 Thank you. I do see that you're in a conference room. And so when we go on our streaming, I'll just need to maybe be reminded of names because we can't quite see you and I don't have the benefit of the little, the name. So maybe each time you speak, if you can find us of your names, but I'm so glad to see you. And I thank each of you for joining us. The gaming commission meets publicly and we have to do that pursuant to the open meeting law. So we also stream as a courtesy so that folks can access us easily. So with that, good morning and a day where I'll set to go. Yep, I'll go. Thank you. I'll set, thank you. All right, good morning, everyone. This is a convening of the Massachusetts gaming commission because we're doing this virtually and we need to take a roll call. Good morning, commissioner, Brian. Good morning, I'm here. Good morning, commissioner Hill. Good morning, I'm here. Morning, commissioner Skinner. Good morning. And good morning, commissioner Maynard. Good morning, I'm here. Excellent. So today is January 10th and it is public meeting number 421 and we are continuing our evaluation of category three sports wagering online operators applications. And today we're very pleased to have a presentation and demonstration and consideration of the application of better. So, and actually it's the full name is better holdings name, but we'll say better today. And we are looking forward to your presentation. Good morning. Good morning. Yes, hi. Good morning, madam chair and commissioners. My name is Ashwin Krishnan and I'm head of legal and business affairs at better holdings name and I'm also known as better. On behalf of everyone at better, we want to thank you for the opportunity to speak with you today about our organization. I appreciate all of the hard work in efforts the commissioners and the staff of the Massachusetts gaming commission to allow for sports wagering in the Commonwealth in such a thoughtful, deliberate and responsible manner. We look forward to speaking with you today about our product and marketing plans, our values and our commitment to offer the residence of Massachusetts State in responsible way in which to participate in sports wagering. We welcome your questions and feedback and we'll be honored and privileged to receive a category three sports wagering operator operator license from the Massachusetts gaming commission. I'm joined today by several of my colleagues including the following individuals who will be hearing from shortly. Joey Levy, our founder and chief executive officer. Jake Paul, our founder and the president. Alex Ursa, our head of gaming. Mike Dinevy, our head of media. Adrian Figueroa, our head of finance. Elizabeth Lodge, our brand strategy and partnership lead. Robert Warren, our compliance manager. And Victor Pires, our business operations lead. And don't worry, everyone will introduce themselves again when they speak. The following individuals will also be available if needed during the session. Chris Bevilakwa, the chief executive officer of SimpleBet, Melissa Davis. The EVP business development general counsel of SimpleBet and Michael Abramson outside council. With that, we'll turn to our presentation. Victor, you're gonna share the screen? Yes, it's a great H3 meeting. We need to quit and reopen it. We have to jump back and... Okay, give us one second. Yeah, no problem whatsoever. And the mills, I know that you're there and Dave, if they need any technical guidance. We don't evaluate based on this. It's always a challenge, it seems. We'll see if that worked. Commissioners, can you all see the presentation? We can, thank you. Great. So turning to slide two here, our agenda. We looked at the criteria set forth by the MGC in evaluating category three sports wager and operator license applicants and have prepared an agenda that we believe will address all the elements set forth by the MGC. First, we will provide an overview better, including its gaming and media businesses. Next, we will introduce you to our founders and executive team and highlight their relevant expertise in this field. We will then provide an overview of our sports wager and platform, including its technical components. Following this, we will highlight our dedication and commitment to responsible gaming throughout all facets of our organization. We will then address the economic impact we expect better to have within the Commonwealth and highlight our contemplated Massachusetts focused initiatives, including working in conjunction with the Massachusetts Lottery. Next, we will turn to our diversity, equity and inclusion efforts, both from a workforce perspective, as well as a supplier spend perspective. We will then discuss in more detail our advertising and promotional plans in Massachusetts. Finally, we will conclude by discussing the matter's licensing and compliance track record. One note I'd like to say as well, we are excited to share our product and vision with the general public. We have designated several sections of our application as confidential pursuant to Massachusetts Public Records Laws. So if there are questions in those areas, we will respectfully request to go into an executive session to further discuss such items with you. With that, I'll turn it over to our founder and CEO Joey Levy to kick off the presentation. Awesome. Thank you so much, Ashwin. Hi, everyone. My name is Joey Levy. I'm the founder and CEO of Better. Thank you so much for having myself and the team here today. We are grateful to be here to have the opportunity to receive the honor and privilege of receiving a sports wagering license in the great state of Massachusetts. On this slide, you will find a high level overview of the Better Business where you will see we have two core businesses, gaming and media. Our gaming business is predominantly initially differentiated by a reimagined simpler and more intuitive user experience, as well as a focus on micro and in-play betting. Although as you could see on the chart here, we also have a free-to-play business, a real money fantasy business and an online casino business. On the media