 going to go forward on because but first I'll do a roll call because we're holding this meeting virtually. Good morning, Commissioner Bryant. Good morning, I'm here. Good morning, Commissioner Skinner. Good morning. Good morning, Commissioner Maynard. Good morning. And I just want to note that Commissioner Hill is here now. Thank you, Commissioner Hill. You're off site. And you'll be an activist where I explained to our applicant. And I won't I won't be affirmatively calling on you. But I know you'll speak up as we go along. Okay, and we're thinking of you today, Commissioner Hill. Thank you. Okay, excellent. Thank you. All right. So we'll get started on the call of the meeting today is January 13. And this is meeting public meeting number 423. Today, we will be hearing from our latest applicant for an untethered category three, sports play during license. Welcome them. And today's presentation will be from digital gaming corporation USA will probably be referring to us DGC throughout the day. And welcome. We will be starting with this item number four on our agenda. And that's to your presentation and a demonstration of your technology if you have that. And if you wouldn't mind introducing yourselves. This, we're so pleased to see so many representatives. And in order for us to keep track, be really helpful to understand your roles as well. So thank you so much. Good morning, Madam Chair. Thank you very much. Shall slide out now when we got up so enthusiastically. Amazing. Thank you. Well, that was your slide. That's good. That was the introduction slide here. So it's a good morning, Madam Chair. Good morning to all the members of the Commission and staff. I am Bruce Ward, I'm Executive Vice President of Operations for Digital Gaming Corporation USA DGC, as you say. And we're excited and honored to be able to present ourselves and our business to the Commission and by extension to the Commonwealth today. And we welcome any questions the Commission may have at any point during the presentation. As I know, as occurred in prior sessions, if a question should require us to share information which we believe would fall within the exceptions to the public record statutes, we would respectfully request that this information be considered for an executive session. I'd like to begin by thanking all of you for your effort and commitment to moving this process forward as swiftly as you have. And for the time today, I appreciate that you've all been working tirelessly this week, last week, and in the months leading up to this, to go through all the applicants' presentations. That's been a massive undertaking. So thank you for that. To start, it's my pleasure to introduce some colleagues who are representing Digital Gaming Corporation. I'm going to start just by introducing the folks that are talking alongside me today. Within the DGC team, we have Shal Bart, Head of Operations, Gary Ehrlich, Corporate Compliance Officer and Melinda Taubach, who's Director of Human Resources for North America. We also have our parent company, Super Group Holding Company, otherwise called Super Group, represented here as well. And doing a short introduction will be Richard Hassan, President and CEO. Our agenda, Shal, if you'll just move to the next slide. Our agenda this morning is straightforward. We'll begin with a brief introduction to Super Group Holding Company from Richard, followed by an overview and background of Digital Gaming Corporation. I'll then touch on a few key areas for my application before we dive into a review of the Bitway product as it exists today. In our application, our file application, we introduced you to our then Bitway brand partner, Super Group. We also noted that Super Group had entered into a definitive written agreement to acquire a full ownership of DGC, subject to obtaining the required gaming regulatory approvals. And the transaction was expected to close during Q1 of 2023. On January 1 of this year, last Sunday, although it feels like a lifetime ago already, Super Group and DGC concluded this transaction, making Super Group the 100% owner of DGC. This was a long process, and we're very excited and proud to finally be part of the global Super Group family. Super Group team brings with it a wealth of experience and technical expertise in sports betting worldwide, as well as financial strength and marketing power. So on that note, I'm going to turn over to Richard Hasen to get us started with an introduction to Super Group. Over to you, Richard. Thank you, Bruce. And thank you very much. And the commissioners take a Bruce sentence for having us here. And as Bruce has said now, I'll give you a brief overview as to the Super Group and how we fit into the DGC story. As Bruce, mentioned, I'm Richard Hasen, the president and CEO of the Super Group with a number of years in the industry. So as Bruce mentioned now, Super Group, we're a leading online sports betting and eye gaming operator. We have a very diversified global business and global footprint. We've been providing first class entertainment to the worldwide sports betting and gaming community for over 20 years, for over two decades. On the sports betting side, with Petway, we offer a single brand online sportsbook. And alongside this, on the online gaming side, on the spin side of the business, we operate a multi brand online casino offering, which includes leading brands such as Jackpot City and Spin Casino. Last year, January, at the end of January 2022, we visited the Super Group on the New York Stock Exchange and have been operating as a listed business for coming on to what is both on one year at this point in time. We are a highly cash-generated business. We run a profitable business across all these markets that we operate in. And we have a debt-free balance sheet. So we are, we're generating cash from running this business across numerous markets around the world. As Bruce mentioned, in January this year, so the 1st of January, we completed the acquisition of BGC and are very happy to have BGC now a part of the Super Group. Since 2019, BGC has held the exclusive rights to operate the Betway brand in the US. And as I say now, BGC is now part of the Super Group. Bruce will go into more about BGC and the footprint in the US when we revert to his presentation. Will you please switch sides? Thank you. So to go into some of the scale of the Super Group, today we have just shy of 4,000 people in our global team with about 22 of those teams operating in country. And the reason that's important is while we're a global business, we're made up of a number of local offerings in many markets around the world. And this is looking at the details, each and every market that we're operating in and understanding what each customer, each market is after. So it's looking at a global business but offering as localized product using this global Betway brand on the sport side in every single market that we operate. Today our technology allows us to be live in 29 different languages. And outside the US, we hold licenses and over 20 jurisdictions around the world. So this is in Europe, in Africa, in the Americas, largely, obviously, in the US from that, so North America, Central Latin America here. As I said, Bruce will go into the US specifically, I'm talking here predominantly about the rest of the world for operations. Like I said earlier, the business is truly global. And it's not a one size fits all business. We localize in the offering, we localize in the teams, making sure that our product is very specific to each and every market that we operate in and giving the very specialized form of entertainment, making it as individualized and as bespoke as possible in every single market we operate in. This will be no different as Bruce will go into when you're looking at the US and each of the states that you see as the idea that's currently eight states. The BBC is running the Betway brand. And they have a runway and a roadmap to go up to an initial 12 different states in the US more that will come data on the presentation. So what we've got here is just a representation of how data analytics and data sits at the core of the business, at the core of Supergroup. And what we believe we have here really gives us a competitive advantage that has been refined and grown and developed over the last 20 plus years. So in terms of what this flywheel depicts here, as an overview of a business, we will look to bring a new customer in or to acquire a customer at the most effective cost possible, certainly CPA, the cost acquisition, bringing a customer into the ecosystem. Once a customer is in that system, we would like to give each and every customer the best form of entertainment possible. And like I said, this is providing as bespoke and as personalized as engaging and offering as possible. What this does, it needs to having very good retention rates and reduced churn, which of course is one of the key metric by which we run this business. And all of this going back to the core is underpinned by data and the use of data to provide this offering that I'm referring to. Alongside this, since extensive sponsorship and marketing, which was reinforcing the messaging, which is contributing both towards acquiring more customers and then keeping those customers in the ecosystem once they are there. And of course, as we'll look at on the next slide, while we're using data on acquisition and retention, data also plays a very pivotal role in looking at the group's responsible gaming strategy and how we ensure that every customer within the ecosystem is enjoying the entertainment and engaging with us in a very safe and secure environment. This is a key part of the business. What we have here on this page is a few examples of the types of tool that we may use in different parts of the world. And again, that's similar in response to gaming will reflect in what Bruce and Jim will go into later. We consider ourselves real leaders in the space. We have significant resource in our business, focused on fraud, on risk and compliance, and on these responsible gambling elements of our offering. So of course, we do a lot of marketing with the single brand on the back side, plus of course, the multi-brand casino offering. And what we've done over many years, we've optimized this multi-channel approach to marketing, and been able to build the single premium sports betting brand, which has become synonymous with global betting. What that means from our perspective is every time we do a brand partnership or a sponsorship, be that in the US or non-US, we are looking at that from a global level perspective, and we have the ability to amortize that spend and that investment across the globe. So what that means is that we have significant brand recognition across multiple markets and across multiple countries around the world. This has enabled us, along with DTC, to have the brand launched in the US, where people are already familiar with the brand, because of this global view of the brand across the multiple sports that we have the brand partnerships with. And what we have here is just a quick overview. Of course, Bruce will go into all of this in a bit more detail, but to give a high-level overview here, today, for our single sports betting brand, that way, we have over 60 brand partnerships running across more than 10 countries. Of that portfolio of 60, 14 of those are in the US again, that will be for US customers, potential customers, but of course, the global customers that we have across our footprint. And this is not a one-size-fits-all, it's how we localize a product. This is numerous different sports, numerous different esports, and again, finding something for all of our customers to engage with across the sports betting portfolio. So in wrap up, I'll just say that we're very happy to have BGC a part of the supergroup. As Bruce mentioned earlier, it's taken a while since our announcement many months ago, but now we're really happy to have BGC a part of the group and for us to work with them as they continue to grow across the US. Thank you, Richard. Thanks, Charlotte. We can hop onto the next slide. Just to drill down a bit and refocus back on digital gaming corporation, a little bit of history, since its inception in 2013, DGC has offered innovative and creative suites of first class digital casino content. The driving force behind our initial success was the establishment of the iGaming product development division referred to internally as our B2B business division. And in support of its B2B business, DGC holds licenses in Pennsylvania, New Jersey, Michigan, Connecticut, and also in our Ontario. On the business to consumer side, which is the Bedway side, which is where most of our focus is today, digital gaming holds licenses in Pennsylvania in sorry, sidestep. In 2019, DGC entered its licensing agreement with a subsidiary of supergroup for the exclusive rights to the Bedway brand across the United States. It's culminated in DGC Bedway receiving its first license and taking its first bet in the state of Colorado in March of 2021. Since that time, DGC has received an additional seven licenses and is now live in a total of eight states. The most recent of these being Ohio, where we took our first bet, along with the rest of the state on January 1st this year. Bedway is also live in Indiana, Iowa, Pennsylvania, New Jersey, Arizona, and Virginia. In addition, DGC runs a simple free to play product Bedway Big Pick, which is available in states where real money gaming is not committed and or where DGC does not yet have a license to operate. We're a relatively small team here in the US with around 100 United States based full time staff on the business to consumer side of things. All committed to developing the Bedway brand in the US. We have US offices in Virginia, New York, Las Vegas and New Jersey, along with a number of staff working remotely in Florida, New Jersey, Connecticut, and Massachusetts in Boston. I'm going to touch again on some of the partnerships that the risks has already referred to, but to begin with some of our existing licenses have been made possible through great partnerships we have in place with Boyd Gaming, the Quartish Companies, Golden Nuggets, GF Gaming in Colorado, and the San Juan Southern Paiute Tribe of Arizona. These partnerships also provide market access to an additional four states, and our teams are also continually assessing new market access opportunities where we believe it makes economic sense for us to do so. Working closely with a Bedway marketing and sponsorship teams, DGC has invested heavily in local sports sponsorships and partnerships over the last few years. And many of these partnerships continue over the next few seasons, showing our commitment to our partners and to the United States sports betting market in general. Current partnerships include the league partnerships with the National Hockey League, along with team partnerships with five professional hockey teams and eight NBA teams across the US. If we're successful in our application, these marketing partnerships will complemented by local sponsorships and digital spend in Massachusetts. DGC endeavors not only to gain market share, but also to grow the entire sports betting industry in the Commonwealth. These investments are important not only for the Bedway brand in the United States, but as Richard already pointed out, also to support the brand in many countries around the globe. And the supergroup transaction, as I already said, brings more than 60 additional partnerships. Some of the more prevalent of those are the partnerships across soccer, including our shared sponsorship with the United and betting partnerships across the EPL, La Liga and Bundesliga. And in tennis betway sponsors numerous men's and women's tennis tournaments around the world, including the Miami Open. This ensures that the Bedway brand is recognized not just in the countries and states where those leagues are active, but more broadly as well. And when it comes to responsible gaming, Richard also already referred to supergroups, ethos and their internal processes and systems to support responsible gaming. And that leads into DGC. As a business, we know that in order to build a long-term sustainable and socially responsible industry, responsible gaming needs to be at the core of what we do. To that end, our baseline responsible gaming framework includes staff training on responsible gaming for all new employees, along with annual refresher training and testing. Type registration controls to make sure only customers 21 years or older are able to sign up and access the product. Ensuring that all brand content is designed to appeal to consumers who are of legal age only. Ensuring that audience controls where we have them are implemented across all channels so that the content isn't viewed by anyone who isn't 21 or older. We have a predictive customer intervention program, which to proactively identify customers who are at risk of betting irresponsible. This is based off 22 different data point triggers that help us identify potential problems. For example, people who are extending their time on device or changing their betting patterns and triggers like that. And as Shar will take you through in the product in just a moment, we have prominent teaching of the helpline numbers and RG control tools built into the product so the customers can manage their deposit limits, time limits, loss limits, cool off periods, can close their accounts, can manage self-exclusion all a click away from the homepage. In the event that DGC is awarded a license, we will explore partnerships as suggested by the Massachusetts responsible gaming framework, including partnerships with the Massachusetts Council on Compulsive Gambling and the Massachusetts Partnerships on the Responsible Gaming. But now I'd like to ask Gary Ehrlich, our