Getting ready for the US market
Transcription
Getting ready for the US market
14 LETTER FROM THE DIRECTOR T Industry experts look at what happened – and what’s next his is our 19th issue, and it will be distributed in London at two great industry events – January 24-26 at the ICE Affiliate Zone and January 27-29 at LAC. We’re looking forward to seeing you at one or both of these shows, the first major get-togethers of 2012. Thanks in large part to what the U.S. Department of Justice announced at the end of 2011, there will definitely be a lot to talk about! GPWA Executive Director: Michael Corfman Program Manager: Steven Corfman Forum Moderator: Anthony Telesca Membership Manager: Nancy Troy GPWA Times Magazine Managing Editor: Vin Narayanan Senior Editor: Aaron Todd Associate Editor: Dan Igo Copy Chief: Bill Riley Designer: George Choi To advertise in the GPWA Times, please e-mail: [email protected] • You Don’t Know What You Don’t Know, by Frank Pracukowski • A Present from the DOJ: Internet Lotteries (and Poker?) Are Legal, by I. Nelson Rose • Thanks for Nothing, by Yehoshua Gurtler • Changes Are Coming to the U.K. Online Gaming Market, by Melanie Ellis No Also in this issue: we reveal the interesting and sometimes surprising results of our Second Annual Member Survey, Sinead Lambert tells us what’s hot in sports betting, Paul Reilly and Gary Beal share innovative SEO strategies, Jeremy Enke offers valuable tips for choosing new poker programs, Jason Rosenberg and Claire Wellard show how private tournaments can increase your traffic, the camera of Alex Pratt takes us on a tour of Barcelona, and we say farewell to beloved GPWA member Pat Chapdelaine (giggles), who passed away in October. As always, let me close with a reminder. If you haven’t done so already, subscribe now to the GPWA Times Magazine at gpwatimes.com. And one final word – my New Year’s advice to fellow webmasters around the world: Fasten your seatbelts and get ready for a wild regulatory ride in 2012! For a FREE subscription to the GPWA Times Magazine, visit: gpwatimes.com Sincerely, Michael A. Corfman GPWA Executive Director ISSN 1941-9872 • Getting Ready for the U.S. Market, by Anna Sainsbury Our cover story, on fractured online gaming markets around the world, comes in six pieces: Vin Narayanan, Anna Sainsbury, Frank Pracukowski and I. Nelson Rose discuss different aspects of the U.S. side of the story, while Yehoshua Gurtler (“Thanks for nothing!”) and Melanie Ellis recap some of what’s been going on in the EU and the U.K. In addition, be sure to check out this issue’s two affiliate manager interviews, five affiliate interviews and the Departments – the latest industry news, numbers, notable quotes, an updated list of GPWA sponsors, the cartoon caption contest, the Wall of Shame and our calendar of upcoming industry happenings. Advertising Subscriptions • News Analysis, by Vin Narayanan 40 Second Annual GPWA Membership Survey Whether looking back or looking ahead, cautious optimism continues to be the prevailing sentiment among our members. See what people are saying about our industry and their place in it. Yes Marketing Director: Andrea Mullaney Cover Story: Fractured Markets – The one-market dream for the U.S. and Europe is shattered 50 How to Position a Brand-New Site on Google Page 1 in Under Two Weeks Paul Reilly shows us what it takes to go from a standing start to page-one ranking in an amazingly short amount of time. Hint: you need links! ALSO IN THIS ISSUE 8 What’s Big in 2012, by Sinead Lambert 10 Barcelona in Photos 42 Five Tips for Choosing New Poker Affiliate Programs to Work with in 2012, by Jeremy Enke 44 Adding Tournaments to Your Arsenal Is Good for Business, by Jason Rosenberg and Claire Wellard 48 Social Media SEO – Google’s G+, +1 and SEO, by Gary Beal 75 In Memoriam – Pat Chapdelaine (giggles) DEPARTMENTS 4 Webmaster News 6 By the Numbers 7 Cartoon Caption Contest 47 Event Calendar 54 Affiliate Interview Series 68 Affiliate Manager Interviews 72 GPWA Sponsors 76 APCW’s Wall of Shame WEBMASTER NEWS Quotables William Hill fires seven managers, resumes online operations in Israel By Aaron Todd “Indian tribes can compete and be as successful as anyone else.” – Bruce Boszum, chairman of the Mohegan Tribe, who said that Internet gaming is of “critical importance” to his people “I am willing to not include it in the bill, only because I want to get into court as soon as possible to have the federal law declared unconstitutional.” – New Jersey Sen. Ray Lesniak, who said he would drop Internet gaming provisions from a new sports betting law in order to get Gov. Chris Christie to sign it “The U.K. is the largest regulated market in the world today and we want to be part of that. The decision was not taken on market share. The key thing is to develop trust with the U.K. customer. This is one of the most important things for the industry.” – Bodog Chief Marketing Officer Dee Dutta in explaining his company’s new marketing push in the U.K. “MGM is proud to have bwin. party as our partner as they have the assets and experience that, combined with our brands, can ensure a secure, fair and entertaining online poker experience.” William Hill fired seven senior managers of its online operations and the company is back to business as usual after remaining employees returned to work following a walkout last fall. “The group can now confirm that normal operations have resumed and that William Hill Online remains committed to its operation in Tel Aviv,” the company said in a statement. The Telegraph reported that Ralph Topping, William Hill’s chief executive, fired the managers after ex-Israeli intelligence officers “found plans for a rival business and that a rabbi, fish feeder and hairdresser were on the books.” William Hill has reportedly agreed to pay £2 million in severance to dismissed staff. The severance pay is part of a deal that saw the dismissed staff sign non-compete agreements, according to The Guardian. The rift appeared to begin with Eyal Sanoff’s alleged refusal to share William Hill Online (WHO) accounting informa- tion with William Hill executives. Sanoff is a friend of Teddy Sagi, the founder and 40 percent shareholder of Playtech, which in turn owns 29 percent of WHO. Sanoff resigned in late September. In mid-October, nearly all of the WHO employees in Tel Aviv walked out, apparently worried that their office would be shut down and moved to Gibraltar. William Hill responded by offering employees who returned to work by October 23 an extra month’s pay in November and another month of bonus pay in June 2012. Employees were also given assurances that they would have at least six months’ notice if William Hill decided to terminate their position for any reason other than poor performance. The Telegraph reported that several William Hill executives stayed behind in Tel Aviv to supervise the office for a few months. – Jim Murren, Chairman and CEO of MGM Resorts “Testimony heard today and other testimony presented in writing, such as ours, demonstrates that new technology and processes used in ecommerce have been successfully adapted in jurisdictions where Internet gambling is legal, such as Great Britain, France, Italy and provinces in Canada, to keep minors from betting online and prevent illegal activities, such as money laundering and fraud.” – AGA President Frank Fahrenkopf “Internet gaming makes total sense. . . . There is so much money leaving the U.S. and the country is losing potential revenues.” – Donald Trump Webmaster News “Full Tilt was not a legitimate poker company, but a global Ponzi scheme. Full Tilt insiders lined their own pockets with funds picked from the pockets of their most loyal customers while blithely lying to both players and the public alike about the safety and security of the money deposited.” – Preet Bharara, U.S. Attorney for the Southern District of New York “We’re well behind the rest of the world. If we do nothing, [the problems] will grow and we will have no opportunity to fix it.” – Poker Players Alliance Chairman Alfonse D’Amato on regulating online poker in the U.S. 5 Absolute Poker founder pleads guilty to bank fraud and money laundering By Vin Narayanan Absolute Poker co-founder Brent Beckley entered a guilty plea on December 20 in response to charges of bank fraud, money laundering, illegal gambling offenses and violating the Unlawful Internet Gambling Enforcement Act (UIGEA) filed by the Department of Justice on April 15. Under the terms of the deal, Beckley pled guilty to one count of bank fraud and wire fraud and one count of conspiracy to engage in unlawful Internet gambling. Prosecutors are recommending a prison sentence of between 12 and 18 months. Beckley has also agreed to forfeit $300,000. Beckley, 31, had been living in Costa Rica. He voluntarily returned to the U.S. on December 19 to make his guilty plea. Sentencing is scheduled for April 19. “As charged, these defendants concocted an elaborate criminal fraud scheme, alternately tricking some U.S. banks and effectively bribing others to assure the continued flow of billions in illegal gambling profits,” said U.S. Attorney Preet Bharara immediately after the indictments were handed down on what is known as “Black Friday” in online poker circles. “Moreover, as we allege, in their zeal to circumvent the gambling law, the defendants also engaged in massive money laundering and bank fraud. Foreign firms that choose to operate in the United States are not free to flout the laws they don’t like simply because they can’t bear to be parted from their profits.” PokerStars founder Isai Scheinberg and Full Tilt Poker founder Ray Bitar were also indicted in April, and several bank accounts belonging to Absolute, Full Tilt and PokerStars were seized. PokerStars has already returned the money it owed American players when it pulled out of the U.S. market. The status of money owed to Absolute Poker and UB players is unclear. Since the indictments were issued, Absolute Poker, UB.com and PokerStars stopped accepting U.S. play. Full Tilt stopped accepting U.S. play as well, and eventually shut down its operations when Alderney suspended the company’s license because it did not have enough money to pay its players. Full Tilt is in the process of being acquired by Groupe Bernard Tapie (GBT). If the sale is completed, GBT will be responsible for returning money to players outside the U.S., and the DOJ will be responsible for returning money to American players. Bodog moves U.S. players to Bovada By Aaron Todd American online gamblers can no longer gamble on Bodog, as of December 14. Players accessing Bodog.eu from the United States that day found a note stating, “Access to this site is not available from your current location. The Morris Mohawk Gaming Group no longer offers its services under license from the Bodog Brand. You can find their services now available at www.bovada.lv.” American players are now automatically redirected from bodog.com and bodog.eu to bovada.lv. Other than the domain name change (a combination of the words “Bodog” and “Nevada”) and a new landing page, not much has changed for U.S. players. Players can sign into the new site with existing usernames and passwords, and existing balances have been transferred to the new site. Players can access the same games that are available at Bodog Casino, and the sports betting menu looks identical to what is offered at the Bodog Sportsbook and Racebook. U.S. poker players who open up the Bodog Poker client are told that it is no longer supported and bovada.lv software begins downloading immediately on their machine. The software, published by Trident BPO Trading Limited, appears to be identical to Bodog Poker software, and U.S. players on Bovada play on the same network and at the same tables as Bodog’s non-U.S. players. Webmaster News BY THE NUMBERS 90 million Number of Americans who will use a tablet device in 2014, according to eMarketer. 71 percent 16 Growth in the 2011 World Series of Poker Europe Main Event compared to 2010. Number of terms served by Massachusetts Congressman Barney Frank, who announced he will retire at the end of 2012. 12 to 14 months $390 million How much money Full Tilt Poker owed to players worldwide by the end of March 2011, according to the U.S. Department of Justice (DOJ). $150 million How much was owed to American players, according to the DOJ. €3.8 million $1.2 million The amount won by Thomas ”Kallllle” Pedersen in the 2011 PokerStars World Championship of Online Poker Main Event. Amount won by gambler “A.D.” on the Mega Moolah online slot machine. $0.50 The cost of the wager “A.D.” made on his winning spin. $59 million How much Full Tilt had in its bank accounts at the end of March 2011, according to the DOJ. 200,000 Number of people who competed in $1 No Limit Hold’em tournament on PokerStars on December 4, a new Guinness World Record. By the Numbers $935,100 Amount won by a Lebanese player on the Millionaires Club III slot machine at Intercasino. 5.3 percent 180 Number of people laid off by pocket kings, the technology and marketing consulting service of Full Tilt. How much time Caesars Entertainment will need to get a U.S.-based Internet poker website up and operating, according to CEO Gary Loveman. $8,715,638 The drop in share price of William Hill’s stock the day after more than 180 employees walked out of its Tel Aviv office. The amount won by Germany’s Pius Heinz in the World Series of Poker Main Event. $500 billion The amount advertisers spent worldwide in 2011, according to an estimate from eMarketer. 350 million Number of users who access Facebook via mobile devices, according to the site’s internal statistics. 26,000 The estimated number of attendees at October’s Global Gaming Expo in Las Vegas. 2nd Rank of LiveSport in this year’s Deloitte Technology Fast 50 Central Europe. CAPTION CONTEST 7 This Issue’s Cartoon So they decided to elope! And who could blame them after what they’d gone through at her parents’ house (see cartoon below)? But . . . hold on a second . . . they’re leaving the chapel, but did they actually go through with it? He looks like he may have had (or is currently having) second thoughts, and she looks like she may have had too much to drink. Once again, only YOU can tell us what’s going on! Go to the forums at gpwa.org and submit your caption for this cartoon. We’ll take a look at all the entries and pick the one we think is the funniest. The winner will be announced in our next issue and will receive a free copy of the iGaming Business Directory. Drawings by Ben Riley, www.ben-riley.com Last Issue’s Cartoon The Winner is . . . “Parents! That wasn’t in the T&C’s!” – hakank Congratulations to “hakank,” who wins a free iGaming Business Directory. And the runners up . . . “Advertising schmasvertising! And don’t call on my daughter again until you have a REAL JOB!” – Chips “Meeting Mom and Dad” – the previous episode in our favorite affiliate’s whirlwind romance – didn’t go well, as indicated by Dad’s reaction. We asked you to tell us what’s happening here – and you did! Thanks to all participants. “Look, mister... When I said that I was just doing a look-up on your daughter’s portal to make sure it was free of viruses, I think you totally got the wrong idea!” - HodgeyBoy “I hope there’s no negative carryover.” – vinism “I can’t believe that was Senator Kyl’s daughter!” – Anthony Caption Contest What’s big in 2012 by Sinead Lambert 2012 is a big year! On top of the usual peak events, this year we have UEFA Euro 2012 and the London Olympics. Below are four events to target and plan for. But before deciding on which events you’re going to target, have a talk with your affiliate managers. Find out which events they focus on, which events generate the most revenue and which events are best for acquisition. Cheltenham (March 13-16) The Cheltenham festival is a staple in the U.K. sporting calendar. Held over four days, it is one of the biggest betting events of the year, with over £500 million reportedly wagered in 2011. It attracts highvalue racing punters, much coveted by bookmakers and affiliates. The four-day festival is the bread and butter for many sportsbook affiliates. The number of online and mobile bets is increasing at a phenomenal rate year on year. The Racing Post App spent four days as the No.1 sports app in iTunes during the festival in March 2011, with a record number of 60,000 customers using the app. Put simply, the festival is too big to ignore. As Cheltenham punters are typically quite high value, bookmakers offer generous customer and affiliate deals during the festival, like increased free bets, daily customer cash-back offers and increased commissions. Even though it is extremely competitive it is still worth your while to promote the festival. Start early; have a chat with your affiliate managers at LAC. Decide up front which bookmakers you’re going to promote. Instead of promoting every bookmaker under the sun, just promote a select few. Go with the bookmakers with the strong, reputable brands. Your traffic will recognize and trust them, so they will convert well for you during the festival. These select few will also be well established and will retain your referrals for you. Grand National (April 14) An estimated 600 million people watch the Grand National worldwide. It is the highlight of the sporting and betting calendar, where everyone from grannies to toddlers places a bet. Due to the mass appeal of the Grand National, whatever the focus of your site is – bingo, poker or casino – it is still worth your while to include some Grand National content on your site. The Grand National is the complete opposite to Cheltenham; it’s all focused on one race, and the audience is largely made up of novice and low-value punters. Keep this in mind when building your Grand National plan. Grand National content should be simple and straightforward. A step-by-step guide on how to pick a winner or a guide on how to place a bet works well. As with Cheltenham, pick a core set of operators to work with. Focus on large brands that are well recognized and well trusted. Your audience is novice punters, so they will only recognize large brands; the smaller operators will not convert as well for you. It’s never too early to start planning. Have a chat with your affiliate managers at LAC; ask them what their plans for Grand National are. Find out what their commission plans for Grand National are, and what their free bet offering will be on Grand National day. Some bookmakers aren’t interested in promoting the Grand National as they believe the quality of customer is too low, while other operators actively chase the large acquisition numbers during the Grand National. Start building a list of bookmakers you will be working with for Grand National 2012. Whatever you’re promoting on your site – life insurance, holidays or cupcakes – on April 14, include some Grand National content (e.g., Grand National odds, free bets and a guide on which horses are the favorites). It is the only thing people will be searching for that day. “ 9 Instead of promoting every bookmaker under the sun, just promote a select few. Go with the bookmakers with the strong, reputable brands.” Euro 2012 (June 8 – July 1) Europe is on its knees and desperately needs a distraction from the never-ending debt crisis and bank bailouts. A football tournament is exactly what’s needed to revive national pride. Euro 2012 kicks off in Warsaw on June 8 and finishes a month later on July 1 in Kiev. Unlike Cheltenham and the Grand National, Euro 2012 is a month-long event. It’s a marathon, not a sprint. With daily football matches, it would be impossible to cover every single match, but make sure you cover the top countries’ games – Spain, Germany, France, England, Italy and Holland. They’ll be the most watched games and the most searched for online for highlights, previews, reviews and tips. So make sure you’re ranking well for all the top keywords related to those countries. As always, it’s going to be very competitive to get traffic to your site, so once you get that traffic you have to make sure you have the right content to retain it and convert it to active betting accounts. Simply plastering your site with free bet banners is not going to cut the mustard. Match previews, links to where the match is available online, bookmaker offers, free bets and the latest odds are all essential tools to help you convert your traffic. Once again, it is important to choose whom you’re going to work with carefully. You want to choose bookmakers who are recognized brands across Europe, who offer competitive prices across a range of markets and who live stream a range of matches. Choosing which operator to promote is important as you want to choose a partner who will maximize your referral traffic and convert and retain it for you. Olympics (July 27 – August 12) Whether the Olympics will be a big betting event or not is hard to say. Some bookmakers believe it won’t be, while others are making it a big part of their strategy for this year. Some bookmakers are using it as an opportunity to change people’s perceptions and show the public there is more to bookies than racing and football. Some are saying it will be the most betupon Olympics in history, but that’s not really saying much. The online gambling industry was completely different during the last Summer Games in 2008, so I don’t believe that is a fair comparison. While it likely won’t garner as much action as the other three events, make sure you keep it on your radar. Always remember, the most important thing you can do to get ahead is to plan. Give your affiliate managers a shout and get to work! Sinead Lambert is the affiliate marketing manager for Valuechecker Affiliates. What’s big in 2012 We love this city! In September affiliates from around the world gathered once again in Barcelona, which has become a preferred venue for gaming industry conferences and events. This time they were there for the Barcelona Affiliate Conference – and as you can see from the pictures, a good time was had by all! Photos courtesy of iGB Affiliate. These two lovely ladies are definitely having a good time. Nick Richardson, obviously having the time of his life. Barc Let’s party! Left to right: Esther Louise Cochrane, Zaruhi Surmenyan, Arusha Iqbal, Sarah Jones, Lisa Whorrall. The gentleman in the middle is Fotis Bachtsevanis from InterPartners. We don’t know the guys who are holding Fotis up, but we like their beards. Two excited attendees strike a formal pose. 11 celona These three shady characters are Mehmet Cicek, Carola Tobar and Miko Salo. We can’t ID the guy in the plaid shirt, but the others are, left to right, Sabrina Robertson, Ciara Martin from Stan James, Trevor Weir, Kiera Goymour and Shona ODonnell from iGB. Marit Van Stedingk from IGaming Business, Carly Wilson and Robyn Katie wish you were here. Another couple takes time out to pose for our roving camera. They’re gorgeous, aren’t they?! Nick Richardson and Jaspal Singh. Has the guy on the left just spilled his drink on the other guy? Oh well - party on! That’s Shahar Attias in the back on the far left, and the waving woman is Yulia Jeshinko. They’re both from Hybrid Interaction. The two ladies in this dramatic shot are Mary-Fe and Francesca from Love Events. 13 Barcelona is beautiful - and so are these happy couples. Hey, isn’t that Natasha Goffman on the right? Yes, it is! We don’t know his name but the guy in the middle works for the company that supplied the stunning models for the party. The guy on the left? You tell us. The guy on the right? He’s Julian Dellipiani from GTECH G2. Second from the left in this photo is Fransyska Kardinetti, and Steve Cutajar in at far right. Two more mystery guests, just making the scene. On the left: Lee-Ann Johnstone from Optimal Payments (NETELLER). Are they having a good time? Yes, they are. COVER STORY Fractured Markets The one-market dream for the U.S. and Europe is shattered Six industry experts look at what happened – and what’s next B alkanization – that old term we learned in history class when we were kids – comes to mind once again when sizing up what’s been going on recently in online gaming. The European Union caves in to the local interests of each member state at every crossroads. In the U.K., tax and regulatory changes are on the way. And in the U.S., the Department of Justice ruled just before Christmas that individual states – all 50 of them (plus the District of Columbia) – could license and regulate non-sports related online gambling. What does this mean for the industry? Read on! The U.S. market: out of many, one — or every state for itself? News Analysis by Vin Narayanan T wo days before Christmas, the U.S. Department of Justice (DOJ) reversed its stance on online gaming and said individual states had the authority to license and regulate non-sports related intrastate online gambling. Intrastate online gambling means the gambling has to be confined within an individual state’s borders. So poker players living in Nevada can only play with other poker players living in Nevada. Or people in New York can only buy New York lottery tickets online. They can’t buy Illinois lottery tickets as well. If no action is taken by the U.S. Congress, it means that the American online gaming marketplace will be remarkably similar to the rapidly fracturing European market, with 50 different states (51 if Washington, D.C. is included) setting their own rules, regulations and laws – much like how individual European countries are rejecting a harmonized market in favor of nation-by-nation regulation. The legal opinion issued by the DOJ came in response to inquiries from New York and Illinois about online lottery sales and a letter written by Senate Majority Leader Harry Reid (D-Nev.) and Sen. Jon Kyl (R-Ariz.) asking for clarification on the legality of online gaming. For years, the DOJ had maintained the Wire Act prohibited all forms of online gambling. But in a letter written to Reid and Kyl, the DOJ announced it was adjusting its position after its Office of Legal Counsel (OLC) reviewed the law. “The Wire Act only applies to the transmission of bets or information assisting in the placing of bets or wagers relating to sporting events or contests,” wrote Assistant Attorney General Ronald Weich. “Since state lotteries conducted by New York and Illinois do not relate to sporting events, OLC concluded that the operation of these lotteries would not violate [the law],” Weich added. A Present from the DoJ: Internet Lotteries (and Poker?) Are Legal 15 After addressing the lotteries issue, Weich turned his attention to other forms of online gaming, including online poker. “Although the OLC conclusion differs from the Department’s previous interpretation of the Wire Act, it reflects the Department’s position in Congressional testimony at the time the Wire Act was passed in 1961. It also provides much needed clarity to those state governments that would like to permit wholly in-state, non-sports Internet gambling, including Internet lotteries” (emphasis added). Weich went on to say that in places where online gaming is clearly illegal, the DOJ would prosecute violators. “Furthermore, in states that ban various forms of gambling – including Internet poker – the Department will be able to investigate and prosecute those gambling businesses under the Unlawful Internet Gambling Enforcement Act and other sections of the criminal code,” Weich wrote. The DOJ’s Wire Act reversal dramatically reshapes the political landscape regarding online gaming. Individual states are now dealing from a position of strength. And how states, and those who support a fed- eral solution to regulating online poker, adapt to the new legal realities will determine the shape of the American online gaming market. Advantage states For years, one of the chief stumbling blocks for states considering online gaming legislation was the DOJ. Online gaming opponents always cited the fact that DOJ viewed online gaming as illegal, so it didn’t matter what the Unlawful Internet Gambling Enforcement Act (UIGEA) said. In 2005, the DOJ sent a letter to North Dakota instructing them not to sell lottery tickets over the Internet because it would be illegal, and states have been gun-shy ever since. This fear of the DOJ is why New York and Illinois wrote letters to the DOJ asking for clarification on the law, even though they believed it was legal to sell lottery tickets online under both the UIGEA and a less restrictive interpretation of the Wire Act. Neither state wanted to get into trouble with the DOJ. “ If no action is taken by the U.S. Congress . . . the American online gaming marketplace will be remarkably similar to the rapidly fracturing European market, with 50 different states (51 if Washington, D.C. is included) setting their own rules, regulations and laws.” Now that states have the DOJ on their side, the political dynamics have shifted. The U.S. market: out of many, one — or every state for itself? COVER STORY Two states that had been on the periphery