side, we are focused on original short form content and the two core pillars of our strategy include premium franchises and always on social. Despite launching our free-to-play app just about five months ago, we already have over 120,000 downloads and multiple top app store ranking appearances. And despite also launching our media business a little bit over five months ago, we are the fastest growing sports betting media company in the country and are already the number two sports betting operator on social by many measures. You could go to the next slide. So here you will find the better team, a little bit about my background prior to better. I was the founder of SimpleBet, which is the B2B technology company that leverages machine learning and real-time technology to pioneer micro betting on U.S. sports. And the company is currently licensing technology to companies like DraftKings, Caesar's, Bet365, among others. I've started this business with Jake Paul, who's our founder and president. Jake is an entertainer and professional boxer who's headlined some of the highest-grossing pay-per-view events in history. He's a top five global creator and media mogul and his social media presence alone is larger than many notable sports media companies, including Fox Sports, NBC Sports and some of the household names that we're all familiar with. We're also on the executive team side joined by Alex Ursa, who's our head of gaming. Alex is a product leader in the real-money gaming industry with over eight years of industry experience. Prior to better, he spent seven years at Flutter across Betfair, Patti Power and most recently, FanDuel, where he was part of the team that helped build FanDuel into the clear U.S. market leader as its senior product director. At FanDuel, Alex focused on launching new jurisdictions, new products and was part of the leadership team that launched five online casino states and 14 online sports book states with a focus specifically on regulatory compliance responsible gaming and helping author their state-by-state go-to-market playbook. Also joined by Mike Dinevias, our head of media. Mike spent the past 10 years at Bleacher Report where he worked his way up from being an intern all the way to founding and operating BR betting which quickly became the number one sports betting media brand on social in the United States. Also joined by Ashwin Krishnan, who's our head of legal and business affairs. Prior to better, Ashwin spent the prior 12 years with the Miami Marlins where he gained extensive business and legal experience as their most recently as their general counsel playing an integral role during a period of rapid growth crisis and significant change. And also joined on this call by Elizabeth Lodge our brand partnerships lead who has extensive experience in the sports media business. Adrienne Figueroa, our head of finance, Victor Pyrus, our business operations lead and Robert Warren, our compliance manager. And a common theme you'll notice with the team is that we all collectively have significant experience across sports media and entertainment specifically with a proven track record across disruption and innovation. You go to the next slide. So here you'll find a high level overview of our gaming business as I've noted at the top and consistently throughout the application. We are initially focused on micro and in play betting within our sports betting business but we do have these other verticals within our gaming business. The initial one we launched was Free to Play which we launched on September 1st of 2022. We're currently live in all 50 states excluding Washington and Nevada. And we view Free to Play predominantly as a registration and onboarding platform mixed with an interactive tutorial for what's really a new and bespoke user experience around micro and in play betting. On the sports betting side, as I've mentioned initially focused on micro and in play betting but ultimately plan on offering most forms of sports wagering over the long run. We actually launched our first licensed product as a day one operator January 1, 12.01 AM in Ohio. And we're gonna pursue a pretty gradual and methodical state by state rollout. You know, we've observed how some of the other sports betting operators have rolled out their products and businesses. And as you can imagine as a startup we need to be very prudent and methodical with how we spend our cash. And we do think that we're one of the first if not the first offer of fundamentally differentiated product experience in this category. And as a result of that, we wanna take our time to really understand product market fit and make sure that we have a value proposition that is really resonating with consumers. The current applications that we have outstanding are as obviously noted here in Massachusetts, Virginia, Indiana and Maryland. So those will likely be the first five states including Ohio where we launched sports wagering assuming we received the honor and privilege of receiving a license in each of those jurisdictions. We also plan on launching a real money fantasy business potentially as soon as later this quarter. We plan on launching that business in over 30 states. And we view this as a simple pre-match experience that complements our predominantly in place sports wagering experience while also candidly enabling us to generate revenue on a more nationwide basis in an interim period where again to support this gradual and methodical state-by-state expansion for sports wagering which has a different set of costs associated with it. And finally, I'll note that we also plan on launching online casino either in the back half this year or in the first half of 2024. And we're in the very early stages of that and then still sort of evaluating exactly how we're gonna go to market with that experience. We'll go to the next slide. All right, Mike, you wanna take this one? Yeah, I can't think of that. Jake, do you want to do this as well again? Yeah, what's up everyone? I'm Jake Paul, known for being a creator, boxer. Most recently, I paired both of these passions together into