Corporate Compliance Officer, to discuss our community engagement and minority inclusion. Thank you Bruce, Madam Chair and Commissioners. A digital gaming corporation or DGC is committed to being a good corporate citizen, making a positive and meaningful contribution to the states in which we operate, not only through paying taxes but also through job creation and providing employment and other business opportunities to residents, including minorities. As it says in our written corporate social responsibility policy, DGC works toward collaborative, consultative, and partnership approaches in our community investment programs. We integrate community investment considerations into decision making and business practices to develop mutually beneficial relationships with communities and we strive to provide employment and economic opportunities in the communities where we operate. We follow these principles because they are the right thing to do, but we have found that they represent good business choices as well. Allow me to provide just a couple of examples. In Virginia where we have a license and operate, we entered into 10-year agreements with three historically black colleges and universities to assist them. Our partner institutions are Virginia Union University, Norfolk State University, and Virginia State University. DGC provides contributions to their foundations to defrate costs associated with internships for students pursuing a major in STEM, that is science, technology, engineering, and mathematics, gaming, or related fields. Our total commitment over the term will come to two and a half billion dollars. What do we hope to get out of this? DGC and the foundations will work with the HBCUs to vet and recommend to us students, graduates, and alumni of the HBCUs for priority interviews for employment with DGC. In Arizona where we're also licensed and operating, DGC partners with a small Native American tribe that has very few resources. Their representatives sent us a note that said in part, I thought you might want to know that so far as a direct result of the partnership with DGC Betway, the tribe was able to provide wooden stones for elders in desperate need of heat this winter. The tribe was also able to provide 50 tribal households with large water tanks. Both the stones and the water tanks were incredibly impactful as most of the tribal members live without running water and electricity. The tribe has also been able to assist students with tuition assistance, back-to-school supplies and clothing items, and they have been able to provide all tribal members with bottled water and holiday food boxes. This is another example of the right business choice that's also just the right choice. Throughout this week we've heard the commission's specific reference to working with the Massachusetts Lottery and we will heed that call should we be successful in our application. In mapping out a working relationship with the lottery we would address, among other subjects, providing users of the mobile application with information about the state lottery and seeking cross-marketing opportunities. I'll now hand it back to Bruce to discuss the economic impact of Commonwealth. Thank you Gary. As Gary just mentioned, in addition to the more obvious tax revenue generation impact, there are a few other areas where operations will positively impact the Commonwealth. Currently DGC has three full-time employees in Massachusetts, a Vice President of Marketing, our AML officer, and a sports content marketer. But if we're successful in our application we'll begin immediately with the employment of a state manager and look to start building out a locally-based team. Of course this team's composition and its size will be growth dependent. It could reach 30 or more individuals over the first few years. And as the team expands we will of course consider whether a local office makes sense. DGC is an online business and as such supports itself generally through services can be provided remotely. However it's important that we hire in-state vendors where it makes sense for us. To begin with we've returned already an in-state law firm Foley-Hoke. We also will have a need to secure local hosting services in order to host our gaming servers and related technologies. In addition there'll no doubt be a requirement for local vendors to provide the following sorts of categories of services. Local media buying, supplying of local media inventory, out-of-home, TV, radio, that kind of thing. Potential local creative agency supports, local product Q&A, quality assurance and testing services, office rentals, etc etc. Melinda our Director of Human Resources will now discuss diversity, equity and inclusion and how we bring that to life within Digital Gaming Corporation. Thank you Bruce and firstly thank you to all members of the Commission and staff for affording us the opportunity to present to you today. I'd like to cover some of the existing DE&I efforts for DGC and what we have in place and what we will continue to champion across our US workforce as we mature as a company. A focus for us while spilling our tar footprint within the US market and where we have seen progress across our efforts touching on workforce diversity, workplace inclusion and the establishment of our leadership programs. Give me a second, sorry technology. As at the end of 2022, 49 percent of our US workforce identifies ethnically diverse with females making up 31 percent of our team. From a management perspective, 27 percent of our US workforce fall within our management structures. 41 percent of this group identifies female and 59 percent as male. Within the same management cluster, 28 percent identify as ethnically diverse. We have and continue to create an environment where diversity and inclusion is not just a metric or once or initiative but that this truly forms part of our makeup and continue to shape our culture as our workforce evolves. We drive only through our internal coaching but also throughout our hiring processes and our employee development programs. We continue annual diversity training across our teams. These training courses touch on unconscious bias and diversity and inclusion within the work environment. This is specifically important to us as each employee within DGC has the responsibility to create a work environment that is free of harassment and that supports a culture of equal opportunity. Looking forward into 2023, we will be launching two internal leadership development curriculums Leap, Learn, Engage, Apply and Perform. This is a foundational leadership program for all new leaders internally promoted and or new to DGC. Our second leadership development curriculum fired up will be centred around fostering fairness, integrity, respect and excellence which will aim to establish which will be aimed to our established managers and our specialists within DGC. A common goal across both these development curriculums is to equip our leaders with the tools to continue building and fostering a diverse inclusive equitable workplace that creates belonging for all of our employees. When we launched in the state of Virginia, we adopted a workforce development and diversity plan. Gary has already mentioned our support to the three historically black colleges and universities in that state. In addition, we've engaged all of these universities or HBCUs through the handshake platform where we prioritize hiring from any historically black colleges and universities nationally. In establishing our Virginia workforce, we had 24 vacancies available, 32 of which our hires were from HBCUs and 71 percent identified as ethnically diverse candidates and of the 24 highest, 29 identified as female. Should our sports wagering license from Massachusetts be granted, as our business grows, we will continue creating local opportunities for unemployed and underemployed individuals. We expect to partner with local HBCUs and various organizations within the Commonwealth to ensure we attract successfully on board, develop and retain a workforce as our Massachusetts business grows. To this end, DGC will proactively reach out to organizations like the National Minority Supply Development Council, the Women's Business Enterprise National Council, the National LGBT Chamber of Commerce, the National Veteran Business Development Council and similar state and local organizations within Massachusetts to partner with us on our DE and I efforts. In terms of ongoing continued supports to various minority interest groups, DGC commits to ensure that a percentage of local spend is committed to vendors comprised of women, minority and veteran-owned businesses that can deliver services across our national footprint but also locally as we recognize that not all businesses have the infrastructure to support a national requirement. I'd like to hand over to Shal Bart, head of operations for DGC, to take you through a presentation of the Betway product including a review of the relevant responsible gaming features that are built into our product experience. Thank you. Thank you, Melinda. Thank you, Madam Chair and commissioners for affording us the opportunity to present the Betway platform to you all today. As Melinda just mentioned, my name is Shal Bart and I head of the technical operations team for Digital Gaming Corporation. My presentation today will largely follow the format of a live live demonstration and in order to present that to you I'll be using both a virtual private network and a mobile mirroring software solution. I mention that only because it may cause a delay in page loads which would not ordinarily be experienced by the customer. I just wanted to highlight. It also bears mentioning that a VPN connection or similar location masking solution would ordinarily also be blocked by a geolocation service provider because I'm using a test account. It has been whitelisted and allows me and affords me the opportunity to do this. The platform also is a native Android application that is currently live in a higher stakes. So you will see mentions to the state of Ohio regulations relating to that in terms of responsible gaming measures, etc, etc. But as Bruce mentions and as I will touch on these are highly customizable depending on state. But before going into the live demonstration I also think it's prudent just to manage to discuss the platform behind provided behind our application. The software development house that has provided us with our fully integrated PAM and platform solution is Maron. Maron is more than 20 years experienced that they can leverage and bring to DGC in software development specifically around gaming software. And we've worked incredibly closely and directly with Maron to ensure that this product is tailored to our needs and also meets the regular later requirements of each and every state that we go to market in. We have worked very closely with Maron to ensure that the technology is not only robust in terms of a player account management tool but that it also contains a variety of configurable responsible gaming controls that both Richard and Bruce mentioned before. And I will catch on a little bit later in this presentation. Although I'll be walking you through the native Android client it's also worth highlighting that the platform is fully responsive it's a fully responsive web client built on the React platform or technology alongside our native iOS and Android applications. We're supported the application functions such as biometric authentication can also be enabled by customers for additional customer security as I wish. And lastly before moving on to the live demonstration I also feel it important just to highlight that the Maron platform currently is GLI 33 compliant or certified. Give me one moment just while I share my mobile screen should pop up any second there we go. And I've broken down this presentation and or demonstration in three kind of distinct sections. Firstly we'll just touch on the player on boarding journey going through that. Thereafter I'll move into the logged in state or as we referred to long logged in state cover the my account section with a principal focus on the responsible gaming tools that and messaging that we have available to customers. And then closing we'll move back to the main home page and look at some features around customer support elements and betting and betting behavior. At any time madam chair commissioners stop me to ask any questions. If I don't manage to notice that I'm sure my colleagues will give me a head. Okay so if we look at this first page of user on boarding you'll notice that it's given me an alert that that email address already exists. We do not accept any duplicate account registrations within our platform. Should a customer try and circumvent this by changing some of the information provided or that may be on file in combination with our PAM third party providers and proprietary linking algorithms we have built we would like to identify duplicate account registrations within the platform. In addition we mandate minimum requirements for passwords and password creations. This is an additional security step. I'll just highlight to you quickly. Should a user decide to not meet those requirements we handhold them through the process. Validation errors will highlight what is acceptable and what is not through that process. Forgive me if I fat finger the telephone every now and then but we're just going to go through the next step so that you can see what happens. I'll try and keep this as simple as possible. So let's generate a email address that looks relatively legitimate. We'll also hack the password never use this password ever. I'm sure I'm preaching to the choir. And should I must that must type the password it will give me an error as it has done there. The user can then see you can see that the password has been a very imagined of Kester. So I have done that wrong twice again. I cannot see what error message has been created. It's an additional three and missing one. Continue the next one which where we capture personal user information. Key thing to highlight here is that we do not require gender from any of our users. We simply require base information that will be utilized to validate the base identity and age. Then to mask how long I've been in this industry. How much let my real date of birth to continue. And that will be the next step. Again, very simple address valid validation. Sorry for the silence. You will notice here that it's optional for the user to confirm whether they'd like to receive SMS notifications. It's not at all mandatory. I can move out ahead with my registration without that. And on the last page is the confirmation of acceptance of our terms and conditions. In the additional messaging that state regulations may require and an affirmation that I am over the age of 21 before I can continue. And that I'm not a key gaming employee. On acceptance of this if I click create an account at this point in time is where the registration forms and registration details are passed to our automated identity verification service providers such as ID comply or Lexis Nexus where they verify the identity and age of the registering customers. Should the customer fail that automated registration that automated KYC check that is that customer is then requested to provide us with a form of government issued ID a utility bill which is then in turn received and reviewed and assessed by dedicated agents within our risk and compliance team. If there aren't any questions at this point I will move on to the logged in state because like I said this is my live test account and you may be able to see the password that I enter. I'm just going to minimize my screen quickly. This is a public forum after all and then I'll bring that back online. Just give me one moment please. The screen that I'm displaying here now is the screen that all new and returning customers will land on. You'll notice it provides easy access to popular leagues, events, live betting and access to things like the betslip in the my account section. I'll return to the betslip later. So for now let's focus and navigate on to my account. Mr. Barber, is that the home page that I would call to you? So that is that is how it will arrive? Yeah. Right when you go to your app and is that the very response screen? That's the very first one. I just want to point out to my fellow commissioners some responsible gaming information at the time. I guess it's very very conspicuous. Yeah, it's very important. Yeah. So I'll jump a little bit ahead so forgive me if I repeat myself later when I go through my script. It is also at the bottom of any active screen page that the user will engage with Madam Chair. So we have both responsible gaming shield if that is not if there's not a mandated one such as New Jersey we will provide our own along with the link. But like I said I'll actually touch on it now when we go to the my account section in a little bit more detail. So my account from here the customer can very clearly see their balance if this is after all the sports the sports betting contest no eye gaming here any free bets that may be awarded to the patron will be displayed here because I didn't want to run into any restrictions on testing my account currently has no free bet and they can initiate a deposit and withdraw from this page as well as access live help and responsible gaming elements. And let me start by highlighting some of the responsible gaming elements that we've made available in the state. And apologies there's the lag. So Bruce has already discovered that discuss this in some detail so I'm not going to unpack them all but let's just jump very quickly into what it would take for a user to add or edit a deposit limit on their account. As you can see here I've already pre-populated or I've provided information