of the online gaming discussion may now take up the issue in 2012. In Massachusetts, State Treasurer Steve Grossman is planning on creating an online gaming task force to evaluate online lottery products and possibly online poker, according to the Boston Herald. And in Connecticut, Gov. Daniel Malloy told the Hartford Courant he’d now be willing to consider online gaming legislation. But the most likely early entrants into the online gaming market are Nevada, which has already passed online poker legislation, California, Iowa and New Jersey. Nevada’s big opportunity In June, Gov. Brian Sandoval signed into law a bill requiring the Nevada Gaming Commission to develop and adopt online poker regulations by January 31, 2012, so licenses could be granted if the federal government approved it. On December 22, Nevada gaming regulators unanimously approved the regulations that had been crafted. And one day later, the DOJ released its opinion that states are within their legal rights to offer intrastate gambling as long as it excludes sports betting. As of press time, only seven companies have applied for licenses. Six have applied for service provider licenses, while only South Point Casino has applied for an operator license. If South Point is granted an operator license, it could become the first real-money poker room licensed and regulated in the U.S. Caesars Entertainment, which owns and operates the World Series of Poker, and MGM Resorts have not applied for Nevada online poker operator licenses as of press time. South Point’s presence in the Nevada online gaming market creates a serious dilemma for the two Nevada-based casino behemoths. Both companies are in a position to offer intrastate online poker in Nevada quickly – Caesars has partnered with 888 Holdings and MGM is working with bwin.party. But Caesars has been lobbying hard in other states – most notably New Jersey – to squash state-level online gambling efforts as it pursued a federal solution. MGM has also been pursuing a federal strategy. The goal behind a federal solution is to give operators a single set of compliance standards, rather than 50 different sets – and hopefully interstate online poker (one national or almost national market). The big problem in California is that the companies and people most vested in the gaming industry can’t agree on an approach to online poker – and they haven’t been able to broker a compromise for a few years. And if Caesars and MGM choose to offer online poker in Nevada only, the companies will undermine their lobbying positions. They’ll simply have no credibility to tell other states not to offer online gaming if they’re offering it in Nevada. Some Indian tribes in California, most notably the Morongo Band of Mission Indians, want to pursue online poker aggressively. Other tribes in California want to take a much more cautious approach. Those tribes are not entirely sure online poker or any form of online gambling is good for their casino business. The California Tribal Business Alliance, which includes the Lytton Band of Pomo Indians, the Pala Band of Mission Indians and the Paskenta Band of Nomlaki Indians, has been the chief proponent of this position. The Iowa factor The Iowa Racing and Gaming Commission published a report in December designed to give Iowa’s part-time legislature a framework for discussing the issue. And State Sen. Jeff Danielson told delegates at the Digital Gaming and Lottery Policy Summit in Washington last month that he is hopeful his fellow Iowa legislators will pass online poker legislation in 2012. From a budget standpoint, Iowa is in the black, so they’re not looking to online poker for revenue reasons. “This is a matter of regulating gambling in Iowa,” Danielson told the conference. But Caesars has yet to weigh in on the debate, and they could kill it. Caesars is a big operator in Iowa, and they’ve lobbied hard to kill online gaming legislation at the state level. Danielson says he hasn’t heard from Caesars so far in Iowa. Apparently, they’re more concerned with a regulation that requires them to offer dog racing in order to have a gaming license. Maybe there’s room to nix the dog-racing requirement in return for not opposing online poker. Or it could be the case that the DOJ reversal on the Wire Act reduces Caesars’ leverage. Either way, the gaming industry should have an answer in Iowa by mid-April. Iowa’s legislature only meets for 100 days, and the 2012 session began in early January. California needs a compromise With almost 37 million people, California is the largest online poker market in the United States. And they are keenly aware that neighboring Nevada is racing to offer online poker as soon as possible. As a result, this could be the year California makes the move to offer online poker. The U.S. market: out of many, one — or every state for itself? California card rooms have also been pushing for online poker legislation, but with little success. The DOJ reversal on the Wire Act and pressure from Nevada (and New Jersey and Iowa), combined with a need for revenue, have created the most positive environment for online poker this state has ever seen. But the inability of stakeholders in California to hash out the issue over the past few years makes this a less than certain proposition. If the stakeholders are willing to compromise, this could be the year for California. New Jersey’s Atlantic City issue In March 2011, New Jersey Gov. Chris Christie vetoed legislation that would have made New Jersey the first American state to license and regulate online gambling. The legislation, which would have given Atlantic City casinos the ability to offer online gambling to New Jersey residents, passed the State Assembly by a 63-11-3 vote and the State Senate by a 35-2 vote in January of last year. In a message to the Legislature explaining his veto, Christie said the online gambling bill violated the New Jersey Constitution. “The State Constitution explicitly requires casino gambling to be restricted to the territorial limits of Atlantic City,” Christie wrote. “Senate Bill No. 490 seeks to avoid this requirement by deeming all Internet wagers as being placed in Atlantic City, even if the person placing the bet is outside the boundaries of the city. In my view, COVER STORY the creation of a legal fiction deeming all wagers to have ‘originated’ in Atlantic City cannot overcome the clear and unambiguous language of the State Constitution.” “Moreover, certain provisions set forth in this legislation are not consistent with my administration’s policy objectives, such as the continuation of public subsidies of horse racing,” Christie added. Christie said he was also worried about the development of Internet gambling cafés in New Jersey. “Nothing contained in the legislation would prohibit commercial establishments outside of Atlantic City such as nightclubs, bars, restaurants, cafés and amusement parks from offering Internet gambling opportunities in order to attract patrons or customers,” Christie said. At the end of his veto message, Christie suggested it would take a public referendum to change his mind about online gambling. State Sen. Ray Lesniak, who spearheaded the passage of the online gaming legislation, says he’s authored a new bill and fixed every element of his online gambling bill to meet Gov. Chris Christie’s requirements, except for the one that requires a voter referendum. He’s hoping to convince Christie that there doesn’t need to be a referendum. But if he can’t do that, he’ll put it on the ballot in November and let the voters decide. If the voters approve it, Atlantic City casinos could begin offering online gaming in 2013. Don’t count out the feds Even though states now have the DOJ’s blessing to offer intrastate online gaming, it doesn’t mean Congress won’t still act on the issue. Immediately after the DOJ gave its imprimatur to intrastate online gaming, the American Gaming Association (AGA) – a trade association of commercial landbased casinos – and the Poker Players Alliance (PPA) – a grassroots and lobbying organization for online poker players – renewed their calls for federal regulations. “The Department of Justice’s interpretation regarding the scope of the federal Wire Act validates the urgent need for federal legislation to curb what will now be a proliferation of domestic and foreign, unlicensed and unregulated gaming websites without consistent regulatory standards and safeguards against fraud, underage gambling and money laundering,” the AGA said in a statement. “This will provide policy makers at both the state and federal level with the legal confidence to move forward with licensing and regulation of online poker and other nonsporting activity within their respective jurisdictions,” said John Pappas, executive director of the Poker Players Alliance. “However, it is our hope that our federal policy makers see this as an incentive to move quickly to enact federal licensing and regulation before various states produce a mix of individual state schemes that may not be the best model to serve consumers.” “[The] PPA’s million-plus members have spoken loud and clear: they prefer clear, consistent federal legislation to a patchwork of state laws to license and regulate the game they love,” added former Senator Alfonse D’Amato, chairman of the PPA. “State-bystate licensing and regulation could result in a balkanized online poker world where players across the nation would be limited in their choices of where and against whom they could play. This could potentially reduce the number of total players, reducing revenues state lawmakers project from this activity. At the same time, it would deter entrepreneurs from entering the online poker market, as there would essentially be 50 different sets of laws and rules to which they would have to adhere.” The DOJ’s Wire Act reversal has made the path to passing federal legislation much more difficult. States jealously guard their rights. And the DOJ opinion essentially gave them the right to regulate online gaming. But the path still remains open. The conventional wisdom in political circles is it doesn’t matter what happens in the House of Representatives regarding online poker legislation. If an online poker measure is going to pass, it’s going to come from the Senate, and it will have to be attached to must-pass legislation because it can’t win a stand-alone vote in the Senate. Two people can make this happen – the aforementioned Sen. Jon Kyl and Senate Majority Leader Harry Reid. Kyl was one of the key architects of the Unlawful Internet Gambling Enforcement Act. He views prohibiting online gambling as a legacy issue. The UIGEA hasn’t been doing the job well enough. Americans are still gambling online. And the DOJ just gave states the legal authority to offer all The U.S. market: out of many, one — or every state for itself? “ The DOJ’s Wire Act reversal has made the path to passing federal legislation much more difficult. States jealously guard their rights. And the DOJ opinion essentially gave them the right to regulate online gaming.” forms of online gaming except for sports betting. So from Kyl’s standpoint, a bill that regulates online poker while banning all other forms of online gaming, is a plausible endgame. Lobbyists say Kyl is open to this line of thinking, and if that’s the case, he might be interested in striking a deal with Reid now. Reid really wants to pass online poker legislation. He represents the state of Nevada. The big casino companies in Nevada (except for Las Vegas Sands) want online poker. Therefore, Reid wants online poker. Reid knows he can’t pass online poker legislation through the regular process, so he has to find a bill he can attach it to. But he won’t attach it to must-pass legislation unless he knows he can get the bill through with the poker provisions. There are a limited number of vehicles each year to do this. Election-year politics also complicate the equation for 2012. Democrats and Republicans alike might not appreciate being forced to vote for a pro-gambling issue during an election year. But if Kyl and Reid forge a deal, federal action on online poker is still a possibility in 2012. Vin Narayanan is the managing editor of the GPWA Times Magazine. COVER STORY Getting ready for the U.S. market By Anna Sainsbury, GeoComply A nyone who follows the issues being discussed on Capitol Hill and in the U.S. media will be aware of the numerous hurdles and obstacles facing iGaming operators as they look to set up business in the U.S. While a full analysis of these issues cannot be as concise as size restraints require, the most important issues facing the iGaming industry in this process deal with questions surrounding state versus federal regulation, location and age verification, and the role of banks in processing financial transactions. State or Federal Regulation As with many divisive issues within U.S. domestic politics, the fate of iGaming is likely to fall to individual states, as it has Getting ready for the U.S. market for land-based gambling. State laws for land-based gambling vary greatly, with the majority allowing lotteries, but with about half of the states (22 of 50) and one U.S. territory permitting commercial casinos. There is no reason to expect that regulation of iGaming will be any different, despite the efforts of people such as Reps. Barney Frank (D-Mass.) and Joe Barton (R-Texas), who have argued that iGaming could increase tax revenue and create jobs. Although there are potentially huge financial benefits to regulating iGaming at the federal level, it is unlikely that the federal government would “encourage” all 50 states to enact legislation, as it did with the national drinking age by withholding money from the federal highway apportionment. What we know at this point is that there are a number of states, including Iowa, California, Nevada, New Jersey, Illinois and Florida, as well as the District of Columbia, that are looking to regulate iGaming or parts of it. This is where we believe anyone looking at the U.S. market should currently be applying their focus. Location Verification In order to ensure that financial institutions processing transactions for stateregulated iGaming companies are not in violation of the Unlawful Internet Gambling Enforcement Act (UIGEA), reliable location verification is paramount. Leading geolocation companies currently serving iGaming operators typically only offer location services through IP addresses. While IP geolocation is useful as part of a geolocation system it cannot be depended upon by itself to accurately identify the location of a player. This is due to a number of reasons, including the ability to 21 “ As with many divisive issues within U.S. domestic politics, the fate of iGaming is likely to fall to individual states, as it has for land-based gambling.” “spoof” IP addresses through proxy servers, the use of screen-sharing software (e.g., GoToMyPC.com) and the accuracy of IP address databases. Proxy servers act as an intermediary to supply a legitimate or approved IP address for the iGaming site they are attempting to access. While this has been a known and hitherto unresolved problem in the implementation of geolocation rules, solutions are now being made available from some geolocation providers which can limit this potential threat through the monitoring and banning of known proxy servers’ IP addresses. Screen-sharing software can permit players to bypass IP geolocation in much the same way as a proxy server. In this case a player can access an iGaming site through a remotely controlled computer that is in a regulated state, even though the player is in another state or country. To combat screen sharing, operators must ensure that their geolocation solution includes the specialized software required to detect when screen-sharing programs are running. The accuracy of IP databases can lead to a discrepancy between the location of a player and the location of an IP address. This is of particular importance when trying to geolocate people who live near a state border. In scenarios like these, people who live just inside a regulated state could be counted as living in the adjacent state and thus denied access to a service they rightfully should have access to. At the same time, people living just outside a regulated state might be counted as living within it and granted access, which would violate the UIGEA. Although some geolocation companies claim an IP-to-state database accuracy of 98 to 99 percent, other figures put the ac- Age Verification At this point it does not appear that any of the U.S. states looking to regulate iGaming have floated a Request For Proposal addressing financial transactions, nor have any of the major U.S. banks shown much of a presence at iGaming conventions, which leads to a couple of questions. First, what will make banks get interested in iGaming (is one state at a time a big enough prize for them?), and second, but more importantly, do they have the necessary tools to integrate into existing iGaming systems? A major social concern when talking about the regulation of any form of gambling is the possible effect it will have on the prevalence of underage gambling. This is of even greater concern when talking about online gambling because the openness of the Internet makes people believe that it is impossible to enforce age regulations. Neither question is answerable at this time; however, with the recent clarification from the Department of Justice (DOJ) that the Wire Act does not apply to non-sports wagers, banks may begin looking to develop a viable system for processing financial transactions for the launch of iGaming in the U.S. However, this perception is far from the truth. There are technologies that already exist which can meet the strict requirements of federal legislation to protect minors from accessing products or services they are not permitted to use. Other questions about players’ willingness to use online financial systems will always be around, but recent data indicates this should not be a concern. A 2011 survey by the American Bankers Association showed that Internet banking was the preferred method of banking for 62 percent of people, up from 36 percent in 2010. Even among people 55 and older, Internet banking was the preferred method at 57 percent. curacy of IP geolocation at anywhere between 70 and 99 percent. For these reasons operators should ensure that their geolocation provider utilizes other sources than just IP to determine a player’s location more accurately. By harnessing the additional metrics which the newest geolocation solution providers calculate, a player’s location can now be pinpointed with 10-50–meter accuracy. One such technology is Aristotle’s Integrity Direct, which is a Web-based age and identity verification service. The service is able to work in real time, verifying the age and identity of a website user against a database of government-issued IDs for over 3.4 billion citizens in 135 nations. The system is currently being used by tobacco delivery sellers to meet the requirements of the U.S. government’s Prevent All Cigarette Trafficking (PACT) Act of 2010. The act stipulates that tobacco delivery sellers cannot sell or deliver any tobacco products to people under the minimum age required for legal sale in the place the delivery is made. Technologies such as Integrity Direct, which are already being used to comply with government legislation, should be easy to integrate into iGaming systems to ensure that all players are of legal age. Banking With the uncertainty created by the UIGEA with regards to processing financial transactions for online gambling it is difficult to ascertain if and which financial institutions would be willing to step forward to service iGaming companies. For now, discretion rather than valor seems to be the order of the day among banks as they seek to avoid any associations with iGaming in the U.S. Not Quite There Yet The issues presented here certainly are not permanent roadblocks to iGaming in the U.S. In fact, age verification doesn’t appear to be the issue that some might claim it is. Yet, there is no getting around the fact that more work has to be done. However, these issues should now be much easier to address with the DOJ’s clarification on the legality of intrastate iGaming in the U.S. and by the upgrading by operators of their location-verification processes and systems. .................................... Anna Sainsbury, former commercial director of TST, has over seven years of experience in regulation and compliance across both the land-based and online gaming industries. Anna has worked with regulators, operators and vendors throughout North America, Australia, Asia and Europe. More recently Anna has taken up the challenge of developing and delivering a reliable geolocation solution for the U.S. intrastate market. As CEO of GeoComply, Anna is now working with some of the first movers in the emerging U.S. online gaming market to harness the latest technologies to ensure compliance with the UIGEA and other governing laws. COVER STORY You don’t know what you don’t know A major American land-based gaming exec shares what he’s learned about online gaming in the last two years By Frank Pracukowski, Foxwoods Development Company I have been in the gaming industry for nearly 20 years. During that time, I have developed what I feel is a fairly comprehensive understanding of casino operations – on the brick-andmortar side of the world. Online gaming, however, is a whole different story. What I have learned about the online gaming industry over the last couple of years is, “You don’t know what you don’t know.” My education was thrust upon me when Foxwoods Development Company began discussions with major online gaming operators and providers in Europe as part of a newly formed joint venture. So I started where anyone who doesn’t speak the language starts: I learned the language and acronyms of the online world. Let’s start with a few basics: B to C (business to consumer), B to B (business to business), B to G (business to government), KYC (know your customer). And let’s not forget clicks, hits, tweets and links. You may think you know what you are doing . . . but you don’t. Before 1990, if you wanted to place a casino or sports-type bet in the U.S. you had two choices: travel to a legitimate brick-andmortar gaming establishment or place an illegal wager through a bookie. Then along came the Internet and a new form of gaming appeared: Internet gaming through gaming casinos and sports wagering that can take place on any electronic device that offers Internet access anywhere on the globe. A number of large casino operators in the U.S. are expending significant time and money investigating online gaming pro- viders, with the goal of forming partnerships to be positioned for when the market opens in the U.S. Casino operators realize their expertise lies in traditional casino operations. Drive the patron to their multi-million-dollar gaming (and hospitality) facilities and the play will follow. But this is the Internet – the world of the young, educated, technically savvy user. Bringing patrons to your gaming site is just the beginning. The real question is how do you retain them? Remember, a customer will access your site and can easily click off your site and move to another gaming website in a matter of seconds. Players don’t have the same “investment” in the online gaming experience; they don’t physically leave their home and travel to your property. Consequently, the player’s online experience with your site will ultimately determine how loyal that player will be. Online casino operators need to understand how to effectively market to the online player. Ultimately, to be successful in online gaming, player retention is critical. Just because you selected your partner doesn’t mean the work is done. Once you have selected your dancing partner for the U.S. market, you will quickly realize that the real work has just begun. In many states, casino operators have not yet experienced working with regulators to begin drafting regulations. KYC requirements will be key and the right technology is the solution. Through the use of a “rules-based engine” combining technology and regulations, you will need to ensure that your players are who they say they are and that they are located where they say they are located. One could write a book on the KYC requirements for the U.S. market. I believe many operators are either underestimating this effort or think that it can’t be done. You don’t know what you don’t know Player loyalty and what it means to online gaming. I learned that online operators/providers in Europe don’t understand the significance or the value of patron loyalty programs used by most U.S. casino operators. Effectively integrating online gaming operations into their land-based loyalty programs has the potential to drive increased visitation not only to their online site but to their casino properties through targeted cross-marketing programs. The purpose of player loyalty programs is to reward the repeat player so that he plays longer. Operators who understand who their online patron is and what “reward” motivates repeat play will hold one important key to success in the online world. Play for Fun . . . is it play and is it really just for fun? I realized early on that there are two schools of thought on Play for Fun sites: whether the sites are loss leaders and whether you should have a Play for Fun site at all. I would liken it to your retirement plan – it is taking stock in your future. In the case of Play for Fun sites your future is developing player loyalty and obtaining e-mail addresses for the eventuality of the legalization of Internet gaming. If the conversation rate of Play for Fun to real-money play is 3 to 5 percent (using typical marketing conversion rates) wouldn’t you want 3 to 5 percent of a million versus 50,000 or 100,000? There are numerous reasons why a Play for Fun site is beneficial; however, don’t expect to see an immediate return on investment. If you develop your Play for Fun site correctly, the return will come as you convert these players once real-money play is legal. Poker, poker, poker. There is a strong push to launch Internet gaming by offering poker only. Why? Is it easier politically, because it is a game of skill? Poker will only make up a small portion of your 23 Foxwoods Resort Casino “ There is a strong push to launch Internet gaming by offering poker only. Why? Is it easier politically, because it is a game of skill? Poker will only make up a small portion of your overall online gaming income.” overall online gaming income. Experience has shown that the real money is in casino games. Take the U.K., for example. Online operators added casino games and immediately site revenues from casino games exceeded poker. And casino games don’t come with the headache of liquidity, managing the network, etc. Today’s partner is tomorrow’s competitor. Another thought to ponder: don’t overlook the possibility that the operator that you partner with today could become your competition tomorrow. Do you realize that in order to fully leverage your casino brand, the online operator needs to have access to your patron database? As of today in the U.S., online gaming sites can only be “operated” by owners of existing brick-and-mortar casinos. As a result of the economic downturn in the U.S. over the last two years, there are a number of distressed casino properties ripe for takeover. How difficult would it be then for an online operator in Europe to purchase the assets of a casino operator in the U.S.? They would be able to begin offering online gaming immediately, once it is legal to do so. A word of caution: be careful whom you select as your partner. Problem gaming and the underage patron. I very quickly learned online gaming critics believed Internet gaming would open up a “Pandora’s box,” making it easier for problem and underage gamblers. What these critics don’t know is that online gaming is much more easily regulated, controlled and monitored than the brick-and-mortar casinos through the use of technology. In the online gaming world specialized technology allows for monitoring every bet placed, who won and who lost each individual wager. In the brick-and-mortar world of gaming, unless that casino is utilizing chip tracking technology such as radio frequency identification (RFID) chips, the floor person is only estimating the patron’s buy in, how long the patron played and how much the patron won or lost. With online sites, you now have the ability to post in real time how long a patron has played, how much money has been wagered and how much the patron either won or lost. Limits can be preset for individual patron loss, maximum time limits for play, etc. – none of which can be easily controlled at your local casino. If someone wants to self-exclude (prevent oneself from playing on a particular gaming site), the process can be automated for the player. This is not