founding Better with Joey here. And like Joey said, we have two branches and the first being the product which you just heard Joey speak about. And the second being a sports media company where we create original sports shows and videos with dozens of talent including myself, a million dollar Marco, giving you a new way to view sports. Our goal at Better Media is to deliver new content that's easy to consume, that gives you the updates, makes you laugh, gives you the highlights and that goes inside of the minds of your favorite athletes. Essentially an honest take on the sports industry and fans experience. And I am mostly grateful for the team around me at Better, the advisory board, Joey, Dineve, Liz, who will, they'll speak here in a second but they are high level business executives and professionals involved in this business and their track record speaks for themselves. We also have a talented and growing team of young professionals on the media branch of our company. Everyone's like a super hard worker and it's what excites me the most about it. Even Alex Ursa on the product side is a wizard and without a strong team, it wouldn't be possible to launch and be here with you today alongside other legacy betting organizations. So yeah, I mean, I thank you guys opportunity to present the better business to you today and we'll allow others on the media and product teams to walk you through our detailed approach and strategy to like how we look at the media side of things and what we are doing and what we believe is effective and responsible. So, Mike, is the head of the break? Got you. Mike Dineve had a media app better. Echo, everything Jake said. Very honored to be in front of y'all today and nice to meet you. For us as Jake Echo, we are on mission here to grow this team to be the best in class. We built out robust social production, original content, partnerships, growth, talent teams to really rise into being what you can see here in bold, one of the top sports betting brands on digital and social in five months since launch. We've been asked close to a million followers across all of our platforms through the strategy of one being always on on social. What does that mean? 365 topical reactionary to the biggest stories in sports and sports betting, original short form content, partnering with creators locally, hopefully in Massachusetts and across the nation to create kind of episodic short form content that we can deliver to our audience in an organic way. And then lastly, as Jake mentioned, creating these premium franchises in which we can start to kind of challenge traditional linear media and use it with celebrities to bring new perspective to a sports audience. So, we'll get into a lot more of this throughout the slide, but I'll take it to wisdom as well. Hi, everyone, Elizabeth Lodge, New England native originally from Rhode Island. And so, for me personally, this is an honor to be considered from Massachusetts for our second suite. As Mike said, and Joey and Jake mentioned as well, I am the brand strategy and partnerships lead for better media. And look forward to walking you through our overview and approach with the next coming minutes. So thank you. Awesome, thank you guys. So some quick notes on the better sports wagering platform. So, as noted, initially focused on enabling micro-bedding and eventually all forms of in play, sports betting while maintaining a strong focus on simplifying the sports betting user experience for a wider audience of casual sports fans. Our sports wagering platform offers micro-bedding for three sports currently, basketball, baseball, and football across five leagues, NBA, NFL, MLB, college basketball and college football. By automating all market mechanics, we ensure market creation, suspension, resulting in repricing happen in milliseconds, which minimizes suspension time and ultimately enables a better user experience. And one core product differentiation that many in the industry aren't really talking about is this idea of bet delays. And we've actually eliminated bet delays from the in play betting experience. So essentially the delay between the customer placing a bet and when our system accepts the bet is nearly instantaneous as opposed to the two-day second buffer that you typically see with other sports wagering platforms. Could go to the next slide. And to summarize at a really high level, everything we do it better from a product standpoint is really sort of delineated within these two core product tenants. One is simplifying the sports betting user experience. I actually got involved in this category because I remember when, you know, I was initially interested in sports betting and I saw things like minus 175 money line plus five and a half point spread. I saw 49.50 slash U, which ultimately I later learned meant over under. But I felt like those experiences were too complicating and intimidating for myself who had a fantasy sports background, if anybody should have been able to intuitively pick up the experience should have been me. But ultimately I felt like the consumer experiences in this category left a lot to be desired if we're really gonna use sports betting as a way to enhance the consumption of sport as opposed to sort of a financially motivated almost like spreadsheet transactional layer which is what many of the legacy platforms looked in and felt like at the time and still feel like to be frank. So really focused on simplifying the experience and if you see the spreadsheet or not the spreadsheet, the screenshot on the right, you'll notice that the betting markets on better really displayed an intuitive multiple choice questions. We've gotten rid of traditional American odds like minus 175 and plus five and a half and added more intuitive pad multiples with the objective that anybody, any sports fan, even if they have not been on sports before should be able to pick up and intuitively interact with the product experience. And then of course the second core product tenant is the focus on micro and in play betting. One, if you really zoom out and look at sort of the history of