already on a daily, weekly and monthly limit. The most restrictive limits here would apply. And were I to change that $5 daily limit for example to two that change will be instantains. It will happen immediately. But if I say we're wanting to change that to $15 that would take 24 hours in the state of Ohio before it will update. As I exit out of this there are other methods time limits. You will notice that you can set a time limit for yourself anywhere from one hour 23 hours, 24 hours only because that is a full day and therefore doesn't really make sense. But let me highlight the responsible gaming information that we make available to our patrons. And in previous presentations I have noticed the ask around parental controls and parental controls methods. So although our app may not have that built in we reference in our responsible gaming term the responsible gaming page several tools third party tools that parents could use to enable on their system should they wish not to have minors engage with gaming content. Alongside that we offer tips for safer gambling any warning signs that may be of consideration myths associated to responsible gaming and of course contact information for authorities around responsible gaming. Again we're mandated to include certain contact information and certain links we will do so. But in the absence of that we will make we will make reference to the items such as national national consulate problem gambling gamblers and monoliths et cetera et cetera. This link, this information is also accessible to the user in what we call the logged out states or pre-logging in or pre-registration so a user need not access their account to get access to their responsible game information. So just to close out there and return to the my account page you will notice perhaps at the bottom of this page that session time is continuously displayed along with the last date and time that this user or myself had logged in. Those two commissioners and Madam Chair persists in any active page within the application so it's not just a menu item. And just in closing on this section before we move on to just general betting and the general betting environment I just want to highlight our help platform. We make available a telephone number for customers to contact us should they shut so wish alongside live chat by far the most popular feature we have found along with email probably the least popular of those email or ticketing solution. If there are no questions on that I will move across to the betting features. Can I ask this question and Commissioner O'Brien you may want to follow. You mentioned earlier I think with Mr. Hassan that you have a great deal number of languages provided single language depending on the customer base if you have multiple languages available. No problem currently in the United States we have a single language which is English but we are soon to follow that with Spanish the Spanish language is on our right not to be delivered shortly and that would be dependent on users language choice. It will be available throughout our platform and the users consider. And is that consistent with your practice globally running for your global partner? Is it a practice in other countries to have multiple languages? Yes, Madam Chair. Yes, Madam Chair. Where it's relevant so in Africa for example or South Africa you would have English and the local languages Afrikaans because as you look you wouldn't necessarily have Spanish the community is very small so it is dependent on the community base within the region that we operate. The US for example it seems to make sense that Spanish language support should be offered and we will build out of that based on need. Thank you. No, no problem. So if you are ready you'll see now we are back on that main home screen and in the button carousel we have access to key leagues and major sporting events. So I just really very quickly want to move over to NFL and let's look to place a bet on the 49ers. You'll notice on the screen sorry if you see the reference in there it's just to look at the screen as well as you would be seeing it the option for a same game parlay. So let's go ahead and place a bet on a same game parlay. Why not? So whilst that loads we'll pay we'll take a money line on the 49ers and we will look to Samuel too sorry put a delay there my earphones to score a touchdown and we'll add that to our bet slip. As I add that to the bet slip let's place I feel lucky $20 wager. You'll notice at the bottom of the screen that there's an option for me to accept all future odds and line movements appreciate that this is probably more relevant or important in live betting scenarios but when odd or line to move here I would get a message or an alert to say the line is moved before I can complete the placement of that bet. If I place this bet now you will notice that I receive an error that is because I've purposely exceeded my loss limit set. So it will show the the patron that you have exceeded your daily loss limit I would need to change this value to something that is more appropriate which given my loss limit is probably around that. This bet will now go through it will be added to my bet slip as an active bet if we can click through and have a look at these all the active bets that are currently on my account where in CashHot opportunity exists it will highlight it for me here CashHot is just a early settlement at that price there's a dedicated tab to that as well so I'm still backing the Boston bronze to take the Stanley Cup and then lastly any settled bets that may have occurred on my account and whether that's when a loss full bet details when I've placed a bet ID etc etc if there are no other questions Madam Chair and commissioners I will now hand the session back to Bruce Commissioners any questions on the technology while we have it I have a question Madam Chair Thank you Good morning again to our presenters we've seen a notification in some of the other platforms that have been demonstrated this week that alerts the patron to the amount of time that they've spent on the tab Is that a feature that you have as well? It's not a feature that we have on the state of Ohio but as Richard showed on one of his earlier slides is a feature that we have within the tech stack Thank you But it can be produced Yes Cool Thanks again Madam Chair and commissioners I will now hand it over to Bruce give me just one second while I situate myself Excellent Thank you, Sean In final closing I realize it was probably gone over our lovely time a little bit so apologies for that I just wanted to take a final moment to thank the commission again for its time today and to reiterate that it would be both an honor and a privilege of DGC where to receive a license to operate on the Commonwealth As a final remark I'd like to add that we believe in transparency and open communications with our regulatory partners The benefits to all parties in keeping communications open and free and frank and to working together to resolve issues and look for opportunities to improve are tremendous and we sincerely hope that we can develop just such a relationship with the commission and its staff that will foster a great working relationship over years to come if we're lucky enough to be awarded a license so thank you very much I appreciate it Thank you so much and if you'll take down the slide I'm sure Mr. one Thank you Better find the stop share I like that Great, thank you Thank you so much for being a presentation and the demonstration Commissioners, I think we have time now to move on to our in-house specialists that that makes sense Okay So at this time we're on agenda item for B for B and we'll turn to presentations and analysis from GLI on the technical components of this application and then move on to the report of suitability by our IEB and then we'll turn to the financial economic impact analysis that'll be presented by RSM So there we are I see Joe Good morning Good morning Madam Chair and the Commissioners Joe, let me give on GLI a little shout out for those who may not be as familiar with GLI who are joining today GLI was first to write and set gaming technical standards which are now considered to be the industry benchmark worldwide GLI has continuously responded to the industry by innovating new standards and testing allowing regulators to feel confident that they are providing a safe responsible method of revenue generation for their stakeholders and preservation of integrity With that Joe, I'll let you introduce yourself Thanks for having us, Madam Chair and members of the Commission My name is Joseph Bonaveth Director of Client Solutions for GLI I'll give an overview of the submittal verification and certification process regarding mobile applications and all the digital platforms to be approved by the Commission This middle preparation includes the following It's a platform we're familiar with a modification list from the last submission to one or more jurisdictions will be requested and reviewed to set up the project plan for MAS considering any changes to the platform in all specific Massachusetts rules and regulations During that process we'll review the technology architecture documentation which includes the complete comprehensive and technically accurate description and explanation of the sports wagering systems This includes the descriptional hardware devices and virtual servers description of all server and client software modules including the software versions the layout of all network communications between various software and hardware modules and an explanation of all third-party integrating systems Postal technical documentation review critical files regarding compliance will be identified and documented Then a complete project plan is put in place taking out the unique architecture and design of the platform and the specific MAS gaming rules and regulations The lab will run a supervised compilation of those source files the signature of those files and the compilation steps and the signature of the signatures of the compiled code Once complete the source code can be submitted for testing in a lockdown environment GLI will review the player account management platform known as the PAM for registration, age, identification verification account controls payments reporting responsible gaming controls required disclosures in geolocation Geolocation testing commences in two parts a field test to verify the borders through sampling along the entire border while completing edge case technical tests The field tests will also cover any restricted areas as defined by the MGC A submissive workaround detection will commence in the lab including but not limited to VPN and proxy usage GPS spoofing co-manipulation in man and middle attacks GLI will verify the sportsbook in total for events markets point spreads bed acceptance and the corresponding timestamps and logging Verify the enforcement of bedding limits in all edge cases Verify pre-event and live event data feeds post event bed settling corresponding timestamps and all logging reporting we will then review the change management process and procedures after the technical checkoffs are met certifications can be issued when GLI verifies the changes made for master use specific deployments including source code differential and any testing to the last reviewed version and GLI has evaluated the product has met all master use specific requirements after certification issued and the MGC accepts them field verification will be conducted in junction MGC that procedure is being finalized and actually starting next week on the CAT-1 level during that time the following commence verification at the production server including verification of all critical signatures reviews of internal controls for procedures to operate the book technical technology for configuration such as proper setup of roles and user right management and potentially interview key personnel to ensure they know how and follow the procedures from the internal controls at this point they would have met the technical requirements for the operation of a sports work in the Commonwealth this concludes our presentation for the submittal certification and verification process Questions for GLI Joe, I have a question GLI certified Ohio in this case is that right that's correct yes that's correct and and Mr. Warrmeyer and and Joe of that would be the same platform that is imagined for Massachusetts correct correct and that's a newer version of my right and what has been used in other states all of those and the other states except for New Jersey because of their protocols were they all GLI certified as far as Joe yes as far as yes as far as I know yes yes and and and and Mr. Warrmeyer is also nodding yes I can confirm yeah thank thank you other questions for Joe okay have a good weekend Joe unless you're going to be sitting around maybe in case we have questions but if we don't talk have a good weekend yep you too thank you very much thank you okay now we're going to turn to IEB and the suitability report by the IEB and I see we have Chancellor Hall this morning good morning Heather good morning chair good morning commissioners as you know the IEB submitted a report regarding its review for preliminary suitability of the applicant digital gaming corporation USA or DGC USA this applicant is seeking a category three untethered sportsway during license the IEB performed its review for preliminary suitability in accordance with the standards set forth in 205 CMR 215.01 subsection two and as you know the IEB did not perform a full suitability investigation and as a precursor to the review the licensing division in conjunction with the IEB performed a scoping review of the applicant and identified one entity and three individual qualifiers that it designated in connection with DGC USA's application those qualifiers are listed on page one and two of the IEB's report and as noted in the IEB's report the IEB may designate additional individual and or entity qualifiers if a full investigation proceeds in this case supergroup was not part of the initial scoping process but I would just note that our licensing division has been in contact with the applicant regarding the supergroup acquisition and in addition the licensing division has performed a review of the submission for deficiencies and no substantive deficiencies have been identified at this time and as you know our team was comprised of contract investigators including former members of the state police gaming enforcement unit who had contract investigators from the firm of RSM all of whom worked in collaboration and with the oversight of the IEB the review for preliminary suitability contained a summary of DGC USA's licensing status in other jurisdictions all as disclosed in its application its compliance history in other jurisdictions pending litigation valued over 100,000 and a summary of open source information with respect to the applicant and individual qualifiers but not the entity qualifiers and the results of those sections as you know appear in the IEB's report we have contract investigator Kevin Murphy available if anybody has questions for him with respect to the financial suitability the preliminary financial suitability review was conducted by a team from RSM who prepared a report that appears as exhibit one to this report RSM worked closely with our financial investigations division with their chief and other members of our FIT and RSM reviewed disclosed financial information of the applicant and as always we have members of the RSM team here to present on that section and available if the commissioners have any questions so with that that's the end of my preparatory remarks and happy to answer any questions the commission might have I have a question council hall good morning thank you go right ahead Krishna Skinner I saw two of you lean at the exact same time so thank you Krishna's going to go right ahead I think I know the answer to this based on your presentation but IEB has assessed the additional qualifiers that will be at play as a result of the acquisition of the applicant by supergroup that actually there have been communications with the applicant about supergroup we were made aware that the acquisition was completed on January 3rd so there have been communications and if a full investigation were to proceed if a preliminary license was issued by this commission then we may designate additional qualifiers for that acquisition but no designation yet that's what I was getting at and so therefore no applications have been submitted on behalf of supergroup that's correct thanks okay Krishna or Brian now so yeah I had a question in the same vein and so the follow-up to the the Q&A you two just had is why not get the supplemental now like what's the time between getting those that information and at least ideaing qualifiers at this point well I think that process is you know currently happening and I think if you know like I said we learned we were notified that the acquisition came to fruition on January 3rd which was last week so I'm not I'm not suggesting that anyone is somehow you know I'm not moving with all alacrity I'm just trying to we have an applicant who's now in front of us with a different corporate structure than what was submitted when they submitted it and so when we're looking at sort of what's required for even preliminary suitability I'm looking for what's the time you know of getting in the BED and updating the suitability report to accurately reflect the applicant who's in front of us today yeah I mean I can't give you an exact time Commissioner O'Brien I know there have been communications and I also know that RSM did reference RSM's data and and their analysis was based on information I think as of November but they did they did note in their report the proposed