an easy task at a brick-and-mortar property, where you have to visit either that casino’s gaming commission or other regulatory department. This process can be embarrassing or intimidating but is not the case online. You can easily exclude yourself for a day, week, month, year or permanently. I would have thought that after two years I’d have a grasp on the ins and outs of online gaming. Well, two years have passed and I am still learning. And one point is very clear: my education is only just beginning. .................................... Frank Pracukowski is the director of administration for Foxwoods Development Company (FDC), where he is responsible for coordinating the daily activities and operational support for various FDC projects. He also serves as the primary liaison between FDC and essential Foxwoods Resort Casino and Mashantucket Pequot Tribal Nation departments. Foxwoods is the world’s second-largest casino. Frank has nearly 20 years of development, management and operations experience in the IT arena, and currently co-leads the strategic effort for Mashantucket Pequot Tribal Nation’s online gaming operations initiative. Frank Pracukowski may be reached at [email protected] COVER STORY An Internet gambling present from the U.S. Dept. of Justice By I. Nelson Rose T he United States Department of Justice (DOJ) has given the online gaming community a big, big present, made public two days before Christmas. President Barack Obama’s administration has just declared that the major federal antigambling statute, the Wire Act, applies only to bets on sports events and races. This is also a gift to the states, which are desperate to find ways to raise revenue without raising taxes. In fact, Nevada and the District of Columbia have already passed laws authorizing most forms of Internet gambling. The two jurisdictions are now free to start their online games immediately. They can even enter into agreements to allow operators in Las Vegas to accept players from Washington, and vice versa. The opinion requires that the gambling be legal under state laws. It will take some time for legislatures to react. But many of the state lotteries can set up online games quickly. They will start with Internet variations of the lotteries they already sell with paper tickets and in-store computer terminals. But some will follow the lead of government lotteries in Canada and elsewhere and set up online poker and casino games. The political fights will be over who gets the licenses. In D.C., the operator is the Lottery. In Nevada, where there is no state lottery, the licenses will naturally go to the privately owned casinos. But what happens in a state like California? The politicians will legalize Internet poker solely to raise revenue, not to protect the local operators. Giving the exclusive right to Internet games to the State Lottery might bring in more money in the long run, but the state is desperate for cash, now. Only outside companies, like Caesars Entertainment, can come up with the $100 million or so the state will want, up front. But California has long-established and politically powerful card clubs and Indian casinos. They will not quietly accept an outsider setting up a competing operation that brings legal gambling into every home in the state. Still, there is so much money at stake that political deals will be made. In states like Nevada and New Jersey, where the local operators are the big money, the land-based casino companies will get the Internet gambling licenses. In states like California, local operators will get a license or two, but others will also be sold to the highest bidders. “ The opinion requires that the gambling be legal under state laws. It will take some time for legislatures to react. But many of the state lotteries can set up online games quickly.” The great irony is that this coming explosion of legal Internet gambling in the U.S. was created by a conservative Republican attempting to outlaw online gaming. When the GOP controlled Congress and George W. Bush was President, Bill Frist (R-Tenn.), then majority leader of the U.S. Senate, rammed through the Unlawful Internet Gambling Enforcement Act by attaching it to a must-pass anti-terrorist bill. Frist did such a terrible job of writing the UIGEA that he accidentally opened the door to many forms of online gaming, An Internet gambling present from the U.S. Dept. of Justice including fantasy sports, skill games and intrastate gambling. It was the last that led to the announcement by the DOJ. The UIGEA expressly allows states to authorize gambling when the bettor and operator are in that state. And it says to ignore the fact that communication wires might cross into another state. But the DOJ had always taken the position that the Wire Act outlawed all forms of gambling, and that this federal law applied so long as the gambling information crossed, even temporarily, into another state. The state lotteries of Illinois and New York asked the DOJ whether they could take lottery bets online, even though some of the payment processing took place in other states. And after the District of Columbia announced it had authorized online poker and other games, the current majority leader of the Senate, Harry Reid (D-Nev.), and the second most powerful Senate Republican, Jon Kyl (R-Ariz.), sent a letter, demanding that the DOJ do something about Internet gambling. The DOJ decided the only way out of its legal mess was to reinterpret the Wire Act. If this statute applied only to sports bets, then it wouldn’t matter if phone lines happened to carry lottery or poker bets into and out of other states. The conclusion by the DOJ that the Wire Act’s “prohibitions relate solely to sportrelated gambling activities in interstate and foreign commerce” eliminates one of the only federal anti-gambling laws that could apply to gaming that is legal under state laws. There simply are no other federal statutes that would make Internet poker and casino games illegal, even if the operators are in one state and the players in another, so long as the games are legal under the laws of those states. In fact, there is now no reason for states to limit their online gambling to residents of the United States. The Wire Act and the 25 anti-lottery laws are the only federal antigambling laws that can apply to legal games. Every other federal anti-gambling statute is designed to go after organized crime. These laws are all written as applying only to illegal gambling. Any state that wants to can now authorize Internet gambling and allow operators to take bets from residents of that state and of other states and nations that have also legalized online gaming. Questions remain. The Wire Act still applies to bets on horse races. In December 2000, Congress amended the Interstate Horseracing Act to expressly allow the states to decide for themselves whether their residents can make bets on horse races by phone and computer. More than half the states have passed laws allowing this remote betting, called Advanced Deposit Wagering, including across state lines. But the DOJ’s official position is still that the ADW operator and the bettor have to be in the same state. No one else, including the World Trade Organization, agrees with the DOJ. And payment processors have to figure out who is right. Another federal statute, the Professional and Amateur Sports Protection Act, grandfathers-in Nevada, Delaware and a half-dozen other states, while prohibiting any other state from legalizing sports betting. This is now being challenged in the courts, because New Jersey voters approved sports betting in November 2011. What impact will all this have on proposed federal laws? Proponents are trying to spin the DOJ opinion. The Poker Players Alliance stated, “However, this ruling makes it even more important that Congress act now to clarify federal law, and to create a licensing and regulation regime for Internet poker, coupled with clear laws and strong enforcement against other forms of gambling deemed to be illegal.” But the reality is that Congressional advocates, like Rep. Barney Frank (D-Mass.) and Rep. Joe Barton (R-Tex.), have had some of the wind knocked out of their sails. Since states are now clearly free to legalize intrastate online poker, and perhaps even interstate, there is not much reason to even bother with a federal law. It might be a good idea to have one unified law. But the success of all the gambling now licensed or operated solely by states and tribes shows that consistency is not essential. Only the major operators, like Caesars Entertainment, need an overriding federal law, because they don’t want to be competing with politically connected local gaming companies for limited numbers of licenses in 50 states. Opponents, like Kyl and Rep. Frank Wolf (R-Va.), might get some leverage for their attempts to expand the Wire Act to cover all forms of gambling. But, as I have pointed out (to the ire of some who have given money to politicians and lobbyists), Congress has passed literally no substantive laws since the Republicans took over the House of Representatives in January 2011. There is as little chance of this Congress passing a new prohibition as there is of it passing a repeal of the UIGEA. So, while Congress continues to do nothing, Internet gambling is about to explode across the nation, made legal under state laws. In 1962, there were no legal state lotteries in the U.S. It took more than 40 years before almost all the states made lotteries legal. Internet years are like “dog years.” Developments now happen so fast that it won’t take four decades before Internet gambling is legal in almost every state. .................................... I. Nelson Rose is one of the world’s leading experts in online gaming law. He is often called upon to testify as an expert witness or act as a consultant on legal gambling. You can read more articles by Rose at rose.casinocitytimes.com and GamblingAndTheLaw.com. © Copyright 2012, All rights reserved. Gambling and the Law® is a registered trademark of Professor I. Nelson Rose, www.gamblingandthelaw.com/blog.html. Department of Justice building in Washington. Photo of by Coolcaesar, licensed under GNU Free Documentation and Creative Commons Attribution ShareAlike 3.0 “ While Congress continues to do nothing, Internet gambling is about to explode across the nation, made legal under state laws.” COVER STORY Changes coming to the U.K. online gaming market Top legal experts in the U.K. preview tax and regulatory changes to Europe’s most important market 27 By Melanie Ellis, Harris Hagan I t is only just over four years since the U.K.’s Gambling Act 2005 came into force. But the U.K. is already considering regulatory changes to its thriving online gaming market. The fact that the government is already proposing to change its provisions in relation to online gambling is testament to how rapidly the gaming industry, and the way it is regulated, is changing. In the next few years we believe it is inevitable that online operators targeting the lucrative U.K. market will be forced to obtain a U.K. license, which comes with the key drawback of the requirement to pay 15 percent duty on gambling revenue from U.K. residents. While operators are likely to have a couple more years’ respite due to the need for Parliament to debate primary legislation to effect the change, they should prepare for this requirement to come into force in the medium term. The online market The 2005 Act introduced a regulatory regime for online gambling for the first time in the U.K., and the U.K. was one of the first jurisdictions to issue online licenses. Of course Internet gambling had been around for a decade already, but no one has ever accused the law of being ahead of its time. The U.K. is an attractive market for online gambling operators, with 11.9 percent of the population participating in some form of remote gambling. While remote gaming and betting duty at 15 percent of gross gambling yield combined with U.K. corporation taxes make the U.K. an unattractive home for online gambling operators, the fact that operators are permitted to target the U.K. from lowtax “white list” jurisdictions means it has been a lucrative market. The Gambling Commission estimates that 75 percent of remote gambling carried out by U.K. residents is with operators located overseas. Rather optimistically, the 2005 Act was intended to be a modern and flexible piece of legislation, if not completely future proofed. The legislation does allow for the regulation of new forms of gambling which were not envisaged at the time it was drafted, such as social media gaming, even though this does sometimes require careful legal interpretation. By introducing wide COVER STORY definitions of concepts such as “remote gambling” (any gambling by which persons participate by means of remote communication), “game of chance,” “betting” and “betting intermediary,” it is possible to license just about any gambling concept which can be envisaged, on any kind of remote platform, provided the Gambling Commission can be persuaded as to which license is appropriate and there are no regulatory concerns. What was not legislated for was the fact that the rest of Europe would not follow the U.K.’s lead in terms of the basis on which remote gambling is licensed and regulated. With hindsight, this was rather naive, as the U.K. is often at odds with the rest of Europe – unfortunately when it comes to online gambling, David Cameron does not have a veto to exercise! What has changed? In the last few years, European jurisdictions (notably Italy, France, Spain and Denmark) have begun introducing regimes for the licensing of online gambling on a “point of consumption” basis. At first this idea was controversial. Commentators argued that the European Treaty’s provisions on the free movement of goods and services meant that a gambling operator based in one jurisdiction should be entitled to allow customers throughout the European Economic Area to participate in its games, and to advertise to those customers as well. Indeed, this is the basis upon which the U.K.’s Gambling Act is currently drafted: operators based in EEA (and also selected “white list”) states are entitled to advertise their services in the U.K. The U.K. magnanimously acknowledges that it does not have a monopoly on good regulation. Further, there is no restriction on the jurisdictions from which operators may accept U.K. customers. However, European Court of Justice rulings and the results of infringement proceedings in the European Commission have led to the position that member states have discretion as to how they choose to regulate online gambling, and may legitimately introduce national licensing regimes where operators are required to obtain a local license in order to target the market. Fortunately, from an industry perspective, it is still not acceptable to maintain a state monopoly system unless this can be justified on public-interest grounds and gambling is restricted in a way that is consistent with these objectives. Given the U.K.’s failure to attract a single major online gaming operator and the substantial tax revenue which flows from a requirement to hold a local license, it is no surprise, at least from a political perspective, that the U.K. should now seek to amend its legislation to regulate gambling on the same basis as others in Europe. Regardless of the developments in Europe, it could be said that the Gambling Act 2005, as drafted, was doomed before it even came into force. As soon as the Treasury set the rate of gaming and betting duty at 15 percent, allied with an ability to target the U.K. from offshore, it became apparent to operators that to remain in the U.K. would put them at a disadvantage as compared to those based overseas. What changes are proposed? In April 2009, the government announced that it would explore ways to “level the playing field” for U.K. operators. One of the options proposed was to require overseas operators to contribute to the cost of regulating gambling in the U.K. When the review of the 2005 Act was first mooted over 18 months ago, it was unclear how a level playing field could be achieved without introducing some form of U.K. license requirement. By January 2010, proposals for a license requirement were announced and the government’s reasoning had evolved from enabling U.K. operators to be competitive, to protection of U.K. players. The government cited concerns as to the inconsistency of regulatory standards across Europe; indeed the Act allows operators based anywhere in the EEA to advertise in the U.K. even if there is no regulatory regime at all in their home jurisdiction. The consumer protection angle reflects the basis on which other European jurisdictions have introduced “point of consumption” licensing regimes and perhaps also makes the legislative changes more palatable to Parliament and the British public. Changes coming to the U.K. online gaming market The government’s stated reasons for proposing to switch to a “point of consumption” licensing regime do not relate to the projected tax revenues. This is unsurprising because the introduction of a new licensing regime to increase tax revenues would contravene EU law. However, the extent to which DCMS and Treasury are working in tandem on the proposed reforms is revealing. Following a consultation period, in July 2011 the government announced that the U.K. license requirement would definitely be introduced, although any indication of a timescale for the changes is still awaited. We now know that in the future all gambling operators advertising their services in the U.K. or contracting with U.K. customers will need a license from the U.K. Gambling Commission. Although the government does not propose to introduce enforcement measures such as ISP blocking, unless it proves necessary and the requisite technology improves, we anticipate that it will become almost impossible to advertise unlicensed gambling services in the U.K. The media will be aware that they may only accept advertisements from U.K.-licensed operators; otherwise they may be committing a criminal offense. It is probably true to say that the government is focusing on the low hanging fruit; the majority of U.K. bets are placed with large, reputable operators (many of them plcs) which will have no alternative but to comply with the law. John Penrose MP, the U.K.’s gambling minister, has recently reiterated the government’s intention to introduce these amendments to the 2005 Act. This indicates that momentum is building for these changes; however, primary legislation is required and (fortunately for the industry) the reality is that due to a lack of legislative time to debate the changes and hold further consultation, it is unlikely that the license requirement will come into force for at least another couple of years. What does this mean for operators? Taxation and license fees The obvious and perhaps most significant implication of the change will be that all Reach your goals FASTEST paying company in the business EXCELLENT back office reporting tool TOP level support from our affiliate team EXCLUSIVE affiliate promos PROFESSIONAL creative team GREAT conversion Photo: Toby Maudsley www.nordicbetpartners.com COVER STORY “ Given the U.K.’s failure to attract a single major online gaming operator . . . it is no surprise . . . that the U.K. should now seek to amend its legislation to regulate gambling on the same basis as others in Europe.” operators transacting with U.K. players will be required to pay U.K. remote betting or gaming duty at 15% of gross gambling yield. Operators envisaging moving their base from a zero or low gaming tax jurisdiction (such as Alderney, Gibraltar or the Isle of Man) will previously have been concerned about the fact that a U.K. license came with a requirement to pay the duty on all transactions conducted under that license, not just transactions with U.K. residents. However, some relief will have come with the recent announcement that the U.K. is moving to a “point of consumption” basis for taxing online gambling, as well as for licensing it. In other words, U.K. licensees will not have to pay gambling duty on bets placed by non-U.K. residents. The change to the basis for taxation will come into force in April 2012, so current U.K. licensees can begin enjoying this benefit almost immediately. As well as U.K. gaming duty, operators will need to budget for the annual licensing fees payable to the Gambling Commission. However, license fees in the U.K. are fairly reasonable compared to other jurisdictions, particularly for those operating on a smaller scale. For example, a license for casino games (including poker), where annual gambling revenues are between £550,000 and £5 million, is subject to an annual fee of around £9,500 per year. A license for remote fixed-odds betting on real events will cost around £13,500 per year, provided revenues do not exceed £5.5 million. In addition to remote betting duty, licensees accepting bets on horse races in the U.K. will also need to factor in the duty payable to the Horserace Betting Levy Board, at 10.75% of gambling yield. license application can be completed in under three months. Currently, it is not necessary for a U.K. license application to be made by a U.K. company. This does not necessarily mean that U.K. corporation tax (26% of profits) can be avoided; however, careful corporate structuring may be able to minimize the impact of this tax. Detailed consideration of this issue is, however, beyond the scope of this article! The Commission will adopt a bespoke, risk-based approach to online gambling regulation. Particularly when it comes to licensing those currently operating from reputable jurisdictions, this means that it has the flexibility to carry out a more or less rigorous investigation depending on the home jurisdiction, scale of operations and operating history of the applicant. The Commission will wish to avoid duplication of work already undertaken by the home regulator and will have considerable flexibility around the conditions to be imposed on licenses to achieve its objectives. Server location As the law stands, all U.K. licensees are required to locate at least one piece of remote gambling equipment in the U.K. The Gambling Commission tends to work from a starting point that all equipment will be in the U.K., but it does have discretion to allow equipment to be located overseas. It is unlikely to exercise this discretion unless the location in question is a well-regulated gambling jurisdiction where it can communicate with the local regulator and effectively monitor the equipment in question. No announcement has been made on this subject, but it may be that in amending the Gambling Act the government removes the requirement for any equipment to be located in the U.K. This would certainly make the transition to a U.K. license easier for companies with established operations overseas. It may also affect corporation tax considerations. Application process When the U.K. license requirement is introduced it is very likely that some form of transitional arrangements will be put in place for operators currently targeting the U.K. from EEA and white list jurisdictions. This will allow such operators to continue their U.K.-facing operations for a period, perhaps six months, pending full determination of their U.K. license application. Operators should be aware that a U.K. license application will entail a rigorous investigation by the Gambling Commission into the affairs and financial circumstances of the main shareholders in the applicant company, as well as companies further up the chain of ownership. Those in key management positions will also be subject to investigation. This process can take up to six months to complete for larger companies, although typically a U.K. Changes coming to the U.K. online gaming market How will the market change in practice? It appears unlikely that companies will relocate employees to the U.K., not least because there will be significant tax advantages to retaining as many ancillary services as possible overseas. Assuming that operators will be entitled to retain gambling servers overseas as well, the most significant differences to operators will be the requirement to pay U.K. license fees and gambling taxes and of course the fact that they will be regulated by the U.K. Gambling Commission. As all operators targeting the U.K. will be subject to these same costs, it may be that the impact of the change on the industry is less than anticipated. Ironically, it is likely to be the customers who most feel the impact, as additional costs to the operator means fewer bonuses and incentives will be able to be made available. We doubt the customer will see this as a price worth paying for questionably greater regulatory protection. ......................................... Melanie Ellis is a solicitor in the gambling law team at Harris Hagan. After graduating from St Hilda’s College, Oxford in 2003, she trained as a barrister before joining Harris Hagan in 2005 and qualifying as a solicitor in 2008. Melanie has developed expertise in all aspects of gambling law advising major casino operators, online betting and gaming operators and start-up companies. She regularly contributes to gaming law publications. Melanie enjoys skiing, rock climbing and competing in triathlons. COVER STORY Thanks for nothing Unless something changes soon, the EU’s online gambling “Green Paper” will be just another missed opportunity for the industry By Yehoshua Gurtler, Herzog Fox & Neeman, Israel F rom the onset of the online gambling industry, the European Union has deferred to local interests – often motivated by national protectionism or political values – and refrained from extending to that industry the full range of benefits offered by the European Internal Market. In the absence of a single EU regulatory regime governing online gambling, the industry continues to suffer from precisely those misfortunes that the European Internal Market was created to avert. Localized legislation often results in access barriers that have no substantive justification. Indeed, the fragmented regulation of online gambling has created various practical difficulties for operators committed to conducting a compliant business (for example, varying technical standards often require operators to develop tailored technical platforms for each regulated market, resulting not only in upfront costs but a serious ongoing development and maintenance burden). More troubling is the fact that several Member States regulating online gambling have lamentably done so in a manner not entirely consistent with the utopian Internal Market ideal of freemoving services, often for purely protectionist reasons (a notable recent example is the new German InterState Gambling Treaty, which, like its predecessor, has already been declared by the European Commission to be incompatible with EU law). Requirements including maintenance of local server infrastructure, establishment of a local corporation or subsidiary, reliance on local financial institutions, and ringfencing of player pools are all examples of various restrictions imposed by Member States through local gambling laws, in flagrant violation of the core principles of EU law. The mosaic-like regulation of online gambling by the various Member States has led to the basic principles of EU law governing commercial activity over the Internet being increasingly sidelined. Thanks for nothing COVER STORY Further exacerbating this undesirable situation, national courts, when implementing EU law (including ECJ case law) with regard to gambling, have taken varying approaches, contributing to the legal ambiguity regarding the legal standards applicable to online gambling within the Internal Market. The EU as an economic entity Notwithstanding its important cultural, social and demographic impact, the EU is first and foremost an economic entity. The European Internal Market, the pièce de résistance of the EU, aspired to create a borderless market for labor, goods, services and capital among the Member States. Indeed, the intricate mechanisms of the Internal Market make it quite possible for a Warsaw car dealer to sell motor vehicles built by Spanish laborers in a German plant owned by a Swedish manufacturer or for a restaurateur in Helsinki to indulge her patrons with premium cheeses produced by Portuguese farmers employed on a French dairy farm. With the advent of the Internet, the freedoms of the Internal Market were simultaneously extended to and challenged by the ever-growing, dynamic and infinitely diverse world of eCommerce. To ensure the implementation of this basic principle of the Internal Market, Article 59 instructs the governing institutions of the EU to issue appropriate directives. And Article 60 takes it a step further. “[T]he Member States shall endeavour to undertake the liberalisation of services beyond the extent required by the directives issued pursuant to Article 