment our technology brings to their future iGaming management.
/…2
Furthermore, it is technology that Ireland can put in place immediately. The employment of this
technology right now can establish a foundation for all Irish iGaming planning, including configurable
‘brownout’ periods during the application process for those iGaming operators who have not applied,
and full ‘blackout’ control on those not approved at the end of the process.
The result of employing our system is that Ireland will capture all iGaming taxation revenue, and
approved operators will be rewarded with the full iGaming marketplace in Ireland – no ‘leakage’ of
revenues to unauthorized sources.
Ireland government gaming authorities need to know that there are extreme flaws with other blocking
options traditionally considered. IP list blocking leaves a gaping hole – it does nothing to stop the
wagering activity of existing players that have downloaded an application onto their computer or
mobile. This means IP blocking will leave the vast majority of current iGaming revenue ‘unblocked’, in
essence cheating Ireland out of tax revenues and cheating future legitimate iGaming license holders out
of access to the whole iGaming market in Ireland. Banking transaction blocking is notoriously easy to
get around, as the United States learned with UIGEA. Again, this approach results in a large portion of
the iGaming market remaining uncontrolled, unauthorized, untaxed and unregulated.
Our technology is called EdgeDefinition™ Market Access Control. I have attached for your consideration
four different documents outlining its importance in setting up iGaming. Please refer to our GREF
presentation, the iGaming Blocking Comparison Chart, the EdgeDefinition™ Summary, and the
BlackEdge Technologies White Paper on iGaming.
I strongly believe this technology is fundamental to your future internet gambling framework. I invite
you to explore more of its capabilities with us through a live demonstration and a detailed exchange of
information. Most of all, I urge you to be fully aware of the options available to you in iGaming
management, and to make decisions that fully meet your objectives in managing gaming for full public
benefit and with absolute control over public safety and gaming integrity.
I welcome any opportunity to discuss this further with the Ministry.
Best regards,
Ian Plumley
President & CEO,
BlackEdge Technologies Inc.
Technology Solutions that Empower Legal iGaming Management
EdgeDefinition™ puts your State in control of its borders for Internet Gaming
It’s your house. You decide who can play.
Product Summary An industry exclusive solution that gives gaming jurisdictions full control over their Internet geographical boundaries. EdgeDefinition™ constantly maintains access control over known and emerging illegal internet gaming sites while enabling those legal in your jurisdiction. Vigilant. Constant. Reliable. Proven
Product Features and Highlights • · Centralized Administration • · Page-specific URL Enablement/Disablement • · Geographical Precision in Access Borders • · Proven multi-million user Installations • · Empowering ‘Conduct and Manage’
Unlike any other gaming software market management solution, EdgeDefinition™ puts gaming authorities in authoritative control of their borders. While Internet gaming began as an unregulated market, its emergence as the fastest growing sector of gaming depends on one thing—the ability of gaming regulatory bodies to regain the full control of their market as specified by law. BlackEdge brings an unprecedented solution. Proven in major worldwide installations, EdgeDefinition™ achieves what has not been done before—real time, full time access management that identifies unlicensed gaming sites while enabling state-sanctioned sites.
Contact Us for a Demo—take control now.
Our team can show you live how this works, and how EdgeDefinition™ addresses all the igaming legal framework needs for your jurisdiction—whether you want to control and licence igaming sites or simply stop millions of dollars bleeding from your economy. Call Ian at (705) 759-1832 or email [email protected]
Find out how we bring the pieces of the igaming puzzle together at
www.blackedgetechnologies.com
iGaming lobbyists like RGA and EGBA, funded from iGaming operator profits, try hard to convince jurisdictions to not use blocking.
Their motivation is clear – to keep all iGaming profits flowing for pure corporate gain, at low or no tax and with little control. They want to preserve an extreme imbalance versus all other forms of Gambling. Their misinformation campaign is well-funded but entirely self-serving.
iGaming can be managed within your jurisdiction.
Within your gambling policy and laws. On a consistent level
with other forms of State-authorized gambling.
At a fair and consistent gaming tax rate for public benefit. With full regulatory and compliance
control to protect your citizens.
EdgeDefinition ™ Access Control Technology is designed
specifically to enable State control of iGaming within State
borders and laws. It is a technology that restores power to the jurisdiction and
dramatically increases iGaminglicensing revenue and regulatory integrity.
Compliance PublicBenefit
Stops
Unauthorized Access by Unlicensed Operators
Empowers Full RegulatoryCompliance & Shutdown
Avoids Overblockingand Unintended Disruption
Enables Licensing Fees Consistent with other Gambling
Protects Consumers and Access to Funds
Rewards LawfulOperators and Eliminates Bank Policing
Geo-BlockingVoluntary Operator-specific self-restriction by ethical or publicly traded companies or as required to obtain a license
IP List Blocking and PortalsState-mandated and enforced IP Address lists
EdgeDefinition™Page-Specific URL Address and iGaming Application Access Control within precise borders with central administration by the State and real-time monitoring and detection
The right blocking technology works. EdgeDefintion™ by BlackEdge Technologies.
Contact us for an in-depth discussion and demonstration of the only technology for pure iGaming market control. Visit www.blackedgetechnologies.com email [email protected] or call +1 705 759-1832
Lawyers and lawmakers trying to understand the law of Internet gambling often make the job more difficult for themselves by starting with two unstated, and incorrect, presumptions:
1. Because the Internet obviously involves communications, it is assumed that gambling on the Internet is controlled by communications law, in particular that is protected in some way by the United States Constitution.
2. Because the Internet allows transactions to take place between individuals located on opposite sides of the globe as easily as on opposite sides of the street, it is assumed that Internet gaming is controlled by international law (or by no law at all), and that it is a problem to be dealt with solely by national federal governments.
Gambling is not a form of speech. When a bettor places a wager by speaking to his illegal bookie by telephone the activity is covered not by communications law, but by gaming law. If actual human speech is not analyzed under the law of communications, a wager placed through computers communicating with each other has no chance of being protected as an exercise of free speech.
The Internet in general and Internet gaming in particular are not sui generis. The ability of large numbers of individuals to easily communicate instantly across borders has been around since the invention of the telegraph. The United States and other federal governments did become involve with regulating the telegraph and similar technological breakthroughs, such as the telephone and short-wave radio. But the control of gambling has always been a matter left up to the states under their police powers. Gambling involves not only the health, safety and welfare of a state’s citizens, but issues of morality. These are almost always questions for state governments to decide. Federal governments are governments of limited power. Their role is to aid their states in implementing state exercises of police power, and not to dictate morality for the entire nation.
"… illegal and unregulated activity is occurring in Kentucky, and … millions of dollars are being lost as a result of (iGaming) activity, a fact that wasn't disputed in Tuesday's ruling... the most appropriate step is to make our case to the higher court,"