corporate structure so I know you know RSM may be able to speak somewhat to that in terms of when we would actually have the BEDs that scoping process has not been completed yet so we would need to scope out any new individuals and entity qualifiers and I can't speak for the licensing division you know I anticipate that it could happen relatively quickly and I think you know it frankly would depend on if the commission how they decided to proceed how you all decided to proceed and you know certainly we would keep the commission in communication with respect to with respect to that process okay just as as one commissioner I would love to see that as part of what what is in front of us on this application I feel like it's the actual it's the actual structure in front of us right now I'm going forward that's that's just me I know I'm not going to put you on the spot you can't speak for the licensing division but as we go through the day if there's any more clarity on how long that process might be if somebody could report back I would appreciate it well I would say too I mean that would essentially be another report and you know obviously I'll defer to the commission on how you wish all wish to direct us that would involve a scoping process identifying individuals and entities it would involve them submitting BEDs MJ PhDs and I guess a general application so I will defer to the commission on any direction that you all have with respect to that I'm not viewing it as needing a general application to be resubmitted it's just the the scoping that I'm interested in just to be clear I'm not suggesting that they need to resubmit an entire application Michelle Barney just to be clear when you say scoping are you looking for the anticipated qualifiers correct are you looking for more than their names and positions I'm looking for them to submit like she said the multi-jurisdictional the probably a lot of what was already submitted to some of the other districts Ohio probably being one of the more recent ones just like they had done for the initial wave that's that's what I'm interested in given that the corporate structure has changed and the presentation rely on large part on supergroup more so than when they submitted I would have done it for supergroup in Ohio would you Madam chair if I may without wanting to I just you know speak to the actual steps in the process that needs to be followed but the supergroup qualifiers the perceived qualifiers are preparing to file by the end of this month and they have already filed in a number of other states one of the transaction conclusion requirements was that we had regulatory approval and they have filed in states like Ohio and others so I'm ready to do it I'm not busy with that process as we speak but how that fits into the commissions process that Joshua the administrative part of that I can't speak to but it is underway and I think by the end of the month is our internal divine for that great thank you for Commissioner O'Brien that's helpful and then in terms of the names along with the qualifiers that's what you like that I'm trying to see out maybe with it being some kind of amendment to this report that's simple as opposed to you know sort of striking the initial just a supplement to it in light of the acquisition for having joined in that and that was going to be my question whether we would get an additional preliminary report relative to supergroup but apparently if they're not the applicant I think a supplement makes sense but I would want to see that it includes all of the information that is applicable to the applicant in the existing report Madam Chair I also have a question about attestations a lot what were relying on is attestations the supergroup when would they in the process Heather when would they you know attest these things have they already would they when they submit these documents sure yeah and essentially the way the process works is that there has to be scoping because the licensing division in 90p has to determine who the appropriate entity qualifiers and individual qualifiers are once that determination is made those individuals would be you know as part of the application would be required to submit the certifications as well as the certification with respect to the entity qualifier so it's all essentially one package with many different parts that would be one part of the package thank you okay other questions for John Sirfowl all right Heather you'll stick around in case something comes up yes thank you Chair thank you now I'm returning to RSM RSM is some RSM US LLP is one of the leading providers of audit tax and consulting services in the United States and RSM has been working with us and that's just gaining commission to provide insights and analyses to help us with respect to understanding the components relative to the financial stability we have limited the scope of their analysis and I know that Jeff Katz will go through that and good morning Jeff please introduce yourself as well good morning commissioner hi everyone Jeff Katz here from RSM I lead our strategic finance and FP&A practice here based in Boston and our team has done this initial analysis financial capacity for the applicants and then if it's okay commissioner I'm gonna put on the screen our presentation thank you okay sure I just want to make sure everyone can see the screen we can we can if you want it right now it's not full full screen I don't know if you want to make it it's okay if you if you can't okay fine thank you okay so just you know this is for that way digital gaming corporation USA and this is in the category three untethered analysis as of January 13th 2023 so RSM appreciates the opportunity to present to the Massachusetts Gaming Commission we understand the importance of the licensing process and the importance of these meetings you know please note that we are we are not presenting on all aspects of the application the purview of RSM's review was expressly limited to information self-disclosed by the applicant as well as information published by market analysts reference to your end specifically we've been asked to provide insights based on applicant information research and our experience respect to the following sections section B2D sports wagering experience description of sports wagering operation and we've been asked to focus on Betway Digital Gaming Corporation or DGC section C2 projected Massachusetts revenue we've been asked to provide insights into all aspects of the DGC projected revenue in section G3 financial stability and integrity we've been asked to provide insights into all aspects of DGC's financial stability and integrity other RSM observations are also available for the MGC's consideration okay and so the summary of our presentation today so the first is sports betting market in Massachusetts and across the US the second section is applicant projected gross gaming revenue or GGR market share and hold percentage and the third section is liquidity so on to slide two sports betting market sizing state of Massachusetts so as commissioner Judd Stein has indicated the RSM team has been asked to join the meeting and make a presentation related to to the aspects here and the just we'll provide some general observations that conclude may benefit the commissioner view of the applicant so for slide two we observed that truest securities 2023 estimate considers a ramp up period for the state of Massachusetts based on our view of historical betting mix between retail and online sports betting for states that have already legalized sports betting we note that the gross gaming revenue contribution related to online sports betting range from 78.9% to 94.1% of total sports betting and this yeah yep I'm sorry to interrupt you did you enlarge your screen just a little bit sure it's the plus that I think it if you could get to it using it is it the plus sign at the bottom yeah here we go I'm sorry nope no problem here we go is that better yes thank you okay yep and so the total estimated gross gaming revenue related to online sports betting for years 2023 to 2027 are as follows and so we looked at two analyst reports for Deutsche Bank as well as true of securities and then we also included all the applicants reviewed by RSM and you'll kind of notice at the low end there's 70 79 million in 2023 and at the high end in 2027 936 million addition to the market size RSM also looked into the year over year growth trends estimates as provided by truest and Deutsche Bank market research for the state of Massachusetts in order to again test the reasonableness of each applicant's projection the chart presented here excludes 2023 through 2024 as this is estimated to be on 300% in growth but you'll notice that in 2027 if from 2024 to 2027 it's going from Deutsche Bank has 9.1% growth all the way to 4% growth by 2027 and truest starting in 2025 has 29% growth scaling down to 16.6% growth by 2027 and truest considers a ramp up period for the state of Massachusetts so that's why 2023 and 2024 were excluded for them moving on to slide 6 and 7 we wanted to provide some insight in the total online gaming market the figures presented here include both online sports betting and eye gaming which as of today online sports betting makes up slightly more than half of this overall market and just as a caveat we understand that bar stool and pen is reported on the table twice likely due to acquisition activity of separate sports books so just as a caveat there and then here in slide 7 for one second I know that there was some discussion about whether eye gaming was in that chart at all and whether you knew what percentage I don't know if you had been able to get that information not particularly to the applicant but as in general in that chart yes so we can we can we can get that to you after this thanks and just on slide 7 we show the market share data by operator across the U.S. as of June 2022 and so this was you know we utilized information from other states and third party research to develop a benchmark or you know this is this is really just your it shows here that this is dominated by three major players who've got Fandall at 33% you've you've got bet MGM at 21% and giraffe kings at 19% which are the top players in the U.S. online sports betting market Jeff can I ask this question while you have this up too I suspect this is not a a fair question but I'm going to ask it anyway okay do we have a sense of what the number of other is we do have some detail on what other is but it's going to be smaller operators so it's going to you know they're going to have a much smaller percentage we can get the detail to you if you'd like yeah that might be helpful okay thank you and then moving on to you know slide eight here so this is hold percentage over time so we utilized information from other states and third-party research to develop a benchmark for hold percentage hold percentage which is the percentage of total bets kept as revenue by the sports book has been fluctuating over time as industry matures and new new jurisdictions launch but you'll see here we have the percentage of all U.S. states that have sports books over the past approximate 18 months and what we did is we used rolling averages to smooth over any swings in hold percentages over time so we have a three-month trailing and then a six-month trailing moving on to slide nine you'll see that this is the median hold percentage of all U.S. states with sports books over the past approximate 18 months and so this this shows the median hold percentage during operation versus the number of sports books by state so based on on this slide what we in our analysis we deduced that range of seven to 10 percent is is the likely range for hold percentage in competitive states so we are estimating that the state of Massachusetts will likely fall into the eight to nine percent range based on the 11 applicants for online sports betting licenses before the before the commission and then just moving on you know for digital gaming corporation USA that that way the applicant which does business under the bet under the bet way brand has a dynamic corporate structure as of January 3rd 2023 it is part of the publicly traded supergroup however at the time of the application the transaction have not been completed supergroup was not submitted as an entity qualifier and was broadly outside the scope of our review as seen in section 4.1 of exhibit one of the IEP's report we have reviewed some publicly available and financial statements for supergroup to understand its liquidity profile which we felt necessary to provide a holistic view for the commission so turning to the applicant proper we were provided a comprehensive view of DGC USA's projected operations in the Commonwealth from 2023 to 2027 we reviewed the applicant's revenue projection information and compared to market analysts Deutsche Bank equity research report and truest securities equity research report gaming industry both of which were issued in October of 2022 the applicant in accordance with section C2 has submitted a financial forecast for operations within the Commonwealth of Massachusetts the submitted forecast contains three scenarios a base case an upside case and a downside case in the base case submitted scenario the applicant provided a five-year financial projection of the sports rendering activity in Massachusetts covering estimated handle gross gaming revenue whole percentage and net gaming revenue or NGR additionally the applicant provides a terminal period upside and downside forecast for operations set another way this is the projection of when the market reaches maturity and stabilizes in year five or 2027 no upside or downside forecast was made for years one through four so we cannot speak to the projected growth path in these scenarios to compile its projections the applicant first estimated the total addressable market or TAM in Massachusetts using industry research reports then applied an expected market share capture rate to calculate GGR it should be noted that projected TAM and the Commonwealth estimated by DGC is at the lower end of the range found in our independent research as the commission is aware revenue is closely tied to whole percentage DGC USA's whole percentage assumption is conservative and in line with what one would expect in a highly competitive state operation again due to the confidential nature of DGC USA's projections I will reserve further commentary for the executive session as spoken to earlier DGC USA and its parent company DGC UK were privately held companies at the time of application the now parent company supergroup as of the last public quarterly filings Q3 2022 had 230 million in cash and 17 million in term loans and leases payable this concludes RSM's public portion of our presentation I will stand the line to see if the MGC or DGC has any questions Jeff can you take down the screen please thanks questions for RSM but Jeff you went off camera but I wanted to I am here we go I'm going back on thank you thank you thanks any questions Paula Jeff I'm going to ask about an area that we haven't talked about but it might be helpful for me to be better informed in RSM's review of all the applications you have been looking at financials for the bottom line tax revenues are report you know estimated tax revenues for common rather estimated and I know in our statute there's calculations around that in consideration of AGR are you familiar with treatment of promo play across the jurisdictions and has that come into consideration at all with respect to Massachusetts applications so we have done research on promo play and what that means for other states no one at least we haven't seen many of the applicants provide any information on promo play within their projections so you haven't seen them assuming a deduction correct and do you but in other states applications would where with why would there be difference among other states you know why they wouldn't be presuming it here I think with the application they put in gross gaming revenue and they may or may not be including promo revenue because they may or may not be thinking about utilizing it it depends on the situation and what their practices are so you can't tell if the tax revenues reflect deductions or are you saying that they didn't take the deductions they didn't take consideration of deductions okay that's so the what we're seeing for tax revenue is what presumably when they were fulfilling responsibility for our request was to say these are the tax revenues that will come based on the laws in front of us that's correct yeah yep thank you really helpful okay any other questions for ours no just confirming that we will be hearing from them an executive session on the portions that weren't for public consumption that's right so we'll put that on the list and Jeff will be back to join us if we go into executive session which we can anticipate recently any other questions that are right for public consumption okay it's 1135 and we're at the center in our application at our agenda where we would turn to our section by section analysis commissioners does it make sense for us to take a short break and then begin that process yeah that's a fun break right okay commissioner hill we're thinking of you we're going to we're going to take a what time is it it's 20 of 12 come back on 25 12 come back around quarter of 12 to the public and we'll start our our section by section analysis and to the applicant thank you very helpful presentation so far thank you so much can I just confirm was that a quarter to 12 or a quarter past 12 that you mentioned that would be a long break for us how about so 1145 okay thanks so much hey Dave okay it's still good morning we're holding this meeting of the master's game commission virtually so i'll do a little call good morning again commissioner