59(1), if their general economic situation and the situation of the economic sector concerned so permit,” the treaty reads. “ In an effort to enforce these treaty provisions, the European Parliament and Council enacted Directive 2000/31/EC “on certain legal aspects of information society services, in particular electronic commerce, in the Internal Market.” The purpose of the eCommerce Directive was to lay down a general legal framework governing eCommerce within the Internal Market and, specifically, to eliminate barriers to the free movement of goods and services offered in the virtual arena. However, though online gambling services fall squarely within the definition of “services” the directive sought to regulate, Article 1 of the directive explicitly carved out online gambling activities from the directive’s scope. As a result, to this day, the multi-billion Euro market of online gambling, which has grown in popularity, volume and variety in the decade since adoption of the directive, remains generally underregulated within the common legal framework of the European Internal Market. It is a lamentable reality that needs to change. Successful regulatory regimes can , generally, lead to a well-developed and attractive licensed market which consumers will usually favor The basic principles over unlicensed opergoverning the European Internal Market ations, and can also are set out in Title IV of the Treaty on – of course – generthe Functioning of the European Union. They Online gambling ate sizable revinclude, among other and the service issue things, the freedom of enue for state corporate establishment The eCommerce Directive rewithin all Member States as coffers.” flects the EU’s legal position that well as the freedom to provide services throughout the Union. Article 56 of the treaty (formerly Article 49) reinforces those basic principles by stating that “restrictions on freedom to provide services within the Union shall be prohibited in respect of nationals of Member States who are established in a Member State other than that of the person for whom the services are intended.” Thanks for nothing online gambling constitutes a “service” which (notwithstanding the explicit carve-out included in the directive) is to be governed by the EU law principles applicable to services, first and foremost – the free movement of services within the Internal Market. Indeed, the European Commission, on various occasions, affirmed its support for such recognition of online gambling as a “service” entitled to free movement within the Internal Market, through infringement measures against Member States whose laws were considered incompatible with this basic principle of EU law. In fact, the European Commission has, over the years, initiated infringement proceedings in this regard with Denmark, Finland, Germany, Hungary, Italy, The Netherlands, Sweden, Austria and France. The European Court of Justice has also repeatedly found that online gambling services do indeed fall within the definition of “services” in the context of EU law – specifically, within the scope of Article 56. But in cases like Piergiorgio Gambelli and Others, the ECJ noted that, unlike other types of services (including most forms of eCommerce), online gambling has not been the subject of legislative harmonization within the EU, and therefore Member States are legally entitled to enact local legislation regulating the field, as long as such legislation is compliant with the general principles of EU law. The result of this approach at the EU level is that while national legislation on this matter remains subject to numerous substantive requirements emanating from EU law, Member States have largely been left to their own devices with regard to the regulation of online gambling. In fact, over the past six years, a growing number of Member States have taken advantage of this gap and adopted legislation governing online gambling (examples include France, Italy, Spain, Denmark, Estonia, Greece and Romania). Similar developments are likely in other Member States in the foreseeable future. These legislative developments in Member States have, in some cases, been positive for the online gambling industry as previously unregulated markets liberalized their legal stance toward online gambling. Successful regulatory regimes can, generally, lead to a well-developed and attractive licensed market which consumers will usually favor over unlicensed operations, and can also – of course – generate sizable revenue for state coffers. It is the joint responsibility of Member States and of the EU’s governing institutions to ensure that the principles of the Internal Market are upheld. Given the repeated failure of some Member States to live up to that obligation, all eyes have been on the EU institutions, particularly the European Commission, with the hope that they would steer the regulation of online gambling in Europe in the right direction. 35 Showing its hand – the EU’s involvement in the regulation of online gambling – from enforcement to acquiescence Though the eCommerce Directive may have been the EU’s first missed opportunity to harmonize the regulation of online gambling it seemed, by the middle of the last decade, that the EU’s institutions were taking a more proactive role in ensuring that online gambling enjoyed the benefits bestowed by the EU Internal Market. In 20052006, the European Commission embarked on a review of the European Gambling market, conducted by the Swiss Institute of Comparative Law. Subsequently, the Commission initiated infringement proceedings against a list of Member States whose gambling legislation was found to be incompatible with EU law. These included Denmark, Finland, Germany, Hungary, Italy, The Netherlands, Austria and France. Indeed, such infringement proceedings had the positive effect of motivating several of these countries to adopt legislation regulating the online gambling market (notable examples include Italy, France and Denmark). More recently, through the mechanism established by EU Directives 98/34/EC and 98/48/ EC, requiring Member States to inform the European Commission and other Member States of any new legislation or regulation impacting various fields of commerce (including online gambling), the Commission (like some Member States) has been influential in shaping local legislation to encourage conformity with EU law standards. According to a 2011 EC document, since January 2005, and increasingly in the last three years, more than 150 pieces of legislation related to gambling have been notified to the European Commission, of which many pertain to online gambling. Similarly, the ECJ has played an important role in the struggle to secure conformity of local gambling legislation with the principles of EU law. Perhaps the most dominant examples are the ECJ’s September 2010 rulings in the German sports betting cases – Winner Wetten GmbH v. Burgermeisteren der Stadt Bergheim, Carmen Media Group Ltd. v. Land Schleswig-Holstein and Markus Stoss et al. v. Land Baden-Württemberg – which found that the German sports betting and lottery monopoly regime failed to systematically and coherently regulate the gambling industry, rendering it inconsistent with the principles of EU law. However, notwithstanding these important efforts and their generally positive impact on the evolving regulation of online gambling within EU Member States, they have contrib- uted very little to realization of the true ideal of the European Internal Market – namely the creation of a harmonized, uniform, borderless market for online gambling services. Signs of cautious optimism in this context came from the European Parliament, which in 2010 adopted a resolution on the integrity of online gambling, calling on Member States to take certain measures toward closer cooperation in the context of online gambling regulation. Similarly, the Council of the European Union, the EU’s primary lawmaking body, debated under various presidencies the need to harmonize online gambling regulation across the Internal Market. These debates culminated in the Council resolution adopted in December 2010 that recognized “[t]he cross border nature of the different issues [pertaining to online gambling] requires Member States to work more closely together . . . in order to address them.” It was against this backdrop that the gambling industry welcomed the announcement by the European Commission indicating its intention to launch a broad consultation (“Green Paper”) on online gambling in the European Internal Market. The hope was that the anticipated Green Paper would eventually pave the way for harmonization of EU gambling law, bringing online gambling in line with other forms of cross-border services. by the various Member States. Though the Green Paper speaks to the need for coherence between local legislation and EU law, and calls for “administrative cooperation” between Member States’ regulatory bodies, it also recognizes that “restrictions imposed to [sic] online gambling by each Member State can be expected to continue to vary considerably, with the effect that what is, or will become, considered a legal offer in one Member State will continue to be deemed ‘unlawful’ . . . in the territory of another Member State.” Mystifyingly, rather than criticizing the segregated approach to the provision of gambling services throughout the allegedly uniform Internal Market, the Green Paper goes on to expressly state that the Commission’s objective is “to contribute . . . to the emergence in the Member States of a legal framework for on-line gambling providing for greater legal certainty for all stakeholders” (emphasis added). Finally, the Commission states that the entire Green Paper process is “without prejudice to the wide margin of appreciation left to Member States as to their regulatory approach to this activity. . . . Member States remain free to determine their approach to this sector within the limits of the principles as set out by CJEU [ECJ, Y.G.] case law.” “ The enthusiasm with which the industry awaited the Green Paper waned with its All in all, the Green Paper is hardly a publication last March panacea to the exwhen it became patentisting potpourri of o ft -EU- law - in c omly clear that the scope patible gambling legislation adopted by of the Commission’s EU Member States. The enthusiasm with Another setback to consultation was which the industry awaitfull harmonization of ed the Green Paper waned the European online far more modwith its publication last gambling market came March when it became pain November from the est than some tently clear that the scope of European Parliament. The the Commission’s consultation had hoped.” Parliament adopted a muchwas far more modest than some had hoped. Though the Commission was careful to state that the consultation was not prejudiced toward any particular outcome, the manner in which the Commission framed the consultation clearly indicates that, far from advocating harmonization of gambling regulation across the Internal Market, the Green Paper embodies the Commission’s tacit acquiescence to the fragmented regulatory model evolving through local legislation curtailed, non-legislative resolution following the report prepared by German MEP Jürgen Creutzmann in connection with the Green Paper consultation process. While the resolution calls for an EU Directive in the field of online gambling, noting the added value to be achieved through a coordinated approach to the regulation of this industry, it also “rejects . . . any European legislative act uniformly regulating the entire gambling market.” COVER STORY By apparently succumbing to the increasingly common “local regulation” model, rather than advocating harmonization and standardization of what is an inherently crossborder industry, the governing institutions of the EU once again missed the opportunity to have a positive impact on the evergrowing online gambling market in Europe. Going for the jackpot – the benefits of a harmonized approach to the regulation of online gambling across the EU In his speech before the European Parliament in November 2011, Michel Barnier, European Commissioner for Internal Market and Services (and the man behind the Green Paper), announced his intention to publish an “EU online gambling action plan” by mid-2012. Potentially, this could take the form of a White Paper advocating EU legislation to govern certain aspects of the regulation of online gambling. Realistically, against the backdrop of the Green Paper and of the Creutzmann report, it seems safe to assume that any call for action from the European Commission on this issue will be a far cry from full harmonization of the regulatory framework applicable to online gambling. That is unfortunate, as harmonization of the normative framework applicable to online gambling will ultimately contribute to growth of the regulated industry, to player confidence in the integrity of the industry and to eradication of the “black market” of online gambling services. Fragmented regulation of the online gambling industry unavoidably results in soaring compliance costs for operators, regulatory redundancy (both for operators and for regulatory authorities), and a loss of “economy of scale” advantages. Furthermore, subjecting operators and consumers domiciled in different Member States to disparate legal frameworks with regard to identical services (often to advance protectionist ends), is a form of commercial discrimination entirely foreign to the most basic principles of EU law. Conversely, regulatory uniformity and cross-border cooperation between and among Member States’ authorities will ultimately allow licensed operators to offer consumers throughout the EU the best product at the lowest price and under similar conditions, embodying the core objectives of the EU Internal Market. There are concrete areas in which practical benefits may be achieved through harmonization: • Player protection – pan-European regulation will give both operators and regulators better practical tools to combat the risks of fraud and money laundering and to prevent the abuse of online gambling platforms by criminal elements. Operators will also be subject to uniform standards of player pro- 37 tection. Together, these will contribute to consumer confidence and make the regulated online gambling market a safer and more attractive one. • Prevention of problem and underage gambling – the identification and treatment of problem gamblers, as well as the exclusion of minors and other vulnerable groups, would benefit immensely from harmonization. It would make it easier for operators to identify and handle those for whom gambling is unsafe or unhealthy (e.g., through the creation of pan-European exclusion lists, or age verification databases) and will also make it more difficult for those who should not be gambling to circumvent the barriers put in place to prevent them from doing so. • Regulatory oversight and control – uniform regulatory standards (e.g., technical standards, internal control standards, reporting and auditing standards, customer verification standards, etc.), along with the sharing of information between and among Member States’ authorities, will allow for far more efficient regulatory oversight by the latter, thereby reducing costs and contributing to the trustworthiness of the industry. For example, regulators across Europe could rely on each other to oversee the integrity of technical infrastructure located in other Member States, removing the need for duplicate IT deployments. • Liquidity – allowing operators to pool players throughout the EU is not only commensurate with the principles of the EU Internal Market, it also allows operators to offer players far more attractive products (e.g., large player pools for poker tournaments, larger jackpots and more attractive pricing schemes, etc.). • Marketing – the disparate regulatory regimes adopted by EU Member States create immense practical difficulties for operators and media outlets alike, given the increasingly cross-border nature of electronic and print media in the EU. Harmonization would subject operators and the various media to similar standards with regard to marketing of online gambling services. It would also contribute, inadvertently, to mitigating the prevalence of problem gambling by imposing socially responsible advertising standards. • Payment processing – a uniform regulatory landscape will allow European financial institutions to provide payment processing services to online gambling operators across the EU, without legal hindrance or uncertainty and at significantly lower costs. • Revenue collection – the creation of a uniform regulatory regime for online gambling and a single European market for online gambling services lends itself to streamlined collection of revenue by the treasuries of the Member States, while subjecting operators to a uniform tax structure and reporting requirements. Furthermore, a uniform tax regime will help alleviate the unfair double taxation situations some opera- tors are exposed to under the present array of disparate regulatory frameworks. Finally, the inevitable growth of a uniformly regulated market will lead to increased tax revenue for Member States’ treasuries. Harmonization may well require some Member States to accede to a regulatory model that may not entirely reflect their traditional values in relation to gambling, and this will be a challenge for EU legislators to overcome. It may require some creativity in shaping the particulars of a pan-European normative framework for this industry. However, it would hardly be the first time the EU adopted legislation in socially sensitive areas, nor would it be the first time Member States parted with parochial values to promote the single-market ideal. A growing number of European jurisdictions regulate the online gambling industry through local legislation. Already, we are witnessing the emergence of ad hoc cooperation between European regulatory authorities (the MOU signed recently between the regulatory authorities of Italy and France is one example and Denmark’s bilateral agreements with prominent European regulators are another). It stands to reason that as more and more Member States regulate their domestic online gambling markets, such cooperation will intensify, as authorities realize the benefits to be gleaned from joining forces. These benefits, some of which have been listed above, can easily be magnified through full harmonization of the European law of online gambling. As the dominoes of regulation fall around the European Union, the window of opportunity for pan-European harmonization is rapidly closing. Though the eleventh hour is upon us, it is not yet too late. With appropriate determination, the Green Paper could reignite the optimism of those hoping for a truly European online gambling market. Without it, the Green Paper will become just another missed opportunity. ......................................... Yehoshua Gurtler is a partner in Herzog Fox & Neeman’s gaming practice, where he heads the regulatory and licensing team. Yehoshua advises clients on a range of issues related to the law of online gaming, concentrating primarily on matters pertaining to licensing, regulation, lobbying and litigation. In addition, Yehoshua advises clients on the regulation and licensing of other forms of eCommerce, with a specific focus on online currency trading, binary options, etc. This article does not constitute legal advice. Thanks for nothing THE 2012 GPWA SURVEY Our second annual survey yielded some surprising information, including some major shifts in how GPWA affiliates make money, surf the web and use their phones. Check out the results of a few questions from our survey here, and check the GPWA forums for more interesting results! A riotous lot! Mobile awareness grows Nearly a quarter of our respondents have been “in or around a riot,” with more than 20 percent saying they have inhaled pepper spray or tear gas (including GPWA Executive Director Michael Corfman; to learn more about his exploits, visit the GPWA forums: http://gpwa.org/248). More than a quarter of respondents said that at least 5 percent of their traffic comes from mobile devices, and nearly two-thirds either have sites optimized for mobile browsers or plan to work on it this year. Yes No Have you ever been in or around a riot? 24.5% 75.5% Have you ever inhaled pepper spray or tear gas? 20.6% 79.4% On average, what percentage of traffic on your sites comes from mobile devices? 0-1 percent 0-4 percent 5-7 percent 8-10 percent 11-15 percent More than 15 percent I’m not sure 25.5% 20.9% 14.5% 6.4% 2.7% 2.7% 27.3% Positive outlook proves prophetic Last year, our survey respondents had a positive outlook, with 74 percent saying 2011 would be better than 2010. And it turns out that 2011 was better than 2010 for most of those who could compare revenue year-over-year, (63.9 percent to be exact), with another 10.8 percent saying revenue was generally flat for them. Revenue change Do you offer a mobile-optimized version of your site(s)? Percentage Grew more than 50% 25.3% Grew 31%-50% 13.3% Grew 21%-30% 10.8% Grew 5%-20% 14.5% Stayed +/- 5% 10.8% Shrank 5%-20% 8.4% Shrank 21%-30% 2.4% Shrank 31%-50% 8.4% Shrank more than 50% 6.0% 8.1% 27.9% 28.8% 35.1% Casino, sportsbook growing; poker shrinking Compared to last year, casino and sportsbook revenue generated a larger portion of revenues for survey respondents, with each growing by 6 percent, while nearly 10 percent fewer respondents said poker was their largest source of affiliate revenue. This year, our respondents once again have a positive outlook on the future, with 51 percent saying it will be their best year in the business to date, and another 26 percent saying it will be better than 2011, though not their best year. What do you expect to see in terms of your revenue in 2012? It will be my best year so far 51.0% Better than 2011, but not my best year 26.0% About the same as 2011 16.0% Worse than 2011, but not my worst year 6.0% It will be my worst year in this industry 1.0% What sector of the online gambling industry accounts for the largest portion of your revenue? 4.5 4 Bingo Casino 49.4 15.5 Poker Sportsbook 16.7 55.5 25.3 22.7 2011 1.8 4.6 Other 0 The 2012 GPWA Survey All of my sites are optimized for mobile browsers Some of my sites are optimized for mobile browsers My site(s) are not optimized for mobile browsers, but mobile optimization is on my “to-do” list for 2012 My site(s) are not optimized for mobile browsers and I do not plan to work on it in 2012 2010 10 20 30 40 50 60 41 Black Friday had a neutral impact for most Extremely negative impact Affiliates have the life when it comes to their commute Nearly two-thirds of the affiliates who filled out our survey work from home, while approximately the same percentage of affiliate managers have daily commutes of 30 minutes or more. 17.2% Moderately negative impact 15.2% Slightly negative impact 11.1% How long is your commute? No/neutral impact 48.5% Slightly positive impact Moderately positive impact Extremely positive impact Affiliates Affiliate Managers I work from home 64.8% 20.0% 3.0% Less than 15 minutes 15.9% 6.7% 3.0% 15-29 minutes 11.4% 6.7% 2.0% 30-44 minutes 9.1% 46.7% 45-59 minutes 2.3% 13.3% An hour or more 1.1% 6.7% Gauging your use of technology Smartphone use is on the rise! Last year, 58 percent of our respondents had smartphones. This year, that population has ballooned to a whopping 76 percent. Do you own a smartphone? 2011 2010 No 24% Yes 58.2% Yes 76% No 41.8% Google Chrome more than doubled its devotees in 2011, while Internet Explorer fell from second to third behind Chrome. Mozilla Firefox had the exact same share in our poll this year as last year, with 52.4 percent preferring it over other options. Opinions on ringfencing customer deposits vary Affiliates and affiliate managers have very different views about whether operators should be required to hold customer deposits in separate accounts. More than three-quarters of affiliates believe they should, while less than 40 percent of affiliate managers agree. Should operators be required to hold customer deposits in separate accounts and not use any portion of those funds to pay for operations? What’s your preferred browser? 2011 Google Chrome 31.4 15.7 10.5 Internet Explorer 2010 25.9 52.4 52.4 Mozilla Firefox Sarfari 1.9 3.8 Other 3.8 2.2 0 10 20 30 40 50 The Prime Directive loses out to The Force in our pop culture wars The GPWA editorial staff (particularly vinism and GPWA_Aaron) are disappointed to learn that they are on the losing end of the Star Wars vs. Star Trek debate, with respondents preferring Star Wars by a 2-1 margin. But we’re sure that egomaniacs Simon Cowell and Piers Morgan will be shocked to learn they couldn’t beat “Who?” in our survey. Simon Cowell or Piers Morgan? 77.5 38.9 Yes 57.1 Simon Cowell 35% Piers Morgan 15% Who? 50% 27 No 61.1 42.9 0 20 40 60 Affilate Affiliate Manager Both 80 60 Star Trek or Star Wars? 100 Star Trek 33% Star Wars 67% Five tips for choosing new poker affiliate programs to work with in 2012 By Jeremy Enke T here is no question that 2011 was one of the most turbulent years the poker affiliate industry has ever seen. On April 15, 2011, the landscape of online poker within the United States forever changed. And although Black Friday specifically rocked the U.S. poker market, the fallout for affiliates has been global. Until Black Friday, the U.S. poker market was undoubtedly the most lucrative market for poker affiliates to promote within. Since Black Friday and the sudden exit of the four largest U.S.facing poker sites, many affiliates have been left looking for new operators to work with. T ip 1 # Industry Trust p, trust is extremely In any business relationshi lly important in the important. Trust is especia where there have been ry, ust ind gambling affiliate rs of both rogue countless stories over the yea es. companies and rogue affiliat trustworthiness of The best way to establish the do your own due to is m a poker affiliate progra the program is at wh on rely not diligence and ory of the affiliate telling you. Research the hist and any other past ers nag program, the affiliate ma best way to learn information you can find. The ual affiliate program is about the history of an individ est affiliate forums. larg by searching the industry’s question is new to the In the event the program in n more cautious when eve be to industry, you’ll need and especially one that entering into an agreement, model. This is not to is set with a revenue-sharing be trusted, because not can say that new programs approach any deal with many can; you’ll just need to skepticism. a greater degree of caution and Five tips for choosing new poker affiliate programs While 2011 was plagued with uncertainty and disappointment, we are all crossing our fingers that 2012 will be a year filled with excitement and new opportunity. New opportunities often come in the form of new programs to work with, and there are a few important factors to consider when choosing new programs to promote. What may be an exceptionally great program for one affiliate could perform terribly for another. While there are no guarantees in this industry, you may be able give yourself a better chance of success in the coming new year by examining the following aspects of potential new affiliate programs you are considering working with. “While 2011 was plagued with uncertainty and disappointment, we are all crossing our fingers that 2012 will be a year filled with excitement and new opportunity.” T ip 2 # Affiliate Manager & Communications When exploring new po ker affiliate programs to work with, the quality of the affiliate manager should make a significan t difference in your fin al decision to promote or not to promote. In the poker affiliate industry, the affiliate managers are often our only contact with the operators. A good affiliate manager is one who has a solid reputation among oth er affiliates, and one wit h whom it is easy to com municate. If I e-mail a potential affiliate mana ger about working tog ether and do not hear back for several days, he or she has already lost my bu siness. Before you cho ose to dive in head first wit h a new poker affiliate program, I strongly ad vise you to have severa l conversations together, and begin building tru st and rapport before ref erring new players. 43 T ip 3 # Terms & ns Conditio g the at checkin seemed th ing up for it n s g y si a d n box whe In the old s” n io re than it d d con othing mo ment, n s a w “terms an m ra on liate prog liate envir a new affi current affi ant to e rt th o p In . im a formality as never been more y are t re tha the it h however, s and ensu C & T e th gh l. read throu our business mode to y le b ra o v fa will shut programs te a li ffi a nt any new ple, some have not se stance, u o For exam y if n w is in unt do time. In th l your acco period of a ring mode a r e h v -s o e u rs n e v re playe a n many to work o Likewise, s choosing decision. e notoriou r o m o p co e a b e e v a h t u ry o would b ust ith in the ind nditions w programs rms and co ding through te ir e th g a in e re for chang ates. Whil nding their affili y understa ll fu , e m notifying o rs eadaches e h b f m o be cu ou a lot y e v sa T&Cs can y ll potentia . them could ons down the road si is m m co d n a T ip 5 # Future Outlook Do you have a crystal ball? I sure don’t. Howe ver, it’s still important to exa mine how affiliate programs are position ing themselves for future legislation or changes. For current U.S.