the sports betting marketplace, the global marketplace as you all know has historically been driven by soccer which is a fundamentally different sport than US sports soccer is a fluid game without a lot of discreet occurrences, without a lot of scoring, without a lot of moments to bet on. But if you think of the composition of US sports, they feature a very stop and start cadence. There's a lot of scoring, there's a lot of speculation over superstar players and what they'll do next. So as a result of that, we think that micro and in play betting may ultimately emerge as the predominant way to bet on sports in this country but it requires a really dedicated product focus which is why we're building, you know, essentially an entire company around it. You could go to the next slide and here I'll hand it off to Alex to talk about the technical standards and features of the Sportsway Dream Platform. Hi, everyone, my name is Alex Sousa. I'm head of daily care there. I'm very honored to be able to present this for you today and also very honored to be considered as a licensed candidate for the Commonwealth of Massachusetts. We're gonna go through a few technical standards and features and then later after the presentation we will also do the product demo. As always, if you have any questions I'm more than happy to answer them. So I think for us the key point that we wanna point today is that we have taken a different approach as Joey said and that's really to ensure we simplify the customer experience. We create a secure environment both from a, I would say identity, money and responsible play perspective. I'm gonna start with account registration. I think the biggest difference between us and other platforms is that as you're gonna see later when someone is creating an account we are also verifying the phone number on the spot at account creation. That allows us to make sure a customer has access to their device and also allows us to enforce two factor authentication to make sure no one is able to access the patient's account without their knowledge. And also when someone is creating an account we are sending them a welcome email. Secondly, identity verification. We have best in class identity verification with our pass rates being significantly higher versus the industry. Our focus was really on allowing customers to pass their identity verification in a simple way. That's also compliant. We have photo age checks. You're gonna see again later you're not gonna be able to actually select an age that if you're under 21. Also very important versus other sports books better will never manually verify customers from the back office to eliminate human error risk or any kind of social engineering when someone then try to take or steal someone's identity. Then secure account access again because we do that phone number verification at account creation we are able to enforce two factor identification. So that means when a customer is using a new device or they come back after a long period of time we will send them a code on their phone number making sure that the person who's logging in the account is actually the account holder. Then moving photo to the enhanced deposit checks we have this was one area of focus for us making sure funds are secure. And first of all as we're gonna talk in the responsible gaming part we do not allow kids in any US jurisdiction. Better is actually the first US operator to not accept credit cards on their platform. Also we have an advanced address verification service so when someone is using a debit card and they need to enter that address we make sure the address they are entering matches the address that is attached to that card. Again making sure the person who has the card is using the card is also the owner. And of course for all methods we will do name validation. Closer withdrawals this is another key feature for us. This will allow a customer to withdraw funds only to a method that they use to fund the account. So I wouldn't be able to use let's say a debit card and then withdraw the funds to PayPal without making a deposit with PayPal. Again this will allow us to make sure the patients are using the same methods and helps us steer away fraudulent and bad actors. Geolocation checks as you know this is the industry standard across all jurisdictions. Regulatory reporting, this is again one item that's very important for us. We would be able to provide the NGC access to comprehensive regulatory reporting both on the financial side and also on individual player at the responsible gambling. Our core focus would be responsible gaming. I am very passionate about responsible gambling. At my time at Fendule and also at Betta I always advocate responsible gambling. And we're gonna discuss more later but we have all the industry features plus some additions like banning credit cards across all jurisdictions and introducing the concept of automatically deposit limits for customers between 21 and 25 and more importantly again we're gonna do that in the demo section a user can set up wager or deposit limits as part of the onboarding process. So before they make any deposit or place any bets they have the option to set up a limit which is again something that we are taking the leadership and then change management is we're gonna be able to provide NGC clear overview of how our platform is evolving how our platform is licensed certified and what changes we're making and what kind of changes we're making. In terms of certification and approvals we received our mobile management service provider in November from Ohio that allowed us to launch in January 1st with other operators. In terms of GLI certifications we received individual GLI 33 certification letter for the betting engine and also for the player account management but also we received the individual GLI certification letter for Ohio and for Virginia also we have been reviewing the Massachusetts regulations and working with our partners making sure we will be able to comply and receive a certification letter for Massachusetts if we get the privilege to be approved for category