brian good morning i'm here and uh commissioner hill if you're able to respond we know you're there I am here thank you uh commissioner skinner good morning and commissioner made a good one again good morning madam chair I am here okay excellent so returning now to uh 4c of our agenda for today and we are in the process of reviewing yet another applicant for uh an category three on tether sports wagering license and we wish to thank digital gaming corporation usa or dgc for its earlier presentation and demonstration with her from our in-house experts and now we're going to start the process of under 4c our review of the application so uh commissioners with that because that we walk through the applications as we have done with other applications that have come before us previously we should consider whether the applicant's response and proposal needs expectations exceeds expectations or fails to meet expectations in this context though since we will have to consider the applications holistically at the end of this individual review this initial assessment as to whether the expectations have been met will be preliminary in nature just to see whether we have a general consensus and a subject to modification once we've had a chance to move through our evaluations of each application in the broader landscape is in greater focus a reminder one or more commissioners may seek supplemental information from the applicant to any component of their application and as part of this process again as we've done prior we should consider as unless we go along any conditions that we might like to see in the event that a license is awarded to this applicant and again at the end of this process on or about 18th or 19th that would be next week we will be meeting to identify any variation between the applicant's proposal in this category as it relates to others as I've mentioned before our process has been construed to allow for flexibility now turning to our section analysis commissioners do you have questions on Section B please I do Madam Chair in particular B4F1 relating to the proposed ability to commence mobile sports wagering in the Commonwealth there was a timing question in there answer in there that I wanted answered I'm assuming that is executive session material potentially but I don't know Commissioner Brian if I can address that you would like to discuss that in an executive session thank you that's all right okay so that Todd I don't know if you have the document how best to describe it in a public session such that it's identified well enough without disclosing anything can I suggest that we you know the way to put it out is that you know we will not be going live in March of this year as the rest of the market intends to or has aspirations to and that's what we address with the commission in an executive session if that's all right okay yeah I think that covers it for me thank you too okay other questions under section B I have some sort of offshoot questions in terms of the merger and how that affects the the product and the launch I think it all folds into that conversation though probably it most likely does yes thank you yep okay Madam Chair yes Commissioner Hill so I'm going to go back to customer service and I think it's on page 86 that you mentioned it and all the availability excuse me the availability of the customers to get in contact with your company through the phone through email through chat I was wondering if you could just walk us through the process if someone had an issue with their account can they talk to somebody immediately or do they have to go through a process of chat email before you can actually talk to a live person and I don't know if you answered this in your presentation is this 24 hours a day seven days a week. Commissioner Hill let me address that one as things stand at the moment we offer 24 seven telephone email and chat support in five of the eight states that were alive three of the smallest states it's not 24 seven I believe 8 a.m to 11 p.m they're about by the time we go live in Massachusetts we can envision it to be a 24 seven service there's no requirement for somebody to go through FAQs first or to chat first before they call you may not have noticed it but when the shower was presenting the product on the customer health page the first thing we present is the telephone number you can call along with the live chat link we put all of that up front in case we have a capacity constraint at some point and there are agents that can't answer the phone you know you may want to have the other options available to you but the intent is for somebody to be able to reach us 24 seven can I just add in um because you may not have heard but I thought uh following on commissioner Ryan's earlier I was just gonna say this okay go right ahead because I think I heard that we're gonna have it in different languages and depending on where your company will be will depend on what type of language you will make for that jurisdiction I think I heard that yeah let me let me just kind of re-articulate that so globally speaking we operate in 29 languages around the world so structurally operationally we are able to support multiple languages our product stack has the capacity to support additional languages as things stand in the united states we're an English only operation with the intent to add Spanish in due course but from a business and operational point of view we're well versed with the complexities and challenges of operating in multiple languages and what that means for an organization so we look forward to being able to bring additional languages to to our u.s. operations I hope that makes sense I think he's all set with that that's excellent thank you um I have a question um under section b if I'm commissioner Skinner and commissioner Maynard if you're all set for a minute or okay so um should uh let's complete transparency your um your references to your investment in data science and analytics and data modeling caught my eye because I have in my my youngest my daughter a a data analyst in the business intelligence of a large a large organization in the sports and music so I'm thinking there this is great opportunity and so I read your response with great interest trying to understand what she does um but what I came out of most pertinent to us is that um you're using your data um analysis to provide alerts to customers um about when you see changes in behavior um and and alerts now I'm imagining it it wouldn't be necessarily a live person but some something that pops up across the screen the other day I was driving for long distance and something came up and said do you want to take a break you know from coffee is it like that mr um on Ryan and if you could elaborate that would be great sure that is a great question thank you um so in short we're using data to to first and foremost to identify and that's that's the first the biggest chunk of the work you're looking for patterns of behavior changes of behavior and things like that as things stand at the moment we don't have any in-product alerting built on top of that because that's another layer of development that we simply haven't uh got to at this point but what we do have is teams of people who will receive a daily alert a segment of customers a group of customers who we need to reach out to to say we think that you may want to consider looking at our tools potentially uh controlling what you're doing or are you comfortable with the levels that you're playing at those sorts of messages and those will go out via uh call center agents or email to customers in a direct communication specifically talking about the impact on responsible gaming other product stacks around the world have built those features into the product so that's definitely where we will be going in our US product it doesn't exist as things stand today by the same token we also don't have alerts built in there to encourage people to make particular bets either so the technology on the segmentation side may exist but we don't have that communications layer built in and automated just yet on the responsible gaming side of things it is a bit manual still but we're using the data to identify the customers so that we can at least get them out of our database and communicate with them where we need to so you're using your human resources it's not automated um and making that somehow to communicate or does it yes for the communication portion of it but we're using the data and analytics and tools and systems we have for the identification or I understand that but but but it's signaling to me at least is that while you don't have the automated version for the communication you're you're taking a more manual approach and priority really prioritizing that need to send those messages which is correct and and it's relatively easy the next step for us I don't want to speak on behalf of my team necessarily but to automate an email to somebody who is coming close to the threshold all those sorts of things that's easy enough for us to do we're simply starting at the at the higher end where customers are potentially spending more right and and uh I I will speak for my fellow commissioners but I like that priority so all right other questions sections B I have a question about the the betway big pick yes um I clicked on the link it takes me to the page it's you know Massachusetts knows who I am says I'm in mass it's in the drop down um just curious like why mass is showing like if I were to try to sign up for this right now uh this I don't know if this is part of the free play that you talked about or this is something totally different it sounds like you're getting to the big big pick free to play product as served in Massachusetts that's what it sounds like okay can you just write that for me yeah that's what it looks like yeah so it's it's it's a free to play product where which is a what you would call a pick a more selective where customers can sign up and select a set of outcomes for an upcoming match or event or group of events so choose a set of results that are happening in today's two matches obviously they're fairly long odds type scenarios but if the customers selects the correct and set of results for that particular bet event they will win a cash prize now the cash prizes are not enormous um the the the kind of the selections that the customer has to make are quite tricky but we pay out prizes with some regularity so it's a fun and engaging product that helps just to get the betway brand to be consumed in states that we don't operate in because as you can imagine we have a brand marketing exposure that scales beyond the states that we're in so in an effort to to leverage that to make sure that customers in states where we don't operate can be still experienced some degree of the brand and to to build up databases in in in markets that we don't operate in that said i'm as a choosers database on the big pick product at the moment is very fairly small we can discuss the specifics that i had in executive session but it's not it's not a fan daily fantasy league we don't drive explicit marketing to it well much explicit marketing to to better a big pick and it's not in the same caliber of what you may have seen from likes of handiola draft kings where it's a fundamental core of their business and am i correct that for me to try to sign up or register the same verification and so they're going to be required i'm not going to be able to do that without being 21 you will make a self attestation to your age we're not doing an external k y c check and validation on that oh it's the same the same as the the my understanding anyway the same as the markets fantasy games and and free to pay products where the attestation is is self attestation consumers licks their age inputs their age confirms their age but we don't do a third party validation and check well i thought another applicant i thought commissioner skinner asked a lot of questions about setting up accounts and even if you weren't able to load money it wouldn't be but you're just distinguishing between dfs type stuff and yeah so i honestly i can't speak specifics about the competitive landscape but to the best of my knowledge all free to play type gaming categories like this don't require an external validation of we don't take social security numbers as an example but the consumer puts their age in they confirm their age and their age at 21 and if they win a prize we will validate their identity so you know there is a part of it but it's it's the participation door is is only closed by self attestation yeah so self attestation to play but if you win the verification then kicks in and no payout is done unless you're 21 enough correct and and you are who you say you are uh you know so right there's a limitation definitely okay thanks other questions commissioners i don't care yes go ahead push your hand yes i'm sorry it's taking me so long to unmute i apologize it's not taking this may this may be a question for an executive session but i noticed and i think it was on page 452 but don't hold that to me um i saw a lot about in-game betting and we've been getting a lot of information about in-game betting and i was wondering if you could just speak to it a little bit as one of your offerings certainly thanks commissionale um so as as with most sports books in the u.s. around the world we have two categories of betting there's the pre-game betting which is happening before an event occurs and then it's betting that is that that takes place while an event is underway and you would have heard from better and others that you know that's a core part of their product offering as it is in ours although it's not the the central focal area um so for example uh we will offer bets on who will next win the next quarter the next half uh touchdowns within the third quarter uh who's going to win the next drive etc etc now those bets are able to be placed while the match is unfolding obviously controlled within the you know the limits of of risk in other words we're not going to allow bets to take place when a game is in a state of of flux or um or anything like that but it's a fairly standard offering of free of betting that takes place within a game as opposed to betting that takes place prior to the game does that address your question or have i just given you a general description of what in-game betting is no um i'm satisfied with your answer okay and then the last question i have which i'm nitpicking uh so take it for what it's worth on page 454 and it could be because of my eyesight um we care very deeply as you know about responsible gaming and i noticed um at least in the font size as you were putting together all your partners on on the page i really could not see the rg emblem as well as i thought or think we should see it so should you get a license here i would ask you to work with our agency and obviously our professionals um to ensure that when people do go to your pages that they do see that emblem a little bit bigger than i think i saw it on that particular page understood commissioner hill i think you know the in a graph like give you is is is ohio you would have seen some of the fines that they've issued in the press recently for not enough you know visibility of the helpline numbers and things like that we understand that completely and and so whether it's the rg emblem or telephone numbers or links to help or whatever it may be if there are specific requirements of course we'll uh complain and adhere to those anything you may have seen is not we're not trying to hide that away it's core to our business and like i said in our presentation to make this business long term and sustainable this has to be responsible it's it's not something that can explode and cause harm to people if we want this to be a business around 15 20 50 years from now so we we're aligned you know i've said this over the last couple of weeks madam chair and i'll say it again this is an issue that's very very important to this agency and we want to ensure that anybody that's doing business here and it's licensed here understands how important it is and that is as important to them as it is to us commissioner hill i just want to make sure um i don't know which page i haven't pulled that up yet but it might be an inner page but i did know um during the presentation it looked on their home page a really good banner at the top and i don't know if you got to see that but that was all about responsible gaming and and um i know that uh probably director van der linden liked that a whole lot but as to the other pages i think your point is wherever you can access the possible gaming tools we want it convictuous and yeah that's all the questions i have for section b thank you madam chair thank you commissioner hill um i have one last one and it's again i think an innovation um that i that i picked up on not sure how to assess it and perhaps i misunderstood it um but it sounds as though in terms of your you know again i appreciate i really really liked um your explanation of of your the management of of your um of and your strategies the management of your company strategies and and you talked about customer relationship management under your crm and then you explained how um that way will ensure ongoing product engagement through a non-incentive system and i guess i'd ask first non-incentive system you know suggests to me perhaps uh less on the promo playlist on on freebats and something else and correct me if i'm wrong and that and then you said including something which you described as customer competitive leaderboards to mitigate customer attrition and some kind it sounds as though a little bit like helipad you know commission uh uh you know competition among patrons which i thought was novel but then of course i also i'm thinking what