-facin g poker sites, it’s really a gamble as to what the ir status will be should the U.S. laws change. This is one of the reasons tha t many of the top produ cing affiliates prefer CPA pla ns versus revenue sha ring for U.S.-facing operator s. If you’re diversifying ou tside the U.S. market, there are several excitin g acquisitions and partnerships that should be considered. Some operators are currently positioning themselves very strategically to ree nter the U.S. market should legislation be pa ssed. These affiliate programs are ones tha t would be worth giving serious consideration to working with if you are not already. T ip 4 # Payment Processing Payment processin g success rates and times vary among operator s and can change qu ite often. However, it sh ould be a considera tion when looking at ne w affiliate programs to promote. After all, if your referred pla yers cannot successfully deposit and withdraw, the program may be a waste of yo ur time. Likewise, it may also mean that your affi liate commission pa yments could be delayed. One of the best ways to learn the status of a poker room’s paym ent processing is to visit a few of the popular players’ forums. Fo r affiliate payment processin g times, there is alm ost always a monthly th read running on th e larger affiliate forums wh ere affiliates post wh en their commission paymen ts are processed. It’ s also never a bad idea to test drive the poker site yourself by trying to deposit and withdr aw on your own. Don’t put all your eggs in one basket! The more you can diversify your promotions and the number of poker rooms you work with, the more stable your month-to-month affiliate commissions will be. As the industry continues to experience high levels of uncertainty, it will be imperative for poker affiliates to be much more selective when choosing new operators to work with. There is no right or wrong answer as to what the “best poker affiliate program” is for every affiliate. Just as we split test our sites to see which banners, links and campaigns yield the highest conversion rates, we need to test out different poker rooms and promotions to see which ones bring the best results and player values. When trying out new operators and affiliate programs, it is important that a level of trust be established between the affiliate and operator from the outset. Affiliates need to be confident that they will be paid on time and that the poker site is a viable brand with a long-term strategy. And while there are many ways to research affiliate programs before signing up and sending traffic, one of the best ways is to reach out to fellow affiliates already working with the operator and learn from their previous and current experiences. The new year promises to be an exciting one in the poker affiliate industry. Many operators are strategically positioning themselves for success, and many affiliates are as well. Nobody knows exactly what the poker affiliate landscape will look like a year from now, but one thing is certain: those affiliates who are planning ahead, diversifying and selecting the right operators to partner with are the affiliates who will experience the greatest success in 2012 and beyond. Jeremy Enke is the CEO of Poker Affiliate Listings (PokerAffiliateListings.com). 44 Adding tournaments to your arsenal is good for business By Jason “Wolf” Rosenberg and Claire Wellard S ince the Unlawful Internet Gambling Enforcement Act passed in 2006, and now Black Friday in 2011, the entire online poker industry has been hit quite hard. With the current downward spiral of the general economy and local legislation changing faster than a runway fashion model changes clothes, some serious hurdles have been placed in front of us. It seems, by the minute, the game of poker is all that more competitive. No more so, than for affiliates trying to earn a living. As a result of Tier 1 operators shutting down or restricting U.S. players, legislation complications around the world and the reduction of the general population’s disposable income, we have been left with a somewhat limited number of available players to promote to. As affiliates, our efforts to acquire, convert and retain these players have just reached a whole new level of competitiveness. Simple banner farms can no longer compete. The heart of the average rakeback site, thriving in 2007, is struggling to beat at a sustainable level. Some affiliates have been left feeling like they came to school totally unprepared for the big test, not knowing what the answers are. Many affiliates feel like cockroaches scurrying for cover because a light has been turned on. Unfortunately, we have already seen many affiliates go out of business because they were unable to adapt to recent and ongoing changes in the iGaming landscape. Today’s affiliates are savvy business people who are doing everything they can to increase and retain traffic. By now, we all should know the importance of SEO, but there are other factors at play. Players demand more from their affiliates. They want exclusive news, information, strategy articles, promotions and advice. You name it, they want it, and it’s up to the affiliates to provide all of this. At the end of the day, the most important thing an affiliate can provide to players is the perception of value. What do you do that will differentiate yourself from other affiliates? Are you promoting the same thing everyone else is? Every operator offers deposit bonuses. Every operator has big money guaranteed tournaments. Affiliates can promote the same old thing, and maybe make a living, but what happens when you give players something that they can’t get anywhere else? They come, click on your affiliate links, keep playing and actually want to get your newsletters to see what’s next. One important tool that affiliates offer players is private tournaments. This strategy is not new, but many have overlooked its potential, especially in the current online gaming landscape. The following strategy works for all sectors of gaming, not just poker. There are four main reasons why private tournaments increase your traffic and your overall revenue. The first reason to develop a private tournament strategy is for increased player acquisition. Hosting a private tournament gives your players a reason to click on a link and create an account. The days of affiliates commanding massive private freerolls are over, but small private freerolls will result in new sign-ups. Your existing traffic and new players that are coming to your site may or may not deposit, but they may very well see a different offer that piques their interest. Bottom line: You now have higher traffic rates and a larger database of players to work with. Adding tournaments to your arsenal is good for business The second reason for a private tournament strategy is increased conversion of depositing players. Trust us, nothing impresses an affiliate manager more than the “C” word. Hosting a buy-in tournament with an added cash prize offers instant value to players. It is something extra that they are not getting on their own from very many operators. Again, this type of private tournament gives new and existing players in your database a valueadded reason to click on your bright and shiny affiliate link, set up a player account and then take that first stab at depositing. Bottom line: You now have revenue being generated from new and reactivated depositors, and your affiliate manager is able to discuss additional prize pools and better pay rates for you. “ 45 What happens when you give players something that they can’t get anywhere else? They come, click on your affiliate links, keep playing and actually want to get your newsletters to see what’s next.” ties started this way, and private tournaments are still a great way to get players to an affiliate site on a very regular basis. Bottom line: private tournaments create loyalty and keep players coming back to your site, where they are exposed to all of your offers. Just like Charlie Sheen, you’re winning! The third reason for your new faith in developing a private tournament strategy is increased player retention. Often you will find that you send players to an operator, only for them to become inactive and stop playing with that poker room, or they move somewhere else where they may not be tagged to you. The worst case is that they just stop playing altogether. Some affiliates argue that retention is the job of the operator and that an affiliate’s job is simply to get players to come to the operator. Here is a thought every affiliate should have: “If I can retain my players on any given operator’s site, how much more do I make through rev share or increased CPA rates?” Hosting private tournaments is one of the best ways an affiliate can keep players actively playing on any given operator, especially if those private tournaments are in the form of a series or league. Bottom line: Increased retention ultimately means more affiliate revenue. The fourth reason for developing a private tournament strategy is for increased loyalty. This is different from retention, and we’ll explain. Retention is when your players keep playing on any given operator’s site. Loyalty is when they keep coming back to your site to see what’s going to happen next. This is a simple but often overlooked concept. If you can consistently provide a sense of value for your players, why would they not come back over and over? Many top gaming communi- So you have identified the need for some private tournaments. What’s next? There are a few options that we will explore. The most obvious one is to speak to the affiliate managers and request some private tournaments. Simple, right? You have the site, you have some traffic and you want to perform better for the operator. Unfortunately in the real world, sometimes this just isn’t enough. Operators have fairly strict rules and guidelines when giving away private tournaments. After all, they are looking for ROI and are most likely held accountable for the results they bring in from the affiliates they work with. Every cent of money or every promotional item they give away comes with a calculated and well thought out approach. Long gone are the days of operators throwing money around and hoping it sticks somewhere. For those of you who have recently approached operators requesting a private 46 tournament, the response you got might have looked like one of those horrid forms you fill out when you are a new patient at the doctor’s office. They probably asked for some of the following information: • How are you going to promote this tournament? • How many depositing players do you have? • How many players do you estimate to bring into the tournament? • What is your monthly rake across the operators you work with? • What countries do your players come from? • Do you or any member of your family have a history of mental illness? (Okay, kidding about this one.) These are just a few of the questions that you will be asked to provide information on. Depending on your answers, you may or may not get that golden e-mail, telling you, “Yes, Dear Affiliate, we would love to pay for a private tournament for your players.” You see, your players may not be from the right country for that specific operator, or you have never advertised a tournament before so you aren’t able to give any estimation on how many players you can bring to the tables. You might not have a large enough database of players to warrant the operator taking a chance on you, or your site might not have a big enough traffic rating. These are all obstacles that can get in the way of your holding a private tournament that the operator pays for. If an operator declines your request for a fully funded private tournament, he or she might offer you a tournament if you share the risk; i.e., you pay for half of the prize pool up front or with your affiliate earnings. This lowers the risk for operators and gives them the security that you are serious about the business and willing to work with them long term. Sometimes, this will pay off and open many doors for you with operators. You get a proven track record, can see what works on your site (hopefully you never have to find out the hard way what doesn’t) and keep the players loyal to your site and to the operator. This is risky, but sometimes you can do quite well in the end. Some operators will go a step further and withhold affiliate earnings until you have brought a certain number of depositors. This is a tough agreement to make. On one hand, you will get a private tournament for your site, but you most likely will not make any affiliate revenue for some time. Personally, this option feels a bit more like being tied to organized crime than a business partnership with mutual benefits. So, you finally have your private tournament approved. Now what? The keys to success are often in the details. It is imperative to work with your affiliate manager, fill out a tournament request form, and make sure you are both on the same page. Be sure you have plenty of time for proper promotion, to write and send newsletters, and post on your site and on social media outlets. Make sure the gerbil that runs your ISP is healthy, and that you have plenty of coffee on hand, because you will also have to provide some type of customer service to your database at some point. There are a ton of logistical variables that can go wrong, many of which may be out of your control. This seems like a bit of work, and it truly is. It is hard to get decent private tournament prizes provided for you, and the follow-through required on your end can easily become a part-time job if you want to run several tournaments per month. Don’t let these obstacles stop you. There are a few solutions that are available for affiliates who want to use private tournaments as part of their marketing and revenue strategy. If you’re having trouble obtaining big money private tournaments that will motivate your players, a second option worth exploring is working with companies like Global Gaming Events. This company takes care of all of the hassle. GGE sets up private tournaments with operators and affiliates use their own tracking links from these operators to promote the events. Affiliates therefore keep 100 percent of any revenue generated by their players. GGE’s most popular brand of tournament, Online Forum Challenge, awards the players with added prize pools, and also rewards the best performing communities with private events of their very own. This bolsters the sense of community on the affiliate sites that participate. In addition to poker, GGE is now offering private tournaments for affiliates to promote various casino games, with more variations being offered all the time. There are other options for getting private tournaments, but they are much tougher nuts to crack. There are a few affiliate sites out there that provide private tournaments, but you have to send your players to sites that have someone else’s tracking links. Often, in order for your players to Adding tournaments to your arsenal is good for business “ Operators have fairly strict rules and guidelines when giving away private tournaments. After all, they are looking for ROI and are most likely held accountable for the results they bring in from the affiliates they work with.” be eligible for these third-party tournaments, your players are required to use their links, not your own. You are then at the mercy of proper and honest reporting, and you make only a small percentage of the revenue that they earn. If you are thinking about adding private tournaments to your portfolio of revenue tools, there are challenges with getting them set up in the first place. You can try some based on speculation, you could wait to promote private tournaments until you build your traffic and have a proven track record of how many players you can bring to the tables, and you can even share the risk with the operators and pay for half the tournament up front or out of your earnings. In addition, you have to carefully monitor their production and provide superb customer service when things go wrong if you do this on your own. ...................................... About GGE Global Gaming Events (GlobalGamingEvents.com) is a marketing company that works directly with the operators and does not charge affiliates to promote any of these tournaments. These tournaments are totally free for affiliates to use as a tool, and are extremely easy to promote to your database and on your site. GGE provides creative, website copy and even a pre-registration form for players to register for the tournaments without even leaving your website. Almost all of the Global Gaming Events tournaments include a freeroll and a buy-in event, along with a bonus tournament after a series of events. These are designed to acquire, convert and retain players, and at the end of the day, result in some nice added revenue for the affiliate. 2012 EVENT CALENDAR JUST LAUNCHED! 47 26-29 January London Affiliate Conference (LAC) Old Billingsgate Market London, England .................................. Introducing GamingMeets.com – your guide to nearly 1,000 industry events including trade shows, conferences, seminars, networking events, and awards ceremonies. Visit this brandnew site for complete details on each of the upcoming iGaming affiliate events listed on this page plus a wide variety of other industry events. For up-to-theminute info on where gaming industry professionals around the world will be getting together, get yourself over to GamingMeets.com! JANUARY 2012 23 January Totally Gaming Awards The Ballroom London, England .................................. 23-24 January 6th Annual Legal Gaming in Europe Conference Millennium Hotel London Mayfair London, England .................................. Grange St. Paul Hotel London, England .................................. London, England .................................. 24-26 April 28 January Global iGaming Summit & Expo (GIGSE) Tiger Tiger London, England .................................. San Francisco, California LAC 5th Birthday Party 29 January LAC Closing Party Amber Bar London, England .................................. 30 January The Centre Page London, England MARCH 2012 4-6 March iGaming North America Spring Conference iGaming Asia Congress & Expo Grand Hyatt City of Dreams, Macao ICE, ICE Baby Party Lyceum Fire & ICE Party Gilgamesh London, England .................................. 26 January iGB Affiliate Awards The Brewery London, England MAY 2012 22-25 May The iGaming Super Show RMS Dublin, Ireland LAC Sunday Session 6-8 March 25 January 17-18 April LAC Welcome Drinks ICE Affiliate Zone Grace London, England .................................. grand hotel Stockholm, Sweden .................................. 7th Annual Online Bingo Summit & Awards 24-26 January 24 January i-Gaming Forum 27 January Planet Hollywood Resort & Casino Las Vegas, Nevada .................................. Earls Court Exhibition Center London, England .................................. 16-18 April APRIL 2012 15-17 April eGR Power 50 Summit SEPTEMBER 2012 European iGaming Congress & Expo (EiG) Milan, Italy OCTOBER 2012 2-4 October Global Gaming Expo (G2E) Las Vegas Sands Expo & Convention Center Las Vegas, Nevada .................................. 11-14 October totally gaming Barcelona Affiliate Conference (BAC) & IGB España Fira de Barcelona Barcelona, Spain Visit GamingMeets.com for full details Pennyhill Park Hotel London, England .................................. 17-18 April eGR Power Affiliates Summit Pennyhill Park Hotel London, England 2012 Event Calendar Social media SEO – Google’s G+, +1 and SEO By Gary Beal i t has been over a year now since Google Plus was released and lots of juicy information has come out so I thought I would hit on the high points for those who do not follow SEO or social media the way we SEO freaks do. The concept behind G+ and +1 is simple: Copy what Facebook did. Google saw the growth of social networks and decided to try to take advantage of an opportunity by joining the fray. +1 button There are actually three distinct parts to G+ and +1: (actually a separate tool but I have added it here) Circles and other social media elements The first part is a more personal page similar to what you see on Facebook, the difference being that you create “circles” of friends and classify them into each group accordingly. When you come across an interesting piece of content you simply share it with individual circles (e.g., Friends, Family, or a custom group that you create [see image below]). Okay, so now you are asking, “So how can I use this in terms of SEO?” The second part of G+ is a “+1 button” to allow people to recommend sites and parts of sites, similar in use to Facebook’s “Like” button. If you have the feature turned on you will see a little button at the end of each result when you are using Google to search, provided your pointer is hovering over the URL. If you perform a search and find a site that someone in your circle has clicked the G+ button on, you will see his or her name below the listing (see image above). After excruciatingly testing various aspects of G+ and +1 I determined that in terms of actually boosting your search engine rankings G+ and +1 have not yet been integrated into the algorithm. An example of this is taking one of my ranking sites, adding the G+ badge, then going to Fiverr.com and buying a bunch (hundreds) of G+ votes over a period of a few months and from different networks, but there was no discernible impact. You should add the +1 badge to your website. Google+ will gain more users and websites will integrate them more in the future, meaning that the information we share will be pushed to more and more people. This presents an excellent opportunity to promote our websites, in much the same way that Twitter and Facebook do now. Then I tried setting up a network of unique IPs. And over the period of about 60 days that each of these hundreds of individual searches ticked the +1 button that showed up in the search, nothing happened. The G+ page Drag people to circles to follow Google finally released its features to everyone a few months after its original release, and the dashboard lit up. And last but not least, the best element from an SEO’s standpoint: the G+ page. In the beginning it was only made available to non–business-related application, and Google even went so far as to shut down pages that were obviously there for business-related reasons. Even Sesame Street fell victim to Google’s wrath. Social media SEO – Google’s G+, +1 and SEO In terms of the SEO benefit from either the +1 or the G+ button, it’s a matter of the size of your network. Those sites with the G+ badge or those that have received a “vote” or +1 click from someone in your network were featured more prominently, as seen in the image above. Additionally, Google pulls in data from other social networks. So let’s say you or someone in your circle did a Twitter post. Google may even show that in their results if you are signed in to your Google account. “ 49 The concept behind G+ and +1 is simple: Copy what Facebook did. I’m curious to see over the next 12 months what Google’s long-term plan will be with G+ and +1, as they both parallel Google’s other tools nicely. Although I wasn’t able to identify any real effect on rankings while testing the thresholds of G+ and +1 for SEO, I think Google will definitely be using this as a metric in the future. After all, they are already allowing it to alter the way their results appear and losing real estate at the same time. Oh, plus there’s this that they let slip a few months ago (in a Forbes.com interview that was mysteriously removed): Google is encouraging web publishers to start adding +1 buttons to their pages, and the message in this meeting was clear, “Put a Plus One button on your pages or your search traffic will suffer.” Like the Boy Scouts motto says: “Be prepared.” I would (at the very least) add a multiple-choice social bookmark bar to your sites. At the end of the day social media as a whole benefit your rankings and your traffic to some extent. I have tested Twitter and Facebook to see if they enhanced search rankings, and both definitely did. This leads me to believe that Google just hasn’t turned on the tap yet and better things are yet to come. .................................... In terms of the SEO benefit from either the +1 or the G+ button, it’s a matter of the size of your network. Gary R. Beal is the head of search at Blueclaw Media in Leeds, U.K. He has been in the Search Engine Optimization field for 12 years. He attended Ohio State University in the U.S. and holds a Master’s degree in Biometrics and Mathematical Statistics. He specializes in SEO for very competitive markets, primarily in the gaming, dating, travel, insurance and financial industries. He has spoken at many SES, SMX ,CAP, AAC, EIG, G2E, AIG, GPWA, CAC and A4UExpo conferences around Europe and has also been on dozens of expert SEO panels. Gary has written specialized articles for multiple online marketing publications and moderates on three separate affiliate forums and as an affiliate has great insight. He is known best for his free one-on-one sessions during conferences and his noncommercial, plain-talk delivery. In the online world he is GaryTheScubaGuy and is known for his Top 12 SEO Tips. 50 How to position a brand-new site on Google page 1 in under two weeks By Paul Reilly A ll too often SEO is mystifying; the Google Web spam team disseminates fear, uncertainty and doubt (FUD); SEO propagates this FUD and suddenly we feel scared to tread; the path seems too long and the journey impossible. Furthermore, new potential affiliates feel overwhelmed or perhaps think they’ve missed the boat. “If only I’d started this five years ago, I could be earning money.” “I’ve missed the good times; there’s no money in this anymore.” I’ve had these thoughts myself, and they lead to a mental block on progressing as an affiliate. The truth is it’s easier than SEO consultants and agencies would have you think. If I were to tell you that you can position a brand-new website on the first page of Google in under two weeks on a shoestring budget, would you believe me? Well, it’s true. I’ve not only done it once, I’ve done it countless times. It requires two things: 1. A soft market 2.An exact-match domain I hear rumors of exact-match domains having their weighting reduced. I have not seen any evidence of this being the case other than a few affiliates who were removed from a select number of SERPs for high-value phrases in super-competitive markets. The steps required to get from a standing start to page-one ranking are detailed in this article. Consider this an easy, step-by-step road map to page-one Google success. Step 1 – Choose a product There are a few considerations when choosing a product to promote. Popularity, competition and ability to accept deposits in a given territory are just some of the things you need to think about when choosing a product to promote. You may want to stick to what you know and a plan to do what you love, or you may decide to make this decision based on the commercial opportunity – the choice is yours! TLD are taken, availability will help you finalize which territory you want to kick things off in. Step 3 – Choose a territory You may decide to promote a multiproduct site. If you’re planning such a site, I recommend tackling one product at a time until each product is generating a positive return on your SEO investment. Before you commit to a singleproduct or multiproduct affiliate site, you need to consider the territory you want to market in. Taking into account relative competition, availability of local-language exact-match domains and macroeconomic and cultural factors, the next step is simply to take clear, decisive action. Step 2 – GEO keyword research • What is a typical salary for various job roles in my target territory? – This will help you judge typical wager amounts. Pick a soft or emerging market where operators are able to accept deposits. I’ll leave this bit up to you to do (hey . . . come on, now . . . you didn’t think I was going tell you everything, did you?). You should also get a local native speaker to help you with the keyword research. You can find great people on Odesk.com. Once you figure out the keywords used to search for your favored product, ask your newly hired help whether accents or