three license. Joey back to you. Thank you Alex. So we have a few slides here dedicated to our responsible gaming approach and I'll just kick this off really talking about our philosophy around responsible gaming which was really informed by these two key points. So one being aside from responsible gaming with respect to every decision we make at better we believe we must exhibit a long-term mindset if we're gonna be the category defining business by the end of the decade which we have every intention of ultimately becoming anything that potentially enables problem gambling will ultimately prove to be unsustainable detrimental to the long-term viability of this category in general and while it may bolster revenue today it will increase customer turnover and introduce regulatory scrutiny tomorrow. The second point which should be a seemingly obvious one is that we're not interested in acquiring users who are gambling with money that they do not have and we could not think of a clear way to articulate this to the regulatory community the industry, our employees and most importantly consumers themselves then by banning credit cards as a method of depositing with respect to all of our real money gaming products. We go to the next slide. So just to sort of reiterate that point last quarter we announced that better would be the first regulated US operator to proactively ban the use of credit cards as a method of depositing while also announcing that we will by default introduce wager and deposit limits for young betters aged 21 to 25 years old. Could go to the next one and I'll let Mike talk about our responsible advertising strategy on the media side. Yeah, hey everyone, Mike and Amy again. Yeah, on the media side and the advertising side this is top priority for us. You really can't go to anywhere better on digital and not see over explicit responsible gambling messaging in terms of end cards, captioned call outs lower thirds, threaded messages. We're also creating bespoke content as our organic strategy is to create original content at a very high volume with that obviously needs to be the responsible gambling content as well. And we take that very seriously. And for us it's like we can't just be checking boxes here. We can't just be saying we need to do this in our bios and we're thinking about this every day on how we can be as explicit as possible to make sure that this is featured across all of our content. And that includes 21 plus, which is obviously a huge priority and we're not featuring marketing targeting anybody underage, including the 1-800-12 if you have a hotline at the lowest end of the health everywhere. And I was just going to show you that it's very important to us that people aren't gambling more over what they don't have and messaging that across. We launched in Ohio obviously a few weeks ago and you can see on the right there's numerous call-outs and praise for our efforts here across the press and industry and we're going to continue to work very closely with the OCC and really make sure we're as transparent as possible and continue to be innovative in this category to make sure we're for the industry. Yeah, Alex will start back. We're going to talk a bit about the player subservice control. So first of all, deposit limits, we allow players to set a limit that they want to deposit daily, weekly, monthly and we said deposit and wager limits will be by default for age between 21 and 25. Wager limits, again, you may be already seen this with other providers but this allows a patient to set a specific amount that they want to wager daily, weekly and monthly or also maximum single bets or somehow doesn't want to bet more than $20 on any given bet, they can set that. In terms of time limits, you can set up a specific amount of hours that you want to use, you'll be able to use our app every day. Then in terms of reality check, we have this on by default, gives customers a notification every 15 minutes to the length of time they play and the amount of money they wager during this time. Cool off periods, functionalize a short set of exclusions from the app and we'll arrange from three days to 365 and then self-exclusion is an extended break or block from the app with periods of one, three, five and lifetime. Also, we are already ingesting a self-excluded list from Ohio and we process that once an hour even if the requirement is to do it once a week, we process that once an hour. If a patient that's on that list tries to create an account with us, we are blocking them or if they create an account from the last hour, we're gonna also block them. We'll be more than happy to ingest a similar list from MGC and also we will be more than happy to if needed to open our list towards the gaming commission if they wanna share that with other operators. Yes, also once a cool off or a self-exclusion period is set the patient is not allowed to decrease the time and at any point they can contact us to extend the duration of the time period and that will take effect immediately. Robert? Good morning. Good morning, distinguished members of the commission. Good morning team. My name is Robin Warren and I have the honor of being the compliance manager here at Better. My background is in regulatory compliance. I'm a former gaming regulator from two jurisdictions. I served as a casino compliance rep for the Maryland Lottery and Gaming Control Agency and I was the investigations and enforcement agent for the Office of Lottery and Gaming in the District of Columbia before beginning my journey here at Better. Basically I'm the whip. Better is dedicated to providing the highest standard of customer care. This has been built into our company culture as well as our sports gaming operations where responsible gaming is a top priority for all personnel as illustrated earlier by my colleagues. Our responsible gaming plan provides the framework from which Better will ensure its practices are consistent with the community's expectations and that the sports, leisure and operation will be conducted in a responsible manner. Better will take all the necessary steps