does that mean for our team so um so if you would like to elaborate that would be great so i think yeah i think the the the non-bonusing part of the incentives and and engagements is as you described so it ranges everything from uh come and participate sharing information about what is happening what product features are available the games that are coming up today information that pertains to players on the pitch and ancillary information that enhances the vetting experience when it comes to leaderboards much like any retention based incentive you always walk that tightrope between incentivizing customers to to to participate more than they should versus providing an offering that is uh attractive and engaging that helps us to retain our available customers and so that particular leaderboard example is just one it's a tool that's used around the world and you might say and and sometimes it's in a an environment that isn't a free-to-play environment we've done that in various markets where we say to customers of a particular ilk if you've done a b and c come and participate in this tournament where the players for free whoever wins the most on this fact check table or whoever wins the most over this weekend's games of this free-to-play money could win a prize or we simply say uh you know everybody who all the particular cluster of cluster of customers wins the greatest return from this game this weekend will win an additional promise on top of that now each one of those has to be assessed i'm giving examples off the top of my head but each one of those things needs to be assessed on its merits and on this impact to customers both positive and negatives obviously there are many moments where I wish that we could be going into apps and navigating all of this on our own but of course that's not really something that we are able to to do as commissioners so thank you um thank you so much i'm anything else under section b all right but let's uh take the temperature or find that we have a general consensus on section b madam chair i would need to hold until after executive session on that okay other commissioners commissioner skinner i think that's appropriate okay commissioner maynard respect my fellow commissioners request okay and then commissioner just wanted to check in is there anything that you would ask of this um uh applicant right now for additional information i think the only thing we brought up so far was the uh on the suitability reports uh commissions of ryan but the for additional information so far yeah i mean i thought we circled back to everything as we go i thought okay i'm i'm going on the list okay yep all right then we'll move on to section c thank you yeah sections on section c Russia skinner can i turn to you do you have any questions on section c i don't have any questions in the section madam chair okay commissioner o brian commissioner maynard commissioner hill um just one clarification i think in the application you mentioned having two employees in mass but i thought i heard three um just wondering if you just go over again who's in mass that's correct i think by the post the filing we brought it on a third employee so we have our vice president of marketing we have our ml officer and our sports content marketer as well and was that a new hire or a move in from another jurisdiction the VP of marketing was a new hire new hire okay are you leaning in commissioner maynard i was just going to say that um i would compliment the applicant on section c it was very robust both in the application and in the presentation today thank you appreciate the feedback madam chair yes commissioner hill so i just want to touch upon an issue that is near and dear to me um i like what i read regarding the tourism partnerships um that you hope to have with our regional tourism councils as well as our mass office of traveling and tourism can you talk about your mass plan or is this an executive session um discussion how you plan on enhancing those relationships and also i heard you talk in your presentation about your community engagement and i was wondering if you could just add a little bit to us what you've done in other jurisdictions i know you gave us a couple of examples but i was wondering if you could just maybe elaborate a little bit more about your involvement with the community being an online you know you don't have a a brick and mortar building here so it's a little different than it would be if we had our our casinos but just wondering if you talk about that a little bit more right i think i think on on the tourism part that's going to be a new a new venture for us but we do envisage kind of at least opening up the conversation and figuring out how we can potentially start by sharing data sharing information on customers looking for cross marketing opportunities if that's what we we think could add value to that sector i think in our in our application we're opening the door to the possibility of what we could do in a state in the Commonwealth we haven't worked with other tourism groupings in in other states but certainly we think that there could be opportunity to add value from our side to that sector in terms of other community involvement let Gary and others on my team join if they can but certainly we've been involved in sponsoring minor league baseball in in in Pennsylvania engaging with a local bar and restaurant chain there to try and collaborate to bring more energy to to their establishment and bring our brand to to to a local community there um you know our involvement with with the the how you to tribe in in Arizona is is new and fresh but already having positive impact and we expect that to expand in time um i think we've spoken about the Virginia HSBC use and our commitment to putting a hub there which is where i now work from so we have an office based on there which is a specific community initiative so uh off the top of my head i think those the the core ones that we've that we've delivered and brought to life but the intent here is to show what we're capable of doing and and that are kind of monies where our mouth is so to speak in terms of of our actions and and what we do as a business gary not sure if you have anything you want to add to that now i would just add that our um it's not only at the corporate level where you see involvement with the community but we encourage our employees to do things with the community whether it's environmental issues uh cleanups speech cleanups things like that uh that's part of what's in our policies and procedures and we are glad that our employees do take the lead in some of those things so it's not only corporate giveaways but it's actually involvement by our employees and i think that maybe someone from supergroup wants to explain here because i know supergroup does a lot of sports sponsoring around the world which is kind of falls into the same category i think yeah that's uh that's correct gary i mean not not a huge amount to add in terms of thought sponsoring um in terms of big teams i think richard and bruce covered that off earlier however there is an initiative called way forward uh which there's a whole lot of information about uh on the supergroup website whereby and betway offices around the world have partnered with underprivileged uh areas and organizations to uh support sport in those areas building facilities uh and that kind of thing i think also go ahead bruce what one more thing to add i know the that supergroup's african division has a domain app called betway cares i believe it's betwaycares.co.za is the domain one of the south african domain and there they display numerous community involvement projects and engagements so i think when we look at our connection with supergroup and that growing over time this is this is the environment that we find ourselves in this is our company this is how we operate and think not just sporadically not just in isolated pockets but you know around the world so it's it's part of the culture that will continue and permeate through dgc excellent thank you very much thank you madam chair thanks come on Sean we're just gonna you're leading in i am i wasn't going to ask this but i think i will at the risk of demonstrating my own ignorance in one of the responses i think it was um relative to the local business opportunities and i i can't remember what page it was on i don't even take note but you reference uh the commission's vendor advisory team and i wasn't sure if you were referencing uh the team a team at the massachusetts gaming commission or or somewhere else i did ask the question internally so could you elaborate on what you mean by that i will have to honestly check the very specific page to that reference uh but i would imagine that it's based off of information we have about an existing entity within either the commonwealth or linked to the the commission that is designed to aid just such a process or or assists that kind of initiative gary do you recall where that is in the in the application ah maybe no apparently i didn't ask the right person internally so crystal thank you crystal has indicated that it's her team so i have some homework to do apparently yeah i'm relieved that i didn't know that yeah well so no i you know i'm all right no that's that's fine that is a an internal team that has been re um activated and only the last year um once we got relaunched after covid but it is a team that we have community members on the ground that work with licensees to help with their procurement opportunities yep thank you see this is why i hesitated to ask because i didn't want to be embarrassed in this way um but thank you so much as soon as you commissioner skinner though like she said it kind of disappeared and came back recently yeah yeah but that's good mr warnerman and team you do know what you're talking about and the questions first under section c also the commissioners can i take your temperature on section c i think it meets expectations i agree same okay just trying to unmute i medics uh they met expectations for section c oh great thanks commissioner hill and so we're all set thank you we'll turn now to section d mr arbrine you're meaning it yeah i have a couple questions one um if you can maybe go through your stats again on diversity and i'm going to give you the pdf page because that's what i scan through it was page 518 on a pdf that was submitted um there's a chart about diversity equity inclusion workforce sort of shades of purple showing um the splits 21 22 q3 22 i don't know if you guys have that in front of you uh commissioner brown i'm sure we can dig it up while we while we chat and get to the right page i'm going to ask melinda to get in here she's got to all the figures of their fingertips misha branko just clarify your question were you looking at um i'm just wondering what the diverse one the gender first um um would you like to sorry because it seems to go in a direction you don't want to be going in so i don't know if i miss reading this or what your stats are because it goes from 36 64 down to 3070 so that potentially is an overview from where we started in 2021 quarter three or quarter four and then moving up to quarter three of 2022 um if i can maybe just chat through some of our stats ending of um 2022 that will give a little bit of a better direction of where we are going and where we are aiming to still enhance on um so if we just look at the gender split between our u.s workforce 31 percent making up a female um and 69 percent male does that answer your question so it is accurate um and i guess the concern that i have a the number i'd love to see more female um but it also trends it you had a higher percentage women to men and it seemed to be going in the in the other direction i'm curious if you could speak as to why or what you're doing in that regard commissioner melinda perhaps i can interject you and just point out simply that uh melinda you can fact check me on the numbers but i believe from a scale perspective in that time we have more than doubled in size and have gone from a very small number with a statistic the percentages uh are two people um and and so where we are now at 100 plus um is probably a better reflection of where things have been of late but not the trend that you're seeing there is not a trend that's as you point out going the right direction certainly not how we would want to see things but i think it's simply a function of that a very small number being showing a perhaps better than expected view historically because the the size of the the group was small now that we are large we know what our numbers are and where our trend needs to be going in the opposite direction there's no question and can you speak to any effort you're going to make in that regard so i think from well from a diversity point of view we have the two programs that melinda has already spelled out specifically focusing on leadership and diversity from a woman in the workforce point of view we have to apply greater pressure on our hiring processes now in addition to of course the internal mentoring and and and promotion but certainly the the hiring is is the biggest challenge and then i don't know um if there was a similar chart as to ethnic diversity if you can speak to that and then um the last one really you mentioned that you have subs in virginia and mariland who are minority and female owned and better or not i'd love to hear more about those yeah you can ask you to chat to the minority when you go to numbers just to chat to the diversity yeah i can go through the the diversity split so on a total headcount for our us workforce base nine percent identify as asian 18 as 18 percent of the workforce identifies black 51 percent as white um 19 percent as hispanic and then three percent as other and that's the us you said yes yes that is correct right harry are you able to give us some more detail on on minority partnerships in virginia or will yes yes uh in um virginia well we have in both in both places we have uh llcs drop down corporations which are the actual applicants or licensees and of those there is minority ownership um of of those actual llc companies so digital gaming corporation usa owns the majority but there are minority owners that are minorities there are women uh they are hispanic um they're all different all different types of people and uh there are people who are not i don't it's hard to say this they're not really rich people who are just getting richer we tried to find people who this was an opportunity for and uh the other thing i would say is they're not just window dressing we wanted people who had business experience so that they could help us with the local markets they know things we don't know we don't want them to just sign on the sheet and never hear from them again we want them to call us and talk to us about things and come to us with ideas and help the business grow in these jurisdictions great so i know mariland the statutory scheme motivated that it was that something that you then carried over to virginia or was there a statutory incentive in virginia or did you carry the the the yeah uh commissioner brine virginia came first got it and then the mariland mariland was later and and a statutory incentive or did you do virginia on your own uh virginia there was not uh any type of minimum percentage there was just the idea that it would be good if this could happen and we took it on ourselves to go out and find people and establish that kind of ownership that's great that's great i wish mass had done that i know we did this in cannabis but not in this area that's great to see that you did it there thank you that was on one of my my questions and it's a great model i know that we touched on it in our application i give you great credit for you know you're you're framing it as it's great for your business and i so respect that and it just allows um underrepresented communities and and businesses to to get the experience so that they can win the bid next time you know um so we really appreciate that work um other questions the great model and michael brine i'm with you in terms of our legislation i've been great um i'm sure skinner i thought the section was good i think one of the benefits of going um later is that you're able to anticipate what it is we're looking for as a body and what was omitted from the application um was sufficiently uh spoken to in the presentation today um the only thing i would ask um relative to your supplier spend i noted the 10 percent bowl you have for minority and women business enterprises does that also include uh veteran owned business enterprises yes i i believe that we put that in the application filing that we would be looking for that spend to spread across all three categories or okay as best we can okay i'm sorry i missed that um um what was absent was a overall spend and so it's it's hard to put that 10 percent into context without without that information so um hoping you could provide that you would be willing to provide that at some point i think what we what we can certainly speak to in the executive sessions is our marketing budget spend now it how much of that would be spent locally as opposed to uh online and then into massachusetts is going to be tricky for us to identify but certainly in the executive session we can try and triangulate those numbers and and and see what that means if that will work for you go ahead i'm just gonna he asked would that work for you i don't know if you've heard about you sorry no i was going to respond yes that works um it does if that if that's okay yep my apologies sometimes it's hard to navigate the virtual platform it's i'm reading a lot of faces um my apologies if i if i step into some all right okay can you can you remind me just one more time what the um total workforce number was in the united states it's 102 