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
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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
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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!
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FAVORITE FOOD:
MUST READ BOOK:
SITE:
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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.
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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.
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obituary
75
In memory of Giggles
PAT CHAPDELAINE 1962-2011
By Rick (universal4)
Last October a good friend and valued
member of the GPWA and a number of
other online forums, Pat Chapdelaine
(Giggles7p - Triple777s), passed away.
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.