to promote responsible gambling on its sports, leisure and platform as well as enforce all regulations pertaining to responsible gaming to include prohibited patron enforcement. Better requires all individuals to acknowledge and confirm their status as an additional step in preventing prohibited persons, restricted patrons and participants of the voluntary self-exclusion program as outlined in Title 205 Code of Massachusetts Regulation 233 from creating an active sports, leisure and account. A player account will automatically be blocked if the first name, last name, date of birth and social security number in the Better database all match that of a prohibited person on the Massachusetts database. Better will review any fuzzy matches when not all but some of the identifiers match a prohibited person and take the appropriate steps if there's a match on the prohibited list for Massachusetts as well. With respect to underage enforcement, Better makes diligent and persistent efforts to prevent underage individuals from gambling. All applications offered by Better will require users to be at least 21 years of age. Better communicates to the public the legal age to gamble through advertising and marketing outreach material and via Better's player protection page. Of course, Better will adhere to all requirements of Title 205 Code of Massachusetts Regulation 250 referencing the protection of minors and underage youth from sports wager. Better monitors our patrons and their gaming patterns to identify signs or triggers a problem gambling, assessing and addressing situations where a player indicates they are in distress or experiencing problems. Better is working with responsible gaming advisors and consultants to implement a rigorous responsible gaming platform across our product, media and business operations. Better recently met with Marlene Warner and Chelsea Turner at the Massachusetts Council on gaming and health. I'm sure this is nothing new to you but I believe that it's absolutely worth mentioning that the Massachusetts Council on Gaming and Health has been at what we would consider the forefront of RG research. Better is looking forward to further discussions with them on incorporating the game-sense framework to include the game-sense advisors into our responsible gaming program and other areas that they can provide assistance and as we continue to make good on our pledge to improve our overall RG culture. We also met with Mr. Keith White from the National Council on Problem Gambling. In that meeting, we discussed the abundance of opportunities that we are looking forward to pursuing in collaboration with the MCPG. Some of those opportunities include live employee training, RG policy and advisement services, brand placement and ICAP certification. And for clarification, ICAP is the internet compliance assessment program based on the internet responsible gaming standards devised by a panel of gambling, harm prevention experts from around the world. I think it's worth noting as well that in that meeting it was stated that the MCPG was looking forward to working with Better in hopes to create a disruptive and innovative RG program and also in hopes that we could provide much more value than the legacy operators have historically been willing to. And last but not least, Better is working with iGaming Academy to ensure all full-time employees and key contractors complete required training on topics such as anti-bibrary, code of conduct, equality and diversity, responsible gaming, sexual harassment and online sports book. We require all new hires to complete this mandatory training. We also require mandatory refresher courses for all employees and key contractors. Again, I wanna thank you for allowing me time to present. I would now like to pass that baton back to my colleague the head of business and legal and business affairs, Mr. Ashwin Kershman. Ashwin Kershman again. One of just in addition to everything mentioned by Joey, Alex, Mike and Robert, note that Better is also proactive in terms of the Form and Compliance Committee to add an additional layer of accountability to our sports wagering operations. We've secured the tentative commitment of three highly respected individuals to provide independent oversight of our operations. A.G. Burnett, the former chairman of the Nevada Gaming Control Board, Mark Dunn, former general counsel Veristicrat and Sarah Tate, former executive director of the Indiana Gaming Commission. The Compliance Committee's specific scope and functions will be guided by the knowledge and experience of its members. Hi, Adrienne Figueroa, Head of Finance. Thank you all for meeting with us today. In terms of the economic impact of the business, Better is uniquely positioned to expand the addressable market for sports betting and the Commonwealth and therefore the revenue opportunity for the Commonwealth given our unique business model and positioning which can be highlighted in three key areas. To the first, being an intuitive interface and experience that cater to the casual sports fans. So as Joey has alluded to earlier in the presentation, the way that typical sports books display odds is simply adds a lot of friction to the experience and is intimidating since the casual sports fan doesn't know how to interpret minus 350 money line, minus five and a half spread, minus 110, et cetera. And so if you look, there's a massive delta between the number of sports fans in the US even in the states where sports betting is already legal and the number of active sports betters in the country. And we believe that the key reason for this massive discrepancy and why the market is so under penetrated is because the casual sports fan just doesn't understand a lot of the terminology and it's not really catered to that. And so our interfaces you can sort of see on the right here is extremely intuitive to where the average sports fan can pick it up and immediately understand the product and know how to use it. The second pillar to this is our primary focus on micro and live betting. So we view this as an ancillary segment of the market