if i'm not mistaken or 105 isn't it um ending on 2022 we were at 117 employees okay apologies thank you and and commissioner meaner i think um a relative question was the number of offices and i think i saw four offices um that's correct right and in this post-covid world a number of our staff are working remotely as well all around the country are you imagining an office space in massachusetts um as i alluded to in my presentation if if if we have a significant a suitable quorum of people we would look to create an office uh from our perspective new staff learn by kind of collaborative engagements with with the rest of the business working remotely that isn't conducive to that and building out a corporate culture and making sure that people understand our brand and our ethos and what's important to us comes from working collaboratively in an office space which is why we have the offices that we do so if if if we're lucky enough to get a license and be awarded a license and our business begins to grow uh we will bear that in mind in thinking about how that team develops and builds out certainly first prize is to have an office when we have enough people to justify having an office and build from from that point forward you answered my real question thank you so much any other questions on d okay commissioners do we feel that this applicant met our expectations on section d i believe expectations have been met here madam chair okay so do i i agree i agree madam chair thank you commissioner hill all right um we're all set then on on section d um we will move on i'm going to assume that we can move on without a lunch break yet section e responsible game commissioners i say responsible gaming then is a bit of compliance at the end of section b as well questions well i'll just start um as everybody gets their thoughts together i thought and commissioner bryan i'm sure you noted that this applicant did take into consideration um massachusetts responsible gaming framework which we appreciated um and and we are proud of of our work so thank you for noting that mr bryan are you leaning in no scanning through the pdf i'm doing a cross check with notes on the pdf i asked this the other day when an applicant came in the some of the mock-ups that you had to about free vet i know there's there's a some movement in the regulatory field to move away from that word um here love to hear your thoughts on if we were to say that that's not appropriate or maybe the only forum is in a web and app as opposed to an ad um if you could speak to that so thanks for the question it's a great one and a very very topical one um for some time now we have been progressing away from the use of that term in our upfront opening offers um and i believe there's a pocket of collateral that has to be updated in one of our states but for the rest of them we have the the opening offer that we offer to customers is not phrased as a free bet or a risk free bet any longer um so we understand that you know that terminology while it was pervasive and common use is not is not appropriate given that customers have to risk their own money upfront to to to enable that to come over the line so as as as a business we're on board with that trend and that's certainly kind of one of the first i think to to to make that change so can you give an example maybe if some of the phrasey algae you're moving toward as you move away from through that unless you tell me sorry it's it's not proprietary i'm just having a post coffee moment no idea what you're talking about one second we can take your time we'll have our own sips of coffee we followed a first bed reset and we still use the term free bet once it's issued to you but we don't talk about risk free bet any longer just to be very clear so it's a first set again a first bet reset first bet reset okay and i think the key here is that you know we're sensitive this kind of discussion and i think it's important for these sorts of things to to surface from whether it's from a regulatory standpoint or an IG standpoint where we're always coming from say guys as a business as an industry whatever it is there is something that needs to to shift and change and operators need to respond to that without it getting to the point of a legislative process to make that kind of thing happen when we when we're in an industry where that happens then things become contentious and and and a fight as which they shouldn't be and i think when the communications are strong and those kinds of things get put across the fence we would react and and adjust accordingly and then circling back to something that i think commissioner skinner asked about i know there was a clock a session clock as you're in your app sort of showing you the ticker and how you've been on um do you have the capacity to do the app limit if somebody says you know not only the cooling off but the i don't want to spend more than two hours on it on a given day shall correct me if i get this wrong but we have that that's right yeah it was right yeah today and i was live in a higher commissioner right and i will okay great thank you so you can sit in increments of an hour i believe you can come in and sit how many hours you want to limit one to 23 and if it slips over to a day that's what we call the cool off period and then you can lock out for a day or three days okay and those are all configurable parameters if there are you know our regulations that govern that okay so you put it in that the regs required it's not something that's built in apps in a rag is that yeah what do you want to it depends it depends i don't think we have a hard and fast rule the reality is that as things are progressing you know we realize this is good for business and included if it's included somewhere because it's a new reg in that state inevitably it will get kind of added to the other states as they catch up from a technology point of view we're not we don't have a single stack that covers every single country and state but yeah it's certainly not cherry picked specifically for regulations if that option yeah no it does thank you can i follow up on that this is something that we've explored with a lot of applicants about giving a global footprint and experience and supergroup we have a bracket and we may need to be examine it on the cooling off periods am i right that you don't offer any notifications to the patron that the cooling off period is about to expire or do you i can answer that question if you don't mind we do not notify the customer madam chair so we will let that expire the customer would need to return we just feel that it's better for responsible gaming if they return the account will be accessible we will not notify them that the cooling off period is expired okay that's and that's the practice of around the world you know that your experience offers her is it in the united states i can't speak for every better division i haven't been in order no i don't want to that i've experienced you that has always been our approach it just seems to be the most sensible the most responsible approach thank you so help book to learn um all right anything else commissioners on the rgp's do you want to explore anything on page 1049 with respect to the compliance commissioners and i'm not sure if any if that could be and i'm not saying there's anything i just want to make sure it's a long document so i'm helping folks it's 1049 if i remember correctly each of those incidents is spoken to in the iab report am i right okay and so i was going to hold until then but i was just or more you know the remedial steps that have been taken since those incidents and i'm happy to i'm happy to wait until we get into the next section if that's helpful or or two sections from now section g just so that i understand a very limited um limited um chart that you filled out it am i right in saying that these are the the fines and yeah so there have been two um i i could call on my colleague marshal bruce got director of banking risk and operational compliance to speak to those now if you'd like or we can leave that for an executive session i'm not sure which you prefer we would we would turn to you to say i think uh council grossman that if it's in the public sphere we discuss it if not um i'll let you finish the sentence counts council grossman yes thank you no it would be helpful to at least begin the description of the matter and the issue and and if there's an outcome you can discuss and then pause when you get to a part that you feel would compromise any sensitive information i think marshal if you're if you're online it'd be good to have you uh chime in here just to discuss the the the transgressions themselves and their nature um i think they involve third parties in some instances so we may be have to trade lightly there but certainly we can put them on the table so the public is aware of what they are um and perhaps if we get to some sensitive stuff we can uh take that to an executive session marshal are you with us i am good morning okay so i will discuss both of them as bruce mentioned there were two the first one was related to a process described in our internal controls which we were not compliant with for a period um that was related to doing a tax identification check on registration um so not a regulatory requirement but a additional verification that we do on registration for roughly six weeks that check was not running therefore we weren't completing it once it was identified we notified um the relevant regulator where it occurred um and we had it fixed and then implemented additional measures thereafter to notify us if that check failed again on any account caused there for any additional questions mr skinner any additional questions sorry it's the first item listed um it's 1049 that's correct no no additional questions if we move on to the second one that is listed there that one had three separate counts i'll go through each one separately um the first count was related to a customer who was able to register two active accounts which is something that we don't commit of course regulation doesn't commit this occurred due to a fail in the duplicate account identification checks that we do at registration and thereafter um this was again identified by dgc betway we notified the regulator of it and the resolution there was enhancing the checks that were occurring um we do have a was the waterfall approach to identify customer who has an existing account and i should have referenced it in its presentation of the product as well so we look at social security number first name last name date of birth and a variation of those details on top of email address to identify if a customer has an existing account and those checks weren't running as expected so in fixing that we resolved the issue i'm assuming you performed an audit on the issue and my question is was was the issue just limited to the one patron it was the one patron um and then once it was identified we did run daily scripts to ensure that there were no further duplicate accounts registered during that period before we fixed it finally all right if i move on to the second count that is listed there um i don't have too many details on this one unfortunately this particular regulator runs a quarterly audit on the exclusion list as provided by them um when running the audit for q2 they identified for apologies for q4 um of 2021 they identified four individuals that weren't presented on dgc's exclusion list it wasn't escalated to us at the time so we couldn't investigate and identify why that occurred um but upon becoming aware of it june 2022 those individuals were no longer missing they were included on the list miss prescott i'm sorry could you repeat that last portion i i i didn't quite catch the ending there sure so when we became aware of the 14 missing individuals in june 2022 we did an additional audits on ourselves to try identify them we couldn't because by that point it had already been corrected by our processes commissioner skinner perhaps i can try and rephrase that the audit that the regulator performed on us in the quarter preceding had found us to be deficient when they notified us with deficiency the deficiency no longer existed in our system it had corrected itself so we could not go back and try and understand how that may have come to pass does that make sense yes that clarifies thank you right and then to move on to the third account that's listed there excuse me um we run a operated exclusion program referred to as the fairway exclusion program when a customer excludes with fairway only excuse me they will no longer be able to access their account deposit wager and they'll need to contact us to withdraw any funds in their balance we have functionality which allows us to run an electronic kyc verification on a customer directly from our back office and there was an error in that code where if it is run and the customer passes the kyc it would override the account status and make their customer activated so as part of a separate investigation in this customer that check was run which activated their account and therefore despite requesting the self-exclusion they were able to log in deposit wager and withdraw over a two day period again as soon as we became aware of it we notified the regulator closed that account and returned the funds to the customer we have also fixed that functionality so there is no way to override and exclusion status on the account and was this issue also limited to just one individual that's correct i think you said as a result of a separate investigation you came aware of the matter can can you speak a little bit about just in terms of what you mean by a separate investigation was it something connected to the vsc program or no so it was part of our ml compliance team to a review of the account okay thank you mr skinner are you all set on on that i am also thank you excellent thank you anything else on the responsible gaming commissioners do we feel that this um application has met expectations with respect to this section e i think i'm what was submitted they met expectations thank you commissioner maynard i think the applicant has met expectations okay well commissioner hill great okay excellent i feel the same and um again really appreciate the work going on in in virginia maryland um then we're moving on to section g oh i'm sorry section half jumping right ahead commissioner bryan's looking at me like um yeah so uh section f my geez my initial notes for that the flowchart was very very helpful that you provided um on section f for those who um are looking at the um large document is 1230 page 1230 um i see that you're using geocompy uh it looked it was less clear to me if you do everything in house on kyc and so if you want to elaborate a little bit on kyc for me that would be helpful who you um use or how it's yeah thank you madam chair let me ask marsha to step in and speak to that as well thank you sure so our kyc process happens at registration um we do use a third party electronic provider so upon registration when the customer answers the details we send that to the third party to verify those details um based on their response but as a pass we consider that as verified activate the account um the customer would be able to engage in gameplay if they do fail we request the physical documents which comes into the specialized team for review of those details we do also run an additional electronic check thereafter with the details that we have in the file to ensure there's no pet sanctions dmf concerns did um did i miss the naming of the um the phones that you use for the kyc or is it not in the application for some reason that's proprietary or protective no so we currently have three providers that we use across all of our states so there's lexus nexus ideology and id comply thank you yeah but i know that you you bring them as of course the top of the industry so thank you for that um other questions on section app and i'm sorry if i missed that any commissioners are we all set a commercial variety of the question it's more of a comment i'm just looking sort of for affirmation of it which is we've had some applicants come in who've been subject to data breaches um and we've talked to them about you know fixes and lessons learned and that sort of thing and when i did a quick search there was a reference to january of 21 over a betway uk um but i didn't find anything relevant to betway usa in terms of your operations here i'm just wondering it looks like that's the accurate state of affairs in terms of public data breaches connected with your platform i'm just wondering if you can comment commissioner bryan i think i could simply affirm that we've had no data breaches whatsoever in our us business i'm personally not even familiar with what may have happened in uk that's been used to me too but certainly not across the across the us business at all yeah the uk was really just an article about maybe some data being sold um can connection with people but not um sort of on the dark web but nothing that implied there were security issues at all um so it's a it's a pretty good record um and so i was just making sure that we hadn't missed anything so now kudos to you for that we're going to knock on wood a little bit too for you there um yeah i know i hope i didn't say it out loud i think i said one or one should always preface those answers as with as far as we are aware right right right now that this is not a just build on commissioner bryan's point um record if you could remind us um of your experience in the us i know that um it's been described as limited but of course um sports uh wagering in united states has been limited right uh compared to um overseas so since 2018 but you've your footprint here in united states has been two years is that correct our live footprint has