diacritical characters are used locally when searching. This can be key: if all the big-phrase, exact-match domains in the local How to position a brand-new site on Google page 1 in under two weeks Research the following: • Is there a gambling culture in my target territory? – Again, an indicator of typical wagering. • Do regulatory issues prohibit impulse depositing via credit card? – This will provide an indicator of sign-up–to–deposit conversion. • Can I acquire an exact-match domain, either on a local TLD or a neutral TLD (.net/.org/.com)? – This will determine how easily you’ll be able to rank in your chosen territory. • When I Google my product’s primary locallanguage keyword (bingo, casino, betting, poker), do I see nonlocal results accompa- 51 nied by Google’s “translate this page” links? – The presence of these results is an indicator of a very soft market; they most often appear as English content. Step 4 – Pick a keyword I always like to say that “picking a keyword is picking a fight; don’t pick a fight unless you’re sure you can win!” Tackling unknown markets can make this defensive thinking problematic. So it becomes more an issue of risk management. This article is about tackling major iGaming SERPs on a shoestring budget. It’s worth noting that with a diverse link mix you can rank upper page one in certain markets with as few as six to 23 links for killer single-keyword queries. It requires an exact-match domain and a perfectly balanced link profile. Step 5 – Buy a domain I’ve never been much of a domainer; buying domains at the right price is a specialist field of its own. Whenever I buy domains, I usually buy them at £10 based on what is available. My conclusion here is that much nonsense is propagated by SEOs. Many of the link orders which come to Media Skunk Works are riddled with dogma. This belief that strict local TLD or GEO IP criteria must be adhered to is in practice unnecessary. Example: I took a Chilean TLD, built a site, linked it up with Spanish-language links on Spanish-language sites all hosted in France . . . and boom! Page 1 for Tragaperras in under 14 days. So don’t believe the hype, folks. Step 7 – Get a logo This step can be bypassed if you want to save even more money. However, one place you can get cheap logo design done is at 99designs.com, or you can look for designers on Elance.com or Odesk.com. Step 8 – Get a site designed You can find great Web designers on Odesk.com although you do take your chances – the quality will vary, and be careful when choosing a designer for the Web. Your logo designer may not be a CSS guy, but rather a print media specialist, and his or her site design may need additional work when it gets converted into code and CSS. • One-third to contain the domain name/ home-page URL (e.g., http://example.com, example.com, www.example.com, etc.) • One-third to contain neither the home-page URL/domain nor the target keyword (Click here, Visit site, etc.) Link exchanges also work very well. Don’t buy into the myth that reciprocal links negate each other. This is SEO folk law, which stems from a filter which was applied to deal with directories which accrued PageRank via free listing in exchange for a link. At the recent Barcelona Affiliate Conference I launched the #BAClink hashtag as a way for affiliates to collaborate and reciprocate links. I strongly advise using this as a method for collaboration. Just tweet the products and territories where you have affiliate websites, along with #BAClink, and share the love. (Only your money sites – no artificially inflated PR or link farms. Let’s keep this pure!) Example: All the best domains are taken, right? Wrong! IDNs (International Domain Names) open up the possibility for the use of diacritical characters (accents) and foreign characters such as Cyrillic. Google appears to take these accents into account when determining the SERPs for any given query that contains them. Guess what? They look shitty, but Google loves them. They’re encoded using Punycode and can be bought from a number of reliable registrars. This Punycode converter will show how the domains are decoded and encoded: http://www.charset.org/punycode.php Note: the French don’t use accents when querying Google due to the position on the keyboard. However, the Germans, Scandinavians and Spanish do use their respective accents when querying search engines. Step 6 – Get hosting When kicking off your embryonic affiliate business, you don’t need expensive servers. I opted for relatively cheap virtual hosting. I’m targeting international markets using neutral (.org & .net) domains and haven’t even set up geotargeting in webmaster tools, yet everything is ranking perfectly. The neutral domains are ranking due to language and local targeted links and the local TLDs are ranking based on language and the TLD’s country. Step 9 – Get a site built I prefer my sites to be built in Drupal, but WordPress is also very popular and versatile, once customized with an easy-to-navigate theme. You’re also in a position to replicate and rebrand the first installation. I use a multi-domain installation of Drupal, which means I can have hundreds of sites running from the same file structure with their own databases. This approach enables me to scale rapidly. Step 10 – Write content Many agencies talk about “content being king.” The first two sites I ranked with this approach had only a single optimized holding page. They both ranked page one for their primary keyword. Again, don’t believe the hype. One page, 300 words will be enough to get you rolling on day one. You can find great local-language writers, researchers and translators on Odesk.com and Elance.com. Always use local native speakers, ideally with iGaming backgrounds. Step 11 – Get links You need links! Buy 15 in the first round and use these anchor variations. • One-third to contain your target keyword as part of the phrase ….and meet like-minded partners in link love to share the juice with. Do it! NOW! Summary It’s actually easier than you might think. The only thing preventing you from building a successful affiliate business is YOU! Get on with it! Experiment! There’s no real barrier to entry, so get involved. Remember... • Don’t let your quest for perfection get in the way of progress. • Jump in, have fun! ...................................... If you have any specific questions e-mail me directly at [email protected] or follow me on http://twitter.com/paulreilly or stalk me on http://foursquare.com/user/paulreilly GPWA AFFILIATE INTERVIEW SERIES They’re all sure of one thing: office jobs are the worst! Whatever it takes to avoid having to report to a 9-to-5 office job, the five webmasters we interviewed for this issue will do it – even if it means having to work around the clock at home! They’re based all over the place – Toronto, Warsaw, Sydney, London and someplace in India. Their literary tastes run the gamut from Ayn Rand and Napoleon Hill to John Fowles and Charles Bukowski – and one of them has recently had a book published. They’ll eat just about anything, including Mexican, Thai, tatar and sushi. EDDIE YU casinoman Social media’s not a fad – it’s the elephant in the room First of all, congratulations on the recent publication of your book, Speedlights & Elephants: Winning the Online Business Game (available in paperback or Kindle on Amazon. com). Tell us about the book – why did you write it, and how could it benefit GPWA webmasters? I wrote the book because I wanted to share my knowledge and experience so that it might help and inspire other people to set up their own online businesses. I felt that a book was the most accessible way for people to get that information in a nicely presented format. GPWA webmasters can get a lot of the mindset help that is needed to become a good webmaster from the book. These folks are among the most successful GPWA webmasters we’ve ever met – they’re doing a lot of things right, and they share some of them in their interviews. You’ll enjoy their stories! *Due to space constraints, we could not print the interviews in their entirety. The complete text will be posted at gpwa.org. Being a webmaster is quite a lonely business and we all know that business is not business without people, so I know that when I started out, I lacked the interpersonal skills I needed to succeed. Over time I gained those skills and I felt that I could share that process with people, to help them over this particular hurdle, which personally took me three years to overcome. Being a webmaster is also not just about SEO or PPC, it’s about being a well-rounded entrepreneur, making good decisions for business, and the book aims to ensure people understand that online business is no different from any other business, that you must get your business hat on and learn about all those things which make businesses work – e.g., cash flow, margins, taxes, legal matters, etc., etc. – stuff we want to avoid, but know that we can’t! In a recent blog post, you pointed out a study that found that “69 percent of all workers believed that the office was unnecessary now.” Many affiliates have been working from home offices for years. Do you work from a home office? If so, what have you found to be the key to success when working outside an office environment? Yes, I do work from a home office and the rest of my team does as well. I think the key to home-office working is to get out more and have meetings in fun places! Business is about people and no matter how many Skype sessions you can have, you’ve got to always mix in real face-to-face meetings and networking in order to get a balance! What kind of writing experience did you have going into the book? Was the process harder than you thought when you first set out to write it? I have no writing experience, other than writing blogs. So as I always do when I don’t know something, I find an expert to talk to, help me and maybe coach me. I found one of the best book coaches in the U.K. (known as The Book Midwife) to help me understand how to create the architecture behind a book and how to structure it correctly. With her help, I found the process much, much easier than going it alone! 55 AGE: HOMETOWN: LIVING IN: FAVORITE FOOD: MUST READ BOOK: SITE: 37 London, U.K. London Thai Think and Grow Rich, by Napoleon Hill casinoman.net GPWA AFFILIATE INTERVIEW SERIES There are a lot of sites in your online gaming portfolio. What is the business strategy behind operating so many sites? Initially the strategy was to build up a network of sites for SEO purposes. Then there would be many sites on many different IP addresses that could all crosslink each other so that in effect I could own my own backlink network. Eventually this strategy took more of a back seat as business moved forward and really that was a short-term strategy aimed to “game” the system. We moved towards more valuedriven, long-term strategies that revolve around good quality content and building a solid brand that could last the years. In terms of Alexa traffic, CasinoMan. net is one of the larger affiliate sites. What were the keys to building up that traffic? What did you do really well that others didn’t? Quite early on, we made a decision to concentrate on branding over SEO because we felt that SEO was an ongoing short-term strategy that put the site at risk whenever the search engines decided to change their algorithm. I looked at other industries and modeled successful retail sites and service-based sites and realized that the long-term business game is always won by brands and not by forgettable domain names! This switch was a major change and it meant that we would now be concentrating on retaining our visitors. To this date, a vast majority of our visitors are repeat customers loyal to the brand, and our stats show that some visitors will come by over 20 times a month. That’s branding at work. We also drove traffic using lots of other diverse methods so that our overall reliance on SEO would keep reducing. Thinking outside the box, we noticed that there were huge amounts of searches and traffic in the desktop wallpaper sites, so we started to create ranges of desktop wallpapers and uploaded them there. We were the first to create game videos and now our YouTube channel has over 1,000 game videos – the largest channel of slot games. We took social media on board as soon as we figured out how to use it. Driving long-term, sustainable traffic is about looking all around and seeing what opportunities there are outside SEO. You posted last May that you were preparing to sell all of your online gaming sites. Is that still your plan? Do you work with any other industries? Yes, this is still the plan. We are now heav- GPWA Affiliate Interview Series ily involved with other industries and my personal mission to create a world without offices. I’m selling our projects in this industry so that I can fully focus on the new opportunities ahead. How long have you been involved in the industry? What drew you to the business? I started in 2001 and it was an article I read in Yahoo News about the potential of the online gambling industry that attracted me towards it. After reading that article I did some market research and noticed that it was a small market with little competition. I saw it as a business opportunity and started to work on the CasinoMan project from then. Are you a full-time online gambling affiliate, or do you hold down another job as well? I am a full-time entrepreneur with multiple businesses. My team takes care of the gambling affiliate side with me directing. You have affiliate sites in a variety of different online gaming verticals – casinos, poker, sportsbooks, bingo and backgammon. How does attracting and converting players in the different verticals differ? How are casino players different from poker players and bingo players? And how do you take those differences into account as you create your sites? To be perfectly honest, our core skill is in understanding casino players and slots players. The other sites we created were, as I mentioned earlier, simply a mechanism for SEO and we never really concentrated on marketing them or attracting players via those sites. Invariably they still did attract players; however, it was never important for us that they did because it was not our primary purpose. I think if you want to understand the differences of each vertical in the industry, you must first understand one of them as much as you can and then translate that knowledge into the others. There are of course similarities in players because their overall agenda is gambling and that is a question 57 57 of understanding the human psychology behind it all. The verticals are merely niches within that psychology. What do you like about the industry? I like the challenge, and the changing legal climate makes it quite the rollercoaster ride. It keeps me on my toes and that has helped to fine-tune me as an entrepreneur. Lessons learnt from this industry have been invaluable for me when I work in other, more stable industries. What don’t you like about the industry? Lack of technological change. Since its earliest days, this industry has relied too heavily on deals, banners, links and not enough on new technology. The adoption of fully automated systems to utilize technology like RSS, XML, social media streams, database API and XML API hooks has been abysmal. As a result, this industry is falling behind as others gain prominence because they are investing in those new formats. What surprised you most about the industry? Strangely I think what’s surprised me the most is how old business thinking has had a chance to succeed in this marketplace merely because demand is always going to outstrip supply, which means that casino companies can be complacent with innovation yet still make a profit! How long do you give yourself for responding to e-mail? And what e-mail tips can you offer? I’m terrible with email and I know a lot of affiliate managers will agree with me on this! I’m afraid my e-mail tips are not worth listening to!! How do you manage your “to-do” lists? Do you use any special software to help you out? We use a combination of Basecamp for long-term objectives, Outlook task management for short-term tasks and I personally keep a handwritten daily task list which I compile each morning to help me focus on the most important things for the day. Time management is one of the biggest issues facing affiliates. What time-management tips can you offer your fellow webmasters? Work in solid blocks of 90 minutes so that you focus only on certain things during those 90 minutes. Have a 15-minute break in-between to relax and chill out. The human mind and body work well with the ultradian rhythms, which are natural biological cycles, so use them to your advantage. Break up the activities as well so you aren’t doing 90 minutes of SEO followed by a 15-minute break and then another 90 minutes of SEO. Mix up the types of work. This rhythm fits with breakfast, lunch and dinner, too! How much time does it take to keep your sites updated? In terms of man hours it takes probably 35 hours per month. How much time do you devote to social networking in order to drive more traffic to your site? Our traffic from social media has grown steadily and hasn’t stopped since we started adopting it. It’s a vital long-term strategy for anyone in online marketing. Social media isn’t going away; it’s not a fad, it’s a necessity, so learn it or get left behind. You’re coming up on your 10th anniversary as a GPWA member. How has the GPWA changed over the past decade, and how has being a member helped you? When I first started, the GPWA was an incredible resource for me to learn about the industry and tips to do with conversion, marketing, SEO and everything else as well. The part of the GPWA I love the most is the friendly, collaborative atmosphere. It is exactly that willingness to help each other that has kept it growing consistently. If you could have dinner with any five people, living or dead, who would they be? 1.Bill Gates – I want to meet the best business mind in the world. 2.Richard Branson – I love his attitude towards life and how it translates into the way he does business. 3.Alexander Graham Bell – the inventor of the telephone, but also of many other things that perhaps people aren’t aware of, including avionics, Montessori and National Geographic amongst many. 4.Margaret Thatcher – I want to find out how she dealt with overcoming what most people of the time deemed impossible and became one of the most powerful people on the planet. 5.Jamie Oliver – I want to find out what drives him on his mission, which I find utterly inspiring. When you need to get as far away from work as possible, where do you go? St. Lucia. How do your family and friends feel about the way you make your living? My family don’t really get how any of it works. They understand the business component, but not the mechanics of the online world. My friends are pleased but at the same time envious. Unfortunately the friends who were close to me when I started out in 2001 are somewhat more jealous than happy for me as they did not see the same level of success in their lives. This is a story I’ve now heard over and over again from successful entrepreneurs, so if you are a webmaster reading this and you are planning to be a success, be prepared to leave some friends behind; it’s for the best. If someone were visiting you, what’s the one place you’d definitely take them to see? Hampton Court Palace – one of the most magnificent palaces in all of Great Britain. What’s your all-time favorite movie? There are too many! I guess a recent favorite would be Star Trek (2009). I’m a total trekkie and this movie goes to show that no matter how old an idea is, if you can give it a brand-new spin for the present day, then it’ll be a success. In an age where many ideas are already done, it’s time to get inventive in business and bring old ideas back into the digital age. If you were a Star Trek (or Star Wars) character, which one would it be? Star Trek – Captain Sisko – commander of a space station! If you won $50 million in the lottery, what would you do with the money? First, I would ensure that my family was all taken care of for the rest of their lives, and then I would invest some in my new businesses to grow and establish them and the rest in property. If you were a brick in a wall, which brick would you be and why? Depends on the bricklaying technique. What are three things that nobody knows about you? 1.I was in the movie Love Actually. 2.I used to take vegetable deliveries from my parents’ restaurant to Pierce Brosnan before he was famous! 3.I want to set up a charity for sexually abused women. GPWA AFFILIATE INTERVIEW SERIES MICHAEL LazyRiver If you wanna do it, do it right and do it in Polish! What’s the state of online gaming in Poland these days? Have recent government efforts to ban it had any effect on the Polish market? It’s hard to say, since it is all gray and underground. Judging by the numbers I’ve seen and the rumors I’ve heard, it is what it used to be before October 2009 (breakout of “gambling scandal” followed shortly by new gambling laws = the Big Ban). There is no decline. Regular gamblers know they’re not likely to be punished for playing online so they keep playing. But there is no growth, either. New potential players are not educated since all the operators backed away from the official marketing channels – you cannot see any ads or promos anymore in Poland. Also all major affiliate sites are – in theory and small print – designed for “Polish-speaking clients gambling from jurisdictions where it is legal.” How seriously you take that disclaimer is strictly up to you. So far our government has taken actions against land-based slot machines, landbased online “terminals” (public slotslike machines which allowed you to gamble online while depositing with the local shop/pub owner) and innocent, recreational tournament poker players who set up card games at clubs. Going after that last group unleashed the fury of the media and online communities (as the police raids were absurdly excessive and exaggerated) and put some heat on the government, which is now considering adjusting the gambling ban to allow tournament poker. But in general the ban is pretty hardcore – the government even removed Hold’em cash games from official land-based casinos and made tournaments totally painful and unprofitable to organize. That is the reason all major poker tours skip Poland right now. GPWA Affiliate Interview Series For affiliates looking to enter the Polish market, how do Poland and the Polish market differ from the rest of Europe? What works in Poland that might not work in the rest of Europe? What works in the rest of Europe that might not work in Poland? In terms of gambling patterns it is pretty much standard, with sportsbook, poker and casino taking even slices of the pie if you look at the profits. Other markets like backgammon or bingo are hardly penetrated and not popular. What definitely works in the Polish market is a strong focus on localization of whatever you call your business – be it betting, casino, poker, affiliate site, etc. If you wanna do it, do it right and do it in Polish! Unfortunately, many Polish gamblers are not that comfortable with English (except maybe for the poker community), so if your offer is run by locals in Polish you immediately gain a strong advantage. Obviously, using local celebrities like Polish sport stars helps too, but since the Big Ban everybody has been more careful. And one more thing – forget Google Translate. Our language is complex enough to give us Poles headaches while writing stuff, so just don’t try it! You will lose your credibility and hurt your brand unless you talk to native professionals. Oh, and the same goes for link-exchange e-mails, guys; please use English with me rather than attempt to e-translate to Polish – I might die of a heart attack laughing one day. . . . What’s the most popular form of gambling in Poland? Is it casino, poker or sportsbetting? Sportsbetting is the most popular in the mainstream, for sure. You can still bet in the shops and betting is pretty much most of the heavy artillery in the typical online operator’s marketing arsenal. The poker scene got hit by the laws, but people keep rocking; you just can’t keep it down, legal or illegal. Obviously more liberal regulations would make it blossom right now, but that is not the case yet, unfortunately. But as far as I know, many players have taken the initiative and formed official associations to represent the community and talk to the government about better regulations. Casino is the most quiet of all, but it is a big business that the government wants to get a tight grip on via a state monopoly lottery, making the government the oneand-only official online operator. You work with some European poker providers. What was their response to the Black Friday indictments in the U.S.? And has your affiliate business picked up on the poker side since the indictments? Well, they got very, very active around the middle of April, if you know what I mean. It was kind of funny to see how they popped champagne corks around the freshly laid corpses of the Big Boys of Poker and how they were all of a sudden convincing players it is all good if you stick with them – which is true, by the way. As far as the business goes, I am way too focused on casinos to notice any big changes in poker, plus I think PokerStars got back on their feet pretty quickly and made sure Polish players were happy and safe. How long have you been involved in the industry? What drew you to the business? I’ve been in the industry for about five years. I started as a marketing consultant for a major U.K. sports bookie, very active in the Polish market back then. Acting as promotion manager for poker and casino, I learned the tricks of the trade and gained a lot of insight into the market. When I terminated my job there and moved on to another business, I decided to use my knowledge to create an affiliate website. That’s how it all started. 59 AGE: HOMETOWN: LIVING IN: FAVORITWE FOOD: 38 Szczecin, Poland Warsaw / London Tatar (raw minced meat + raw egg + raw onion + pickles) MUST READ The Magus, by John Fowles BOOK: SITES: kasyno.pl hazardowo.com jednoreki.pl worn out over the years. It is nothing but a trap for first depositors and something that can put them off for good. I might be a dreamer but I want to conduct business by recommending solid, modest operators who don’t give away fake fortunes but instead offer top-notch service and entertainment, making people come back for more. My top-performing operator offers no welcome bonus at all, and I am happy to place him with my top spots. This business is NOT about gaining, it is all about maintaining. Then again, we all know that the fish goes for the bait – we just have to be reasonable with it. Are you a full-time online gambling affiliate, or do you hold down another job as well? I am a consultant and part-time manager with an international technology company with a branch in Poland, and this takes up 80 percent of my time. The remaining 20 percent I try to dedicate to consulting for Lazy River Group – a company which owns gambling affiliate websites in Polish. It probably won’t be a surprise to say I want to make it 100 percent in the future, but with the current state of affairs in this market, it is a risky bet. What do you like about the industry? It has to be that certain kind of day-to-day unpredictability of the business. I believe we all (affiliates) have certain gambler’s DNA encoded inside. Sure, I learned soon enough not to gamble excessively myself, but I love the thrill of checking my stats in the morning – even if the long-term results are pretty stable and predictable. What don’t you like about the industry? The legal environment, for sure, at least in Poland. Banning is not the way to go, unless you want to protect your monopoly. The same rule goes for gambling as for drugs, religion, music, literature, sex, video games – whatever you want to occupy your mind with. Regulate it wisely, profit from it and make your voters happy – that’s the way I see it. What surprises you most about the industry? The number of affiliate managers who still believe in the magic powers of a flashy ad banner. You posted about a year ago that operators and players alike seem to be moving away from the “welcome bonus” promotion. Do you think this trend is continuing? What impact, if any, will it have on affiliates? I firmly believe that the extreme “welcome bonus” formula has Your Kasyno.pl site has an appealing design with online casino reviews and news. How much time do you spend working on content compared to the amount of time you spend designing your sites? I guess there are two kinds of affiliates in this business – those coming from an SEO background and those with a writing/publishing background. I count myself among the latter, so I always put a lot of effort and attention into the way my websites look and speak. Kasyno.pl is a premium domain which deserves proper design – and it still could be better. I believe my job is to convince my visitors that gambling online is just as safe and normal a thing to do as shopping at Amazon or posting on Facebook – hence the design and content, which should be flawless and professional. Yes, I spend a lot of time on design and tweaks, whether it is text, screenshots, actual testing of the casinos, etc. I just want to be honest with my readers and give them proper advice on how to gamble safely online. GPWA AFFILIATE INTERVIEW SERIES As mobile gaming continues to increase in popularity, do you have any thoughts on the market or any actual plans to begin promoting a program or two? Yes, I have already obtained a couple of interesting domains, including www.mobile-casino.asia. Mobile gaming obviously needs to be done on the international level right now, because the Polish market is not mature enough to support projects aimed at a local mobile market. Mobile gaming is definitely a promising market and I am trying to get my head around that, sorting out how much of it is just hype and how much of it represents a real business opportunity. In promoting your sites, do you put more time into SEO or into enhancing your social-media presence? Which in your opinion produces the most conversions? SEO is definitely my priority. Social media presence and response might be fine for my ego, but businesswise I want to be where my potential players are looking for help, and that is still search engines. If you ask me, I would skip that whole “social” thing and jump right onto mobile apps. For example, AppStore search optimization is the thing of the future – provided you have your own aff app already there. Also, most people think “social = Facebook + Twitter.” They forget how powerful YouTube is. Kids don’t read anymore, they watch videos – they search for clips, not articles. How long do you give yourself for responding to e-mail? And what e-mail tips can you offer? If an e-mail makes sense, I respond within 48 hours max. My tip? Flag any e-mail you find interesting and review your flagged items every three days. Anyway, an IMPORTANT e-mail gets answered immediately. How do you manage your “to-do” lists? Do you use any special software to help you out? No, I use an old-school Moleskine notebook and a pencil to put down my ideas, action items, things to do, etc. I also run a general Excel spreadsheet to keep track of long-term projects regarding my main domains – something I review once a month, to be honest. Time management is one of the biggest issues facing affiliates. What timemanagement tips can you offer your fellow webmasters? Focus on what you GPWA Affiliate Interview Series do in your “aff-time.” Get down to business. Create an account with Xmarks for your browser and switch to aff-only bookmarks when you work on your sites. No Facebook, no YouTube, no Twitter. Just work-related links in the top bar. Once you start your daily session, jot down in your notebook REALISTIC goals to achieve today. Cross them out and don’t move forward if you’re not fully done with the previous one. In general – no magic formula here. Just hard work, that’s all. How much time does it take to keep your sites updated? No limits here. If I could commit all the time I had in the world, I would spend three to four hours a day. The rest would go to my little daughter, sports, reading and video games in the evening. How much time do you devote to social networking in order to drive more traffic to your site? Honestly, almost nothing. I might be wrong, but I believe in “fresh blood” from Google, not the “friends” from Facebook. Plus, gamblers prefer to keep a low profile in Poland. The ban and legal situation don’t really go well with the whole “social” concept, if you know what I mean. . . . What prompted you to join the GPWA, and how has it helped you so far? It was a GPWA seal on one of the sites I purchased. I checked out what it meant, got into forums and lurked around. At first I saw it as being too U.S.-centric, but since Black Friday I’ve seen it switching more toward the European market and audience. I got some helpful advice from the site as well as some business leads. Still, I think personally it is too fragmented as a discussion forum to keep track of what’s really going on. I would prefer way less subforums: I am a big fan of the evolution theory – weak threads will drop down and interesting topics will stay on top, so there’s no reason to categorize everything. If you could have dinner with any five people, living or dead, who would they be, and why? David Simon, the creator of The Wire – I love the show. Ricky Gervais – this guy cracks me up. Donald Tusk, the current Polish Prime Minister – maybe I could explain why our gambling laws suck and how to make them better. Mike Patton from Faith No More – for the music. And Charles Bukowski – for the books. When you need to get as far away from work as possible, where do you go? I am an avid runner, so I just get up from my desk and run 10-15 km, totally relaxing and recharging. For a longer break I go snowboarding or hit the Greek island of Ios. How do your family and friends feel about the way you make your living? My family supports me and my friends don’t know much about it. I tend not to bore them with my business life; we have better topics to discuss when we meet! If someone were visiting you, what’s the one place you’d definitely take them to see? The Warsaw Uprising Museum. It commemorates a tragic yet heroic moment of our history, which is hardly known to outsiders. What’s your all-time favorite movie? Swingers (1996). It reminds me of my good old student days, hanging out with my crew, still able to waste my time and have fun. And it has the cult scene in Vegas, where Jon Favreau and Vince Vaughn pretend to be high rollers at the blackjack tables. Anyone from the industry should see this. It’s so money! If you won $20 million in the lottery, what would you do with the money? I would take my family and friends on a crazy trip to Vegas and double the winnings. . . . If you were a brick in a wall, which brick would you be? Probably the bottom one, hardest to remove. What are three things that nobody knows about you? 1.I sailed on a small boat all around Europe when I was 18 with a captain and five other mates who, like me, had no clue about sailing. 2.I was one of the first downhill skateboarders in Poland in the mid-80s. 3.I was playing online poker for microstakes once and got into an argument with another player via chat. The heat was on and we took it to a high-stakes, heads-up face-off where I lost my entire bankroll within five minutes. GPWA AFFILIATE INTERVIEW SERIES SABA gamblingdomainer Wild symbols, Scatter symbols and bonus rounds – today’s players want it all! Both of your sites provide players with information, news and gaming strategies. Which site brings you more income? www.casinopromotionblog.com Are players more interested in bonuses and promotions or finding ways to beat the casino? Bonuses. What in your opinion is the best strategy for winning at slots? Bet on the maximum number of paylines to increase the chances of winning the jackpot and go for slot machines that offer bonus rounds. Do players looking for promotions tend to stick around at a casino after they’ve played through the bonus offer? Or do you find you have a lot of bonus hunters? These days there are a lot of bonus hunters, I guess due to the fact that casinos are coming up with new and lucrative bonuses almost every day. Players want to experience it all! You have a lot of reviews of slot machines on your site. What are the most important components in a review of an online slot? Slot theme, slot features including Wild symbols and Scatter symbols, bonus rounds, and jackpot value. How do you pick the programs that you work with? What are the most important factors you weigh when considering a new program? Programs that have: • A good reputation for paying their affiliates on time. • A good CPA percentage. GPWA Affiliate Interview Series How long have you been involved in the industry? What drew you to the business? It’s been more than three years now. I first worked in a gambling company earlier before realizing that being an affiliate is more fun and exciting. Are you a full-time online gambling affiliate, or do you hold down another job as well? No, I’m not a full-time affiliate; gambling is more or less my hobby. I do work as a digital marketer offering consultancy to other gambling operators. What do you like about the industry? The risk, competition and volatility. What don’t you like about the industry? The fact that there are many casinos out there cheating players and giving out fake bonuses. What surprised you most about the industry? The United States accounts for the highest percentage of online gambling traffic and still the government has not made it legal. What better way for a country that is struggling to fight recession (to generate tax revenue)? How long do you give yourself for responding to e-mail? And what e-mail tips can you offer? I try to respond within 24 hours. E-mail should be very concise and not wordy. Don’t make people hunt for information. Instead, put the information right in front of their face. You’ll be saving your readers a lot of time – and saving yourself some writing time, too! Also, e-mail should always be personalized; it makes it more effective. How do you manage your “to-do” lists? Do you use any special software to help you out? I belong to the old school of thought, so usually my to-do lists are on my diary and sticky notes. Recently I’ve been using the calendar on my mobile due to a rather hectic travel schedule. Time management is one of the biggest issues facing affiliates. What time-management tips can you offer your fellow webmasters? When you leave a job and become a full-time affiliate to work from home and at your leisure, there can be a lot of distractions. Some things that have helped me stay focused are maintaining a to-do list, blocking people on chat who engage in conversations during the work hours, and not going on websites like Facebook and Twitter. The key is, make a plan and stick to it. Have more self-control and don’t be distracted too easily. How much time does it take to keep your sites updated? Around two hours every day, although sometimes I skip updating for two or three days (blame it on my poor time management!). How do you use social media to promote your sites, and what role does SEO play in your efforts to improve your site rankings? I give a lot of focus to Facebook, Twitter and StumbleUpon. Using social media tends to encourage conversation and create loyal players. SEO undoubtedly is the key to generating traffic. Google Search is the biggest source of my traffic, and thus the importance of SEO. Do you ever contract outsiders to do SEO for you, or do you always do it yourself? Being an online marketer myself, I make the strategy and implement on-site SEO. For off page and link building, I do have some freelancers working with me to promote the websites. What prompted you to join the GPWA, and how has it helped you so far? The GPWA is the biggest gambling forum in 63 my opinion and being here has been awesome. I have been able to interact with a lot of people with similar interests and learn a lot about the latest industry trends. If you could have dinner with any five people, living or dead, who would they be, and why? 1.Michael Jackson (he is my favorite – need I say more?) 2.Steve Jobs (the best innovator I have ever seen) 3.Jesus (it would be good to meet God in person) 4.George Carlin (best comedian ever) 5.My maa (it’s because of her I am where I am today) When you need to get as far away from work as possible, where do you go? A long road trip to an unknown destination. How do your family and friends feel about the way you make your living? They have come to terms with what I do with my life. Surprisingly they are very supportive now. If you were a Star Trek (or Star Wars) character, which one would it be? Luke Skywalker. If you won $50 million in the lottery, what would you do with the money? Let me get the money first, I will do the thinking later! If you were a brick in a wall, which brick would you be and why? Aren’t all the bricks the same?! What are three things that nobody knows about you? Some things are better kept a secret. . . . AGE: 28 LIVING IN: Mauritius and India FAVORITE FOOD: MUST READ BOOK: SITES: Mexican The Fountainhead, by Ayn Rand casinopromotionblog.com winslotsmachines.com GPWA AFFILIATE INTERVIEW SERIES Josh joshac Find a gap in the market – then fill it All of your sites provide players with information on current bonus opportunities – and they all pull in a lot of traffic. Tell us about how you conceived and developed the sites and what you do to keep players coming back. When I created the first site (LCB) in late 2006 I looked for an opportunity and gap in the market that needed to be filled and found the need for an honest casino bonus comparison site. I achieved this by listing bonuses of all shapes and sizes and ranking them from most attractive bonus to least. Also as the site progressed I was also able to capture a large portion of the no-deposit market. The mission statement for the website is to provide the best possible bonuses for players; no matter what game they like to play they have a choice for everything. The forum plays a huge role in retention and we have an awesome and dedicated team that update bonuses, provide exclusive offers and communicate with our members and visitors continuously. Your sites all have the same “brand.” How important has that brand been in driving existing players to new gaming market sectors? Should all affiliates build sites that have a similar look and feel to build their brands? Or is it okay for affiliates to build sites that look and feel completely different and have separate brands? We started on the casino comparison site and after finding success in that area we found a need for the other gambling markets (bingo, poker and sports) in the same bonus comparison capacity. Because the casino brand and our mascot had become known and now resonated with members in our particular target market it was best to stick to the same brand and branch out. Players would then be familiar and take to the poker, sports and bingo sites more easily, as they would trust and understand the purpose of the site. We were able to reinvent the LCB mascot to fit the other gaming sectors quite easily. The four sites together enable us to sustain and grow our brand equity. However, if an affiliate has a slots-focused website GPWA Affiliate Interview Series with a slots logo, then it would not work for a poker or sports website. How long have you been involved in the industry? What drew you to the business? I started in late 2006 because I wanted to earn a little extra money while working in my current web consulting capacity. Having looked at a couple of affiliate sites from different industries I made the conclusion that the gambling industry seemed to have good return on traffic. Are you a full-time online gambling affiliate, or do you hold down another job as well? Full-time with over 20 people involved in the sites. What do you like about the industry? I like the flexibility it gives me to work when and where I want. I like being my own boss and I never want to be working in an office from 9 to 5 again. I also like the low overhead related to being an affiliate with no products to deliver or inventory to house. What don’t you like about the industry? The unregulated nature of the industry with many shady operations and unreliable operators, which leaves both affiliates and players at risk. What surprised you most about the industry? The biggest surprise was the non-corporate nature and the Wild West feel to such a large global industry. A couple of years ago, a GPWA member launched a site that was almost entirely lifted from one of your sites. Are you satisfied with the effort this member made to remove your content from his site? Are you comfortable with his being a GPWA member today? I do recall a site but I have not kept a follow-up as many people have made somewhat clones of my site. It is an ongoing task to ensure the content and images are not stolen. I guess it’s the highest form of flattery. I haven’t really put much thought into it and not even sure who he/ she is, to be honest. You recently experienced a payment problem ($10k+) with an Asia-based program whose Terms and Conditions were subsequently termed predatory by Affiliate Guard Dog. Was the payment issue resolved? Do you currently do business with this program? I have been paid around 30 percent of what was owed but still the terms remain predatory whereby a minimum number of new depositors need to be delivered per month. I do continue to work with them to get the 70 percent owed. To be honest, affiliate programs like this are being very shortsighted, losing out on the majority of affiliate business as I cannot recommend the program and promote them any further on my other ventures. How long do you give yourself for responding to e-mail? And what e-mail tips can you offer? I usually turn around my e-mail within a day or two. I prioritize my responses in regards to urgency and importance. Personally, I respond in a short and concise manner to deal with the volume of e-mail received. How do you manage your “to-do” lists? Do you use any special software to help you out? I have no “to-do” lists. I have decentralized the work involved in running the website and do not micromanage the people working on the site. Time management is one of the biggest issues facing affiliates. What time-management tips can you offer your fellow webmasters? Again, do not be afraid to employ or partner with capable people and trust that they will manage their responsibilities. It is the only way to grow. How much time does it take to keep your sites updated? The man hours are considerable with over 12 full-time employees. How much time do you devote to social networking to drive more traffic to your site? We do employ a social networking person for Facebook and Twitter as well as a team of forum moderators to build the forum community, which has been integral to the success of the site. 65 AGE: HOMETOWN: LIVING IN: 35 Sydney, Australia Sydney, Los Angeles FAVORITE FOOD: I like everything! Growing up in Sydney you have a wide selection of multicultural cuisines. MUST READ BOOK: I was never much for reading, but I was brought up on movies and I have recently been enjoying the comic-to-movie adaptations. SITES: latestcasinobonuses.com latestpokerbonuses.com latestbingobonuses.com latestsportsbonuses.com bingo-reviewer.com 50/50 PARTNERS casinolistings.com WITH: casinoslots.net What prompted you to join the GPWA, and how has it helped you so far? It is always important to stay abreast of issues that develop in the affiliate community so you can be reactive to problem affiliate programs and issues arising in the industry, as well as spot like-minded individuals who can help in the success in my ventures. The GPWA has been helpful with problem affiliate programs, late payments, link development and copyright violations. You have been a member for nearly five years, but have just eight posts. Do you visit the message boards often? And what, if anything, would make you want to contribute more often? I don’t get involved in the day-to-day community goings-on of affiliates. I prefer to spend my time looking for value-adding services for my players and visitors. If you could have dinner with any five people, living or dead, who would they be? Tough question! Einstein, Freud, Darwin, Gandhi, Mandela. When you need to get as far away from work as possible, where do you go? Work never really leaves me and I don’t have a negative outlook on it. I am happy to travel all around the world, which I have been doing, and take work with me, whether it’s an hour poolside in Fiji or at a European café. How do your family and friends feel about the way you make your living? They think it’s awesome with the flexibility that I have. They are very proud of my success and I do try to share with them as much as possible. If someone were visiting you, what’s the one place you’d definitely take them to see? Sydney Harbour. What’s your all-time favorite movie? To be honest, I love movies and watch several every week and I have no one favorite. I tend towards science fiction and adventure, but enjoy all genres. What are three things that nobody knows about you? What a question! Ummmm, pass. . . . GPWA AFFILIATE INTERVIEW SERIES TIM GLENN tg12345 He’s a Golden Tee champ – but sometimes he’s just a goldfish Tell us about NoDepositBonus.cc. When and why did you start it? And what are you most proud of? The site started about five years ago out of a personal interest in no-deposit bonuses. I figured if I was interested in them, other people must be as well. I’m most proud of my oldest losing his first tooth the other night (red and green sprinkles for “fairy dust” under the pillow) and my youngest got his green belt last night (he wants to be a ninja when he grows up). His favorite joke at the moment is: Him: “Knock-knock.” Are there fewer no-deposit bonuses available in poker and bingo? Is the nodeposit business model is a good one for either poker or bingo? Definitely fewer in poker. Most bingo sites seem to have a no-deposit offer, but I make more money with casino sites so that’s where I tend to spend my time. What’s one thing you really want to do with your site right now, but simply haven’t had a chance to do yet? Getting additional languages up and running . . . almost there now, finally. Him: “MOOOOOOOOOOOOOOO!” How long have you been involved in the industry? What drew you to the business? About five years. I noticed an “Affiliates” link one day at the bottom of Club Player Casino when I was playing their $65 free chip. That’s how it all got started. He’s “three and three-quarters.” I tend to use parentheses and quotes a lot, sorry. (We’ll all just have to “deal with it.”) Are you a full-time online gambling affiliate, or do you hold down another job as well? Full-time since November 2008. Me: “Who’s there?” Him: “Interrupting cow.” Me: “Inter-” Are you still thinking about adding live dealer and/or mobile sections to the site? Yes, still thinking about a mobile/live section . . . just haven’t gotten around to it. You list/offer hundreds of no-deposit bonuses on your website, and you grade each one of them. How do you assign your grades? And how do you keep track of all of those no-deposit bonuses? I grade the bonuses based upon how much money I make, to be honest. I lose track of bonuses all the time . . . some programs are better than others at updating me when they decide to make a change. Some just make a change and then let me know after I get a ton of player complaints. Usually, it goes like this: Me: “Hey, I’ve been getting complaints that ‘NDBN13’ isn’t being accepted.” Random Aff Manager: “Oh yeah, we stopped accepting that.” Me: (sigh . . .) GPWA Affiliate Interview Series What do you like about the industry? The money and traveling to conferences . . . hanging out with some of my favorite affiliate managers . . . drinking mojitos at 10 a.m. under the guise of “networking.” What don’t you like about the industry? The seemingly random unannounced changes that occur on a regular basis with respect to my bonuses. When the U.S. DOJ seizes funds from processors. Just having to trust that I’m not being “shaved,” since there’s no real way to police that. What surprised you most about the industry? How much of it is based in Israel. How do you manage your “to-do” lists? Do you use any special software to help you out? StatsRemote is a lifesaver. The rest of my daily tasks I have to slog through on my own. . . . Time management is one of the biggest issues facing affiliates. What timemanagement tips can you offer your fellow webmasters? None. My timemanagement skills are atrocious. I was in the middle of some hugely important work, so I interrupted myself and spent 20 minutes answering interview questions, then surfed memebase.com for an hour, had coffee with my wife, then the kids woke up, so I got them ready for school, drove them to school, stopped off at Starbucks, had a skinny vanilla latte, figured I could use a shower too, had breakfast, answered a couple more interview questions, checked out the Leafs message board (lost to the Bruins last night, again), lamebook.com, Facebook, remembered what I was doing prior to getting these interview questions, finished that, came back to this, then underdogsports.net for a while – I’m like a goldfish. Look at this side of the bowl, look at THIS side of the bowl, LOOK AT THIS SIDE of the bowl. I’m so easily distracted it’s crazy. ADD for sure. My only tip would be to avoid the Internet entirely, but that seems somewhat counterproductive in our business. How much time does it take to keep your site updated? Depends on how many updates there are, I suppose. You recently characterized yourself as “a former problem gambler.” How did you deal with that problem? Do you gamble at all now? Is it difficult to continue to work in this industry, considering your personal history? Online, I stick to the $1.35 9 a.m. Turbo knockout tournament on PokerStars. My balance tends to fluctuate between $50 and $100. One day, I’ll win the whole thing and buy a new pair of shoes or a waffle-maker. I go to Vegas once a year during WSOP and play the deep stack tournaments and a considerable amount of pai-gow, but I stick to a budget. Gambling is not a problem for me anymore (no, seriously, it’s not – don’t giggle). Except for Grande Vegas and their stupid policy of paying affiliate commission into a player account . . . I’m a VIP there. 67 AGE: HOMETOWN: 39 Toronto LIVING IN: Toronto Suburbs FAVORITE FOOD: Sushi MUST READ BOOK: SITE: The Foundation Trilogy, by Isaac Asimov NoDepositBonus.cc You created quite a stir in the forums a few months back when you stated that what gambling affiliates do is the equivalent of pushing “crack/cigarettes/booze. We’re drug dealers.” How do you reconcile the moral qualms you have with the industry and the fact that promoting gambling is your business? And do you draw distinctions between poker and casino gambling? And if so, what are those distinctions? I have no moral qualms, obviously. Gambling is a “Stupid Tax” and some of us pay more than others. Poker is not gambling. It’s math/psychology with a rake. What responsibility do operators and affiliates have in terms of problem gamblers? What steps should be taken by both affiliates and operators to help people who have problems? Take the money slowly so they can keep playing. What prompted you to join the GPWA, and how has it helped you so far? I was a newbie and figured that I needed to join it. The list of affiliate programs and the “new posts” feature on the boards are good. Definitely helps me stay in touch with what’s going on. You once let it be known that you placed second in the world in the 2003 and 2004 Golden Tee World Championships. Please describe the game, for those who may not have played it. Do you still compete at a high level? Yes, I still play Golden Tee. It’s the golf video game with a trackball that you see in bars. If you’re really curious, check this out: http://gpwa.org/249 – and then check out the related videos. Just so you know, the World Team beat Team USA that year . . . and, with two kids now, I don’t compete at the level I used to. When you need to get as far away from work as possible, where do you go? Shoeless Joe’s to play Golden Tee. How do your family and friends feel about the way you make your living? I don’t tell them much, to be honest. If you were a Star Trek (or Star Wars) character, which one would it be? I’d hope to be Captain Kirk or Commander Riker . . . they get all the alien babes. If you won $50 million in the lottery, what would you do with the money? Spread it around to my family, buy a bigger house and a car with doors that open up. “ I’m so easily distracted it’s crazy. My only tip would be to avoid the Internet entirely, but that seems somewhat counterproductive in our business.” Affiliate Manager Interview Series MEET THE AFFILIATE MANAGERS Say hello to Katy Stafford and Anthony Prissman! Anthony’s based in South Africa and insists that Cape Town “has to be the most beautiful city in the world,” and Katy’s in Malta, where the “sun is . . . always shining and the sea is on your doorstep so it’s a world away from London.” Katy joined InterPartners in September 2010 and Anthony joined Fortune Affiliates after returning to South Africa from Australia. One of them has been thrown from a horse and the other has been chased by a guy with a shotgun. Which is which? Keep reading! KATY STAFFORD InterPartners InterPartners offers two casinos (InterCasino and VIP Casino), a poker room (InterPoker) and Parbet, which offers both casino and poker products. What do affiliates need to know about these brands in order to effectively market them to their players? InterCasino is our flagship and award-winning brand. Launched in 1996 it is one of the pioneers in online gaming and has one of the best retention programs in the industry along with over 300 games available in the following languages: English, French, German, Italian, Spanish, Dutch, Danish and Japanese. VIP Casino is our alternative offering, which is currently in the process of being repositioned as a luxury casino brand. InterPoker is one of the most trusted and popular names in online poker and offers easy navigation, fantastic software, an impressive variety of games, a massive tournament schedule and a 200% welcome bonus up to €1,000. “I am in charge of all InterPartners payments and I run a tight ship so affiliates can be guaranteed that payments are prompt and sent in a timely manner.” What distinguishes InterPartners from other online gaming affiliate programs? Our commitment to all affiliates whether small and new or large and established; understanding the value of con- Affiliate Manager Interview Series versions and player insights to deliver optimal player retention strategies; trust and reputation earned from our longevity within the industry; an experienced team willing to assist affiliates wishing to develop marketing channels they don’t currently excel in or offer such as e-mail, SEO, PPC, etc. We also have our very own mobile app for affiliates on the go! Early in 2011, you rebranded your program, changing the name from PartnerLogic to InterPartners and relaunching your program using Income Access software. What was the motivation behind that change? How has it affected the affiliate experience? And how have affiliates responded to both the rebranding and the rebranding process? The main motivation was to give our affiliates an easier back office to use, with better reporting, creative library and more functionality. We changed our name to be more in keeping with our flagship brands – InterCasino and InterPoker – and to create a new brand identity in keeping with the rebrand of these products. I don’t believe we had too many obstacles during the rebrand process – in fact I think it was far smoother than other rebrands I have seen. The new system has made the affiliate experience far easier and manage- able – one of our main concerns with the previous system was the user experience and I believe that we have achieved this with both the front-end website and the affiliate back office. Affiliates have responded well to the change as the new system is both easier to use and has far better functionality than PartnerLogic. You offer a revenue share model, with increasing percentages (up to 50 percent) based on the amount of revenue an affiliate brings to your sites. Some other programs offer increasing percentages based on the number of players an affiliate brings to their sites. Why did InterPartners choose to base revenue share percentage on revenue rather than the number of players an affiliate has brought to your properties? We believe that quality over quantity is a better model to use and also enables the smaller affiliates to grow over time. Obviously, numbers of new users are important but we have been able to build better relationships with our affiliates in the last 10 years using the revshare model. However, we have also started to offer CPA and hybrid deals, which was something that we were unable to do with the old PartnerLogic system. 69 Some brands, especially those focusing on Europe, use sports betting sites to acquire customers for their other products (casinos, poker, etc.). That’s not a path you’ve chosen to travel. What advantages, if any, do you feel you have operating without a sportsbook? What disadvantages do you feel you have working without a sportsbook? Advantage – focus entire efforts on maximizing our expertise and affiliate revenue for the higher player value casino traffic. The main disadvantage of not having a sportsbook is not being able to cross sell to our other products, but it is something we are looking into so watch this space! Go ahead and pull back the curtains a little bit. What three things would affiliates be surprised about regarding how InterPartners – or any affiliate program – operates? 1.We always give top level service to affiliates regardless of their performance or how long they have been with us – all affiliates are treated as VIPs. 2.The phenomenal amount of time we spend on Skype and other messaging apps daily! 3.The amount of work that goes into delivering fresh creatives, marketing tools, promotions and newsletters for our affiliates monthly. You have a background in psychology and criminology. So how did you get into the online gambling industry? When and where did you get your start? Do you think your university work helps you in your role as an affiliate manager? If you had to assess the mental well-being of the industry, what would your diagnosis be? I started working for InterCasino back in 2005 and so have been with the company for over six years now. This was my second “London” job out of university. I started in a support/admin role and moved up into office management and finance. Finally, with the office relocation to Malta, I took the opportunity to move into the marketing side of things as I believed both my long-term experience with the brand and company together with my reporting/finance knowledge would be a good fit for InterPartners. I think the psychology part of my university course is helpful in looking at the psyche of our players but also how they would be best retained, what promotions work better for them, etc., which can only be benefi- cial for any affiliate manager. With regards to diagnosis, as the iGaming industry in my eyes is still in its infancy, it’s quite difficult, but inasmuch as mental wellness is defined by emotional well-being, the capacity to live a full and creative life, and the flexibility to deal with life’s inevitable challenges, I don’t think our industry needs to worry too much. As an affiliate manager, ultimately I feel my financial background within this company helps me in this position as I gained a totally holistic view of revenue generation and fundamentally I am here to help affiliates generate more money! How long have you been working with InterPartners? How is it different from your previous positions at other companies? I have been working for InterPartners since September 2010. This is my first role as an affiliate manager. This is definitely a more “hands on” position and is great as I get to deal with people on a day-to-day basis and foster relationships that I hope will flourish. What do you know about the industry now that you wish you knew when you first started? How fast paced it is and how everyone knows everyone – it’s like a massive family! How do you ensure that payments are sent out on time? And when do your payments go out? Payments are sent automatically within the first seven days of the month (as long as the affiliates have entered their payment preference in their InterPartners account). I am in charge of all InterPartners payments and I run a tight ship so affiliates can be guaranteed that payments are prompt and sent in a timely manner. Where do you think the industry will be in five years? It’s hard to say as there is so much regulation going on in various countries. I would love to see a return to the U.S. marketplace (as does everyone!) but for the time being I think there are loads of opportunities in other markets such as South America and Eastern Europe. There is so much more to develop and grow and I just hope I will still be part of it in five years. What’s the best movie food? Hot dogs and pick-n-mix. What is the last book you read? Did you enjoy it? And did you read it on an ereader? Or do you need to have a copy of the physical book in your hand? I am a big reader and so I normally have a couple on the go at the same time. At the moment I am reading We Need to Talk About Kevin and also a biography of Mary Boleyn – sister of Anne. They are both really interesting – very different from each other but variety is the spice of life! I am very much a physical copy kind of girl – most of my books have been read again and again and there is nothing better than seeing a well-worn book on a shelf. How would you describe life in Malta? If someone comes to visit you and they’re in Malta for the first time, what do you make sure to show them? I really enjoy life in Malta. The sun is generally always shining and the sea is on your doorstep so it’s a world away from London. There is also a really big expat community and my work colleagues are all close friends so you never get bored for company. When people come and visit, the top spots I normally take them are Valletta and Mdina – gorgeous architecture and amazing little restaurants. Also on the top of the list is Muddy Waters, my local bar and the best in Malta! What is your favorite movie? Léon: The Professional (1994). If you had a theme song, what would it be? “My Sharona” – played live in Muddy Waters. . . . If you could go anywhere on vacation, where would you go? India – I have never been and would love to travel around. If you could have dinner with three other people, living or dead, who would they be? Stephen Fry, David Thorne and Jane Austen. What would you do if you just inherited a pizzeria from your uncle? Eat a lot of pizza! What are three things that no one knows about you? I am slightly obsessed with processed cheese, I can barely walk in heels and I was once thrown from my horse into a ditch. Affiliate Manager Interview Series ANTHONY PRISSMAN How did you get involved in online gambling? Why did you choose to join the Fortune Affiliates team? I had been living in Australia for four years and decided to return to South Africa with my family. Fortune was looking for someone who had experience in international markets who had both customer service and marketing skills. My profile met their requirements and the rest is history. I knew very little about the online gaming industry but had done some research and realized that Fortune Affiliates had the reputation as a leading program held in high regard. That, plus the fact that Fortune Affiliates represents one of the oldest and most established casino clients, Fortune Lounge, convinced me that it was an opportunity of a lifetime! “Our systems and month-end processes are a well-oiled machine. We understand the importance of giving our affiliates what is rightfully due and payable on time for all their hard work. We have never paid our affiliates late.” What do you think the three greatest challenges facing the industry are right now? And what would you do to solve them? This is a tough question to answer as the industry and global economic climate both present many challenges for 2012. • Regulatory landscape – developing and implementing new business models for each landscape, tackling one market at a time and not diluting our focus. • EU policy and economic meltdown of many major economies – unfortunately this is not something we can solve but we all have a role to play in trading through volatile times. • Market saturation – focus on strengths, differentiation and niche markets. Affiliate Manager Interview Series Fortune Affiliates If Fortune Affiliates discovers someone is spamming to promote a Fortune brand, what steps will be taken to stop the spamming? We have zero tolerance for spam in our business. As per our terms and conditions affiliates found guilty of spamming will have their accounts locked until the case has been fully investigated. Repeated spamming will result in the closure of their account. It is mandatory that all affiliates sign our no-spam guarantee as part of the registration process, in which they undertake not to send unsolicited mail. Fortune Affiliates offers a variety of brands to promote. How difficult is it for you to give each brand equal love? Do you find yourself steering affiliates to one brand over another? As a company equal effort goes into building out each brand. We had four additional brands which Fortune stopped promoting. These brands were our U.S.-focused brands, which we did not deem worthwhile to continue with for a number of reasons. By only having four casino brands, we are able to give the resources and focus to each and build up the brands in markets where there is a good fit. Cultural nuances play a big role in which brands suit markets best and this is where our differentiation is key to building high-profile, highconverting brands which players love and stick to over time. Do the target audiences for your various brands differ? Our target audiences don’t differ for our various brands. We position our brands in a way that can cater to various demographics through smart marketing techniques. Different channels require bespoke offers and different approaches which our marketing team works on constantly to drive as many visitors to our brands to facilitate depositing players. Royal Vegas is definitely our flagship brand and has excellent brand recall and attracts a broad player base in almost all marketing territories. Some companies use sports betting sites to acquire customers for their other products (casinos, poker, etc.). That’s not a path you’ve chosen to travel. What advantages, if any, do you feel you have operating without a sportsbook? What disadvantages do you feel you have working without a sportsbook? Fortune has always been a very focused group. We take the view that we should do what we do right and not spread ourselves too thin in any area. I do think that sportsbook has presented great opportunity to many operators and helped to fill the funnel but we apply our minds to understanding how to offer brands for the casino vertical which brings in the right player the first time. Investing resources into offers, branding and player experience in the casino brands has proven to both ourselves and our affiliate partners that player loyalty, conversion and retention are the result of these efforts, and we have not diluted our focus or strategy away from this vertical. We have done extensive investigation over the years regarding the sportsbook crossover scenario and have always come back to the same conclusion: Let’s stick to the knitting and do what we do best. Adding a sportsbook to our bouquet would add complexity and is a very different business from what we are in. We know that sportsbooks have produced great results for some operators in certain markets and have helped act as a buffer where casino acquisitions have been hampered. Go ahead and pull back the curtains a little bit. What three things would affiliates be surprised about regarding how Fortune – or any affiliate program – operates? 1.Professionalism and integrity. 2.Our expertise – making us leaders in keeping ahead of industry trends. 3.The amount of money that can be made. 71 You offer a revenue share with increasing percentages (up to 35%) based on the number of “new active accounts” affiliates deliver. How do you define what a “new active player” is? Are they players who have been delivered that month? Or can a player who was delivered months earlier who is still playing be considered a “new active player”? Affiliates earn revenue share on total actives. This is made up of players brought in during previous months plus those brought in during the current month who have purchased and wagered, which we define as new actives. The bottom line is that affiliates will get paid for ALL players they bring in. Affiliates are generally not fans of new active player terms. While they understand affiliate programs want their brands promoted, they also know that online casinos/poker rooms/bingo rooms, etc., are a critical part of the conversion process. And they don’t want to see their revenues reduced by a site’s inability to convert players. What was the thought process behind implementing this term? And how do you address affiliate concerns that their income could be dramatically reduced through no fault of their own? We pay all affiliates revenue on the basis that a player purchases and wagers regardless of the time period. The “new active player” term is merely an internal means of measuring the players who came in/or who purchased and wagered in the same calendar month. This by no means affects the earnings of affiliates because regardless of the time frame in which players purchase and wager they will still earn their entitled revenue share. Some affiliate programs offer increasing percentages based on the amount of revenue an affiliate brings to their sites. Why did Fortune Affiliates choose to base revenue share percentage on the number of players delivered rather than the revenue generated by affiliates? This was a decision made many years ago when our earnings models was established; it facilitates an ongoing partnership. It was considered the industry norm and we chose to go with it. We reward affiliates monthly for the players they bring into our business, hence we choose a tier model instead of a value-based earnings model. Our business relies on constantly filling the funnel with new players and this model has worked for our partners and for us, so we have chosen to stick with it. What steps has your program taken to ensure that affiliates will be paid on time? Our systems and month-end processes are a well-oiled machine. We understand the importance of giving our affiliates what is rightfully due and payable on time for all their hard work. We have never paid our affiliates late and endeavor to get payments out by the 15th of every month even though our T&Cs stipulate payment on or before the 20th. If we do have problems we always keep our affiliates in the loop and well informed. In your mind, what’s more difficult, attracting players or retaining them? There is no clear answer to this question and I confidently can say that we do well at both but ALWAYS strive to do better. Both present massive challenges and you have to be ahead of the game in both areas. We never acquire enough and we never retain well enough. This drives our business to constantly do things better and smarter with the ultimate objective of making our clients and partners more money at the end of the day. How can affiliates help in retaining players? There is no doubt that affiliates have a massive role to play in retaining players. I have always said that affiliates are our billboards and ambassadors for our clients’ brands. Affiliates who have websites with relevant content which attract repeat visitors and who have an online community have the ability to give players far more than just an opening offer with a call to action. Where players enjoy the ongoing retention efforts with the help of affiliates through promotions, tournaments, events and more, we experience an increase in the “stickiness factor,” which helps keep players loyal to our brands. How long have you been at Fortune Affiliates? What is the biggest difference between when you started and now? I have been with Fortune affiliates for three and a half years. In my opinion our biggest change has been in building a team of affiliate managers who have knowledge of what it takes to be an affiliate. It’s all about sharing knowledge and helping our partners build their businesses. Historically affiliate management was a “relationship management function” where now the business is far more proactive and takes a value-added approach. Our program builds on this mission to constantly add value to our partnerships. What distinguishes Fortune Affiliates from other affiliate programs? Affiliate programs today have very similar offerings across the board extending to management tools and reporting and tracking tools. What distinguishes us from other affiliate programs is our people – the relationship managers who build long-standing relationships and make our affiliates more money. Our long-standing partners will bear testament to the fact that over time, in a number of cases, affiliates earn more with Fortune. Did you enjoy the World Cup being in South Africa? What was your favorite thing about the experience? The opening goal of the 2010 World Cup scored by South Africa set the nation alight. This will never be forgotten. If someone is visiting you in South Africa, what’s the one place you have to take them to see? Cape Town, which has to be the most beautiful city in the world. What would you do if you just inherited a pizzeria from your uncle? I love cooking and people so this would be a perfect fit. My beautiful kids and I would make the best pizza and pasta in town. What’s the best movie food? And why? South African dairy milk chocolate. Nothing else comes close to SA chocolate. Our cows are built differently! What is the last book you read? The last book I read was Daniel Silva’s The Rembrandt Affair. All Daniel Silva’s books are so well researched and you get lost in his world from page one. What is your favorite movie? And why? Schindler’s List – the movie teaches one to never forget the past. If you could have dinner with three other people, living or dead, who would they be? Jamie Oliver – this guy lives with such passion and loves what he does to the core. My late mom – left me too early in life. Billy Joel – to add some of that soul music. What are three things that no one knows about you? 1.I love to sing. 2.I love to cook . . . food is my passion and I could happily land up owning a restaurant one day. 3.At the age of 12 I was chased off a farm by a farmer with a shotgun when he caught me riding a motorbike across his property. GPWA SPONSORS M eet the organizations whose generous, enthusiastic sponsorship helps keep us strong. 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It’s no secret that I am a strong advocate for the smaller affiliate and Giggles really exemplified what it means to be a GPWA member. Although Pat was what almost all of us would term a small affiliate, she knew that she could visit the GPWA for help, guidance, support and all-around camaraderie (besides having a good laugh), and she would be treated with respect no matter how much money she made or how much traffic or how many players she could send to properties. Pat was a member of many forums, although she was quite a bit more active in some than others. Anyone who ever came into contact with her was always greeted with cheer and a sense of humor that was both fresh and uncompromised. Pat’s screen name, “Giggles,” came from her days as a truck driver. It was her CB handle. But it was also a great way to describe the joy she brought to people’s lives and these forums. She had a way of cheering people up. No matter how they felt prior to talking with her (or reading her posts), rarely would anyone have an interaction with Giggles without feeling better about their current situation. She wrote poems for people on their birthdays. She always had a joke to cheer people up. And she was always able to laugh at herself. She also loved being a member of this community. “I just love everyone to death, I have such a great time here, laughing, flirting (one of my favorite things to do) lol, and learning,” Pat once said about the GPWA. “It’s priceless the knowledge that comes out of this site, there are a few members here that I swear are at a genius level!” Pat also loved animals. One of her dreams was to open her own animal rescue foundation. “I plan on doing this in the future, [opening] some kind of animal rescue,” Pat once said. “My life is not complete if there are not animals included, all animals -- except spiders!” Here is just a sampling of what some of her friends had to say following the news: Cash2c: A wonderful woman indeed! My thoughts and prayers are with the family. GFPC: Whenever I think of animals now I will always remember Giggles - she was a true cat fanatic just like me. AK: Pat was one of the finest people I recently had the opportunity to do business with. ElaineGardiner: Pat was always so full of life with her jokes and poems. Bonustreak: Pat always had such nice things to say about everyone, and she always made sure to cheer those down up. The above is just a portion of what people had to say about her. She touched so many lives with her kindness and she will be greatly missed. What a lot of people didn’t know about Pat was that she was constantly fighting her own battles with illness, but rarely did she ever let anyone know that she herself was having a bad time because she was always more concerned for others no matter what she felt like. Sadly on the evening of October 20, 2011 it became too much and she passed quietly in a hospital room surrounded by her close family. She is survived by her husband of 20 years, Gary, and by three children: two boys, Jamie and Branden Coneita, and one girl, Toni Cunningham. The family did not have a public memorial service but instead had a private gathering at their neighborhood church. In subsequent conversations with Gary, as well as posts and talks with Branden, the one thing that was apparent was how much Pat truly loved everyone and, as Branden put it, “She always loved writing and finally got her chance to do it on here. You guys also gave her a chance to spread her love and laughter around the world.” Goodbye, Pat. Rest in peace. In memory of Giggles Wall of Shame By J. Todd, Executive Director, APCW F or many, many years, the loudest opponents of regulated online gambling were the executives of the major landbased casino companies. These casino companies were terrified that online gambling would siphon away funds from their properties. Why would anyone go to Las Vegas or Atlantic City when he or she could simply gamble on their computer at home? Of course, that belief proved to be foolish. People still go to Las Vegas and Atlantic City (well, not as much to A.C., but that’s another issue) because they enjoy the casino experience. It’s not strictly about gambling. Slowly but surely, the casino industry has come out to support some form of Internet gaming regulation and legalization. The American Gaming Association is a major proponent. So is Caesars Entertainment, which now operates online gaming sites in the U.K. MGM Resorts recently reached an agreement with Party Poker. Hell, even Steve Wynn had a deal with PokerStars before the Department of Justice came along and rained on everyone’s parade. That brings us to this issue’s Hall of Shame inductee, noted curmudgeon Sheldon Adelson. Adelson, APCW’s Wall of Shame 78, is the Chairman and CEO of Las Vegas Sands. According to Wikipedia (which is never wrong), he is the 16th-richest person in the world and has a net worth of over $21.5 billion. He is a true gambling giant and no one denies his impact on the land-based casino industry. His views on the online gambling industry, however, leave MUCH to be desired. He told Washington, D.C. insiders in early December that he opposes any federal legislation that would legalize and regulate online poker. His opposition led a Las Vegas Sun reporter to proclaim that federal legislation had no chance of passing as long as Adelson wasn’t on board. What hurts about Adelson’s stance is the fact that he is BFFs with previous Wall of Shame inductee Sen. Jon Kyl (April 2010). Adelson has a prime opportunity to influence Kyl’s views on online poker. But instead of toeing the line with the rest of the land-based casino industry, Ol’ Sheldon decides to pull the “what about the children?” card. children spend time online. What you can do, however, is employ the best possible measures to try to prevent it. That is done through legalization and regulation. And you know what else won’t go away? Underage gambling in brick-and-mortar casinos. Would Adelson ever shut down The Venetian or The Palazzo because a couple of 19-year-olds were able to sneak onto the casino floor and play some slot machines? Of course not. So then why is it acceptable for him to advocate denying millions of Americans the right to play online poker simply because some teenagers were able to deposit money on a site? Of course, underage online gambling is a concern. And underage gambling is going on right now. But what’s the best way to combat the problem? It’s definitely not by looking the other way. It’s outright hypocrisy. And it’s even more hypocritical if you believe (like I do) that Adelson’s stance on Internet gaming has nothing to do with protecting children. It has everything to do with Las Vegas Sands being behind their competition. Unlike Caesars and MGM, Sands isn’t cultivating relationships with the online gambling community and should regulation happen, the company would severely be behind the eight ball. Let’s face facts. Underage online gambling will never fully go away. There will never be a foolproof system to stop all of it. It’s really up to the parents to monitor how their Now, these relationships aren’t bearing fruit just yet. But they will bear fruit. And assclowns like Adelson will have no one to blame but themselves.