that really expands the addressable market whereas other operators may be focused on the same match outcome based odds. Better wants to become synonymous with live and in play betting, which really just expands the entire pie of the sports betting market and offers users more choice. Lastly, as we alluded to several times is our marketing and brand awareness strategy given our media content side of the business led by Jake Paul and his 70 million followers across social media and better's almost a million social media followers that we've gained in just a few months since launch. We've developed a really strong way to acquire users some of which again, we're not really hardcore sports fans are super into sports betting to begin with. And we've gotten a lot of great feedback from a lot of users that are using the app who have actually never bet on sports before. So when you tie all of these three pillars together we're really uniquely positioned to expand the market and attract maybe more casual sports fans that were not otherwise going to be back at sports betting users on other platforms. Yeah, so in terms of the Massachusetts focus initiatives as you all know better is a Miami based business today with just one office located in Miami, Florida but we have much broader ambitions to become a national company with a localized presence across the country. If we are fortunate enough to be granted a license in Massachusetts this will certainly be a key market force and we plan on hiring for in-person marketing media production, products and business operations in the Commonwealth. Massachusetts is an extremely important market for us for a couple of reasons. The first being a little more obvious and just how big and important a sports market Massachusetts is. Obviously a lot of the most iconic sports brands across all of sports reside in Massachusetts and this really lends itself well to our media and content side of the business there's a lot of opportunity to have an in-person presence there and something that would really play to our strengths. Secondly is that if we were fortunate enough to be granted a license in Massachusetts this would be one of our first two states that were launched in and so this is a long-term relationship that we want to develop and it's really important market for us and as a result, Massachusetts is a strong candidate for a satellite office down the road and we're really, really excited about seeing a strong local presence in Massachusetts and I'll pass it off to Liz and Mike to cover the rest of our local initiative. Yeah, would also love to bring a boxing bullies gym to somewhere in Massachusetts. I know Boston's a big fight capital but boxing bullies is my foundation where we're focused on instilling leadership, courage and just hard work through the youth through the sport of boxing while fighting back against bullying. We've opened up five gyms in the past 18 months given over 500 pairs of gloves to kids held workouts and so it's a really good initiative for the community and boxing is growing it's like the third fastest growing sport now so it would be awesome to get involved somehow with boxing bullies in the local Boston area or really wherever we would like to work with you guys to figure out where would be best within Massachusetts. Yes and hi, Elizabeth Lodge again just to speak specifically to what I think the opportunity is from the media side as well as going live product launches that within our physical footprint if we are to engage locally on the ground as we did in Ohio we look to take over certain restaurants, bars, activations and within that physical footprint of course we want to ensure that we are creating aspirations around the functionality and use of betting for anyone underage so all of those bars and restaurants and locations similar to Ohio would all be 21 plus and furthermore we're set fast against kind of creating an environment within local activations that supports and encourages small businesses so looking to create and while Adrian said we don't have an office or a physical location in Massachusetts quite yet but I think as a step one into the investment we've been very mindful of hires and expenditures until we grow but a part of that grows we'll be having action, video and different media activations that require localized staff upwards of four to 20 people per production shoe and that's not inclusive of talent drivers ambassadors and others that we hope to engage locally within Massachusetts in the Commonwealth and Osho. Yep and just to touch again on community involvement we did cover the boxing bullies initiative which we'd like to bring to Massachusetts but we'd also like to work with other charities and non-profit organizations particularly those focused on workforce development for communities that suffer from high unemployment, under employment within the Commonwealth. We examples of organizations that better intense their support partnerships with our YMCA's Boys and Girls Club and a particular nonprofit called the Action Area Institute that focus on the Haitian-American community which is both prevalent here in the Miami area and also in the Boston area so that was of interest to us. We're also looking to partner with local colleges and universities to provide professional development career guidance, coaching, internships and shadowing opportunities. We've already had discussions with Harvard Law School and the UMass Eisenberg School of Management on what these partnerships might look like. What's up guys, Mike Dinevy head of media again just building off of what Liz was just saying in terms of how we're connecting with the audience on the ground in Massachusetts you know our whole goal behind creating this organic first content strategy is we want to form deeper connections with our users other than just pass by commercials or traditional advertising. And that same strategy carries over to what we want to do on the ground as we connect with the audience and the people of Massachusetts. So you know going to the games sending a list of talent to a Red Sox game or going