been since march of 2021 um but certainly dgc is an organization as have been around since 2013 developing eye gaming content slot game is in related platform elements for the eye gaming industry um so that's how dgc came to be and then in 2019 we concluded the contract with the supergroups at surgery to take advantage of the changing regulations and to to acquire the rights to use the best way brand and to start the process to get ourselves live but we took our first bit in the early 2021 so that portion of it is is is low i mean for you know short from a time perspective so yes and then and that's across um how many jurisdictions again we are live now in eight in eight good other other questions on out okay hearing none do we feel that this applicant has met the expectations with respect to section this is commissioner hell and i feel they have met expectations thank you commissioner i agree thank you commissioner i agree thank you commissioner thank you commissioner so we're all set on section f i agree um and now we'll turn to section g some of this will come up of course in our um executive session with rsn questions that are for the public or or is there something else that's relevant to an executive session commissioners i'm all set and aside from what we are expecting to hear from rsm an executive session i believe the section meets expectations thank you any questions or agreement with commissioner schitter um just also pending the rsm i do have the questions that i raised earlier just given the the acquisition i'm not indicating i see anything deficient in the submission right now that's before us as as it was filed in november but the reality on the ground is a little bit different and so i am looking for the supplemental information that's the thing we can talk about later but nothing for executive session okay thank you any other questions commissioner maynard are you thinking are you an agreement with commissioner schitter at the stage yeah i mean we we typically go over some of the ieb report we did that in open session um really good compliance work is what comes to my mind and i would say that um they've met expectations okay and and forgive me i'm um i think commissioner hill has weighed in but i don't i i may i on this did you weigh in yeah i haven't weighed in but okay let's thank you but in my view they have met expectations thank you commissioner no all right commissioner brian barring any other questions and i'm abstaining at this point madam chair just given what i said oh because of and commissioners i want to make sure that we respect that it's the same some of the questions that she raised earlier applies here so do we want to actually revisit this i'm fine with revisiting excellent is are you okay with that commissioner schitter as well i need to be reminded of those questions i'm sorry no problem i mean is it it's relative to the um parent entity now okay okay yes okay thank you thank you yes there's some overlap right yeah so then i'm fine with me visiting okay thank you so much all right then we'll we'll pause on on h and it was a pause on on um on b correct all right so i think it sounds like we need some lunch um perhaps so um it is just after one o'clock we've gone through the sections we have a couple to revisit but we also plan on an executive session i think it makes sense before we we pause lunch to go over what we expect to cover an executive session so grossman sure i have three items on the list the first um as we have customarily done relates to asking the applicant and rsm to provide specific information relative to financial projections trends and associated methodologies applied in developing those projections and evaluating the data including as they relate to the revenue projections the market share projections handle and hold percentages and other information associated with those issues including relative to the applicant's financial stability and overall stability number two uh pertains to the background and an explanation from the applicant relative to the timing of its launch vis-a-vis the march um allowable go live date uh within this category and any associated issues that may be attendant to that particular matter the third one and commissioner skinner this one you raised i wanted to make sure i got this right and perhaps you can uh offer a little further explanation but this one pertains to their marketing budget and the associated spend figures and how they may apply to the massachusetts market should they become licensed can you refine that issue a little bit commissioner yeah it more pertains to this diversity spend and so yeah and and so i believe mr watermire was tying the marketing budget to that somehow okay so it's the the diversity spend as it pertains to the overall marketing budget and how it may be affected in the massachusetts market my question and request is it limited to the marketing budget so i'd rely on mr watermire to explain that correct that's that's understood i think you're trying to get a sense for the real don and sense spend on minorities and the like in in massachusetts and the only way to do that is to talk about some of the spend numbers that we have not just marketing that's right right and then the the um diversity spend numbers as compared to the overall company spend right okay let me just make sure i got that okay the the only other issue and i i believe um it seemed as though the explanation offered by mrs brosgaard was satisfactory related to those compliance matters and there were no further questions on that so i didn't include that on the list but i just wanted to note that so my list includes just those three aforementioned issues and if that is in fact the whole list and my explanation is consistent with the expectations then in my opinion each of those relate to competitively sensitive information it was all provided in the course of this application and disclosure of these pieces of information and materials in public would place the applicant at a competitive disadvantage accordingly it is appropriate to move to go into executive session to discuss those subject matters and i think it would make sense if we're going to move in that direction that we do this now um to let the public know that we would we turn some time after our lunch break but that we would return in executive sessions should we so far right okay so commissioners you know that i have to read this into the record under the open meeting law the commission anticipates that it may need an executive session in conjunction with its review of the digital gaming corporation usa application in accordance with gl chapter 30a section 21 a 7 and gl chapter 20 and section 6 i consider information submitted by the applicant in the course of its application for an operator license that is a trade secret competitively sensitive or proprietary in which if disclosed publicly would place the applicant at a competitive disadvantage we have a motion madam cherry move that we go into executive session on the matter delineated by general counsel grossman it's the recent stated by the chair okay any questions commissioner hi commissioner hill hi commissioner maynard thank you commissioner schinner well i have commissioner maynard hi i wish you could see what i'm seeing so you would understand there's logic behind this tired brain commissioner schinner and hi commissioner maynard you've said i and i vote yes thank you five zero we will move into executive session and we anticipate returning to the public session sometime after our lunch in completion of the executive session but crystal should we be put into our yep if we could just join the magical room that would be great yep okay thank you uh dave thanks dave okay okay this is a reconvening of the massachusetts gaming commissions a public meeting we've been in executive session and took a short break at the conclusion of executive session and um because i'm holding we're holding this meeting virtually i'll do take a little call from brian i am still here and not mobile i am here you're still here okay thank you um commissioner hill i saw that you might be able to be listening i i too am still here thank you um come um commissioner schinner front of the senate i'm here excellent and commissioner maynard i'm still here all right we'll get started so again thank you to our applicant for our patients as we consider its application um we left it where we had a few matters that we had to attend to and so we put a hold on section b and section g so we've been able to get a good deal of information and questions answered um at our executive session i thought i would take a the temperature of where we are on on section b commissioner maynard um madam chair i believe the applicant's met expectations except i believe we will need to seek supplemental information regarding the launch date um as we discussed in the executive session general commissioner brian from cleaning in yeah the only thing i would be more specific on his um specifically is to the b4f1 part of the applicant submission um which i believe is the area that um commissioner maynard is talking about as relates to the launch date yes i forget what page it was on and scrolled but let's go with the uh section itself um commissioner schinner definitely my fellow commissioners in that madam chair okay and uh commissioner hill yep i agree as well thank you okay excellent um and then in terms of section g turn commissioner maynard again um madam chair i believe the applicant has met expectations except i believe um we would like to seek supplemental information around supergroups entity and individual qualifiers yeah but yeah that's consistent with what i was looking for it's just because of the change in uh corporate structure that was effective a few days ago just looking for them to be with ib and change that i know that the timing isn't going to get to us before next week and to the extent that there's a license awarded i think a further condition in terms of timing on that can be set out but i would agree with what commissioner maynard just said commissioners i did speak with loretta lilios just now um about what the status is with respect to supergroup and the licensing process so i think she can give you an update and then we can figure out the exact mechanism that would work for the commission hi uh good afternoon so our licensing chief caro bryan has been in active communication with the applicant about the supergroup acquisition she has actually already received like documentation that would be consistent with the scoping survey like she's got the organizational charts and so forth it's just a meticulous process there's not only the super group ownership line that she's working on but there's a separate a couple of shareholder groups that she's working on she's well along in that process i don't want to over promise for her but you know she's very close to having the designation letter completed at that point after the designation letters completed it's it's possible that the applicant could get all of the attestations that you look for in a very short period of time of course the applications themselves may take the applicants uh longer uh is that helpful can i may i madam chair may i ask a question of the applicant uh you know hyal or any other jurisdiction has supergroup been scoped and submitted any kind of application with it in with respect to gaming has any other jurisdiction done this analysis i believe so i think william leith can probably add a bit of color to it but pennsylvania new jersey indiana have all not only received applications but approved the transaction are higher they're filed and well what am i forgetting i can't remember specific states but a number of the states in which we're live required us to required supergroup that is to file in order to approve the transaction which took place on the 1st of january so the sure answer to your question is yes pennsylvania and indiana specifically i believe new jersey as well new jersey also bruce here we go so with that is there any um is that helpful uh karen or well just wonder how you could explain the process i'm just going to defer to la rata but one option would be in the interim while we are doing our process if they already have you know the designation letters from the most recent jurisdiction that did scoping and they could submit the forms and they could submit the attestations in the next couple of days just so at least we have that in the record it's a thought but i'll defer to the iv because that's their area of expertise well we could certainly uh coordinate that you get the designation letter from another jurisdiction if the applicant would provide that to us and then we can provide our attestations and then all the people on that list from the sister jurisdiction uh you know we could look to um you know pennsylvania might be a good one to look for perhaps you could send we can have an offline converse or maybe not offline we can if you'd send pennsylvania and ohio those would be two two good jurisdictions we can look at that list and ask for attestations on the combined individuals and entities on those lists and if the commission is comfortable moving forward with those attestations we can coordinate that that process with you for you you know the the rest of the process taking getting in the actual applications would i anticipate take take longer and you know doing a report even similar to the report uh that we've done uh on preliminary suitability we would need a little more time for that but if you're comfortable moving forward on the attestations for qualifiers into sister jurisdictions with the applicant's help we can we can coordinate those documents michelle brian yeah i mean i think between now and when we come back next week i'm comfortable moving forward in that regard and again if we get to the point where we're discussing licensing for this applicant i think that there's mechanisms to put shorter conditions on in terms of a timeline that also works with ivy to get the supplemental report we can send to you what's that yes thank you okay that's great tishers do you agree i'm i'm very uncomfortable um as well okay um christian hill i'm not hearing any objections so no objection from me madam chair excellent all right thank you to i e b um oh this is a dynamic process and we appreciate everyone's nibble so thank you um okay so with that we have done our review of the the sections of the application and as it's been mentioned we are very anticipating uh moving as a commission over the 18th and the 19th and possibly into the 20th to do our um our full full-sum assessment of all the applicants who are seeking to do business as an untethered category three online sportsway operator um i guess we do have other considerations i want to turn back to uh council growthsman is there any is there anything outstanding now before we close no i think with that you actually covered everything that was outstanding was the supergroup qualification issue and then the supplement to the application of uh commissioner maynard spacecraft commissioners you're satisfied um is there any other information you're seeking to either get clarification or supplement this application i see i see all knows and i'm not hearing from commissioner hill must be all set as well all set okay all right well it is a Friday and it's about four p.m eastern time seems like a good time to close up business i want to thank this applicant for all of your time today it's been it's been a very interesting application and we appreciate all the work that went into it and your interest in doing business here commissioners would you like to address the applicant at this time now thank you um pure time like i said there was lots about this application that are stellar um you know we've asked you for supplemental information but i don't want that to take away from the other parts of the application that we lauded you on earlier so probably isn't a long weekend where some of you are but have a good weekend thank you commissioner skinner i also want to add in in my thanks to the applicant and and its team appreciate your hanging in there with us literally all day i think but uh look forward to receiving the supplemented information commissioner maynard i want to thank you for your presentation and your time and uh and wish everyone a happy doctor dr king day on monday thank you and commissioner hill i'm going to steal a line from commissioner maynard and say when you go last there's not much else to say so i'm just going to say thank you uh for your time and thank you for hanging in there with us and i too wish you all a very good weekend thank you all right everyone um madam chair if i may yes i was going to turn to you mr. wiremire yes i'd like you about to close it out i just wanted to convey our very sincere thanks for for the opportunity to speak with you today as i said in the outset i know you've been listening to having sessions like this all weekend last week uh commissioner hill extended thanks to you given given medical treatments and all the rest of it underway it's it's it's amazing so thank you we're committed to massachusetts and appreciate the opportunity to refile and resubmit and it is our sincere want to address the challenge of timing so we will be in touch with you course thank you and have a wonderful weekend thank you and we'll coordinate with um uh the iev and we appreciate everyone's uh hard work for the whole team here um from the mgt team whoever's here we thank you for all of your good work on this application and everyone have a nice weekend with that i need a motion to adjourn move to adjourn madam chair second thanks commissioner okay commissioner brian hi commissioner hill hi mr skitter hi commissioner maynard all right and i vote yes thank you five zero thank you so much