to the tailgates having watched partners at bars and really being as inclusive as possible with the entire state and then extending that to content and also partnering with a lot of the local businesses as Liz has already been working on in Ohio and we've seen some great success in math case study but obviously we've done that in Massachusetts as well. On the lottery side, you know we're very committed to cross marketing the lottery can help increase ticket sales here. We see the Massachusetts lottery as something that we can really help amplify through that content strategy that I was just talking about, you know getting ageless talent to engage with the lottery and creating that content around it and showing the participation the fun you can have in doing it obviously all responsibly. So that would be kind of step one. And I think step two is really interesting where we can use this creative collaboration that we have internally at Better to partner and collaborate to create cross-promotional opportunities. One example of this is something we created at Better was a free-to-play game called Better Ticket where you have to guess if you will how many yards will a quarterback have a running back have will a wide receiver have and kind of get this long number much like a lottery ticket and there was a prize and a soft rate success and beginning people to use that download the app and engage with that and I do think that can be one example but I think there's tons of really collaborative and creative ideas that we can help amplify the lottery and obviously drive up awareness and sales to it. So turning to diversity, equity and inclusion Better is a champion of diversity, equity, inclusion efforts across its investor group, leadership team and broader organization. We successfully obtained racial ethnic and gender minorities within our investor group which is seen in our application. Two of our board members are racial minorities and across our 14 person leadership team we have six individuals that identify with minorities including our head of engineering, head of finance, head of legal business bears, head of the product customer, brand strategy and partnerships lead and business operations lead. In terms of statistics across our entire organization more than 55% of our full-time employees are racial ethnic or gender minorities. Breaking that down a little further, 41% identify as racial ethnic minorities and 19% identify as gender minorities. Better will continue to find talent across underrepresented groups in sports betting and the sports media industries. We also look forward to the findings of the Massachusetts Gaining Commission on Minority Disprecipations in Sports Waging Industry in Massachusetts which will help guide our efforts and grow the inclusion participation of women, minorities and veteran businesses in this nation industry. We're eager to work with these underserved communities to provide vocational training, professional development, internships, real-life work experience and financial support. Examples of organizations with whom better envisioned partnership opportunities with surrounding race, equity and inclusion within the Massachusetts agonomic and workforce landscape include the Massachusetts Lottery we've just heard about. We recognize the lotteries and essential source of local aid for communities in Massachusetts so we're very eager to work on cross-promotional campaigns and marketing collaborations so not only not take away revenue from the lottery but actually enhance and increase its effect on local communities. Additionally, we're interested in working with the Urban League of Eastern Massachusetts, the Black Economic Council of Massachusetts and the NAACP Boston branch. We'd love to be part of these organizations to better understand how better and the sports waging industry as a whole can contribute to the workforce development of minority communities in Massachusetts. Additionally, we'd like to work with the women and Enterprise of Science and Technology to ensure that women are included all levels of the workforce as the sports wagering industry takes shape in Massachusetts. We'd also like to join and participate in the Massachusetts Nonprofit Network, the Greater Boston Chamber of Commerce and the Massachusetts High Technology Council as part of our larger efforts to inform the development of our own workforce policies and programs in the areas of diversity, equity and inclusion. A non-going priority for us has been creating an internal supplier diversity policy handbook that includes relevant DEI education that you're on outlines our DEI-focused goals. The initial high-level principles that we envision serving as guideposts for our supplier DEI efforts are as follows. Clearly identifying the categories that count towards our diverse supplier spend, which we're taking from the SBA. So small businesses, women-owned business enterprises, minority-owned business enterprises, veteran-owned business enterprises, service-disabled business enterprises, SBA-8 business enterprises, hub-zone business enterprises and LGBT business enterprises. We are committed to having 30% of our supplier and vendor spend come from diverse suppliers by 2024 in accordance with the aforementioned categories. We also want to ensure that better employees, especially those in decision-making positions with respect to vendors, understand the importance of investing in supplier diversity. Finally, we want to elevate our relationships with our vendors, particularly ones we view as pioneers in the DEI space for more than this transactional relationships. Better has created a DEI survey for our vendors to ensure that our organization is accurately monitoring our supplier ecosystem and tracking for those spend commitments. Initial survey insights show nearly one million of spend with vendors that identifies each of Hispanic American, African American and Asian Pacific American, as well as more than 100,000 more spend with vendors that identify as each of Alaska Native and Native American. Hey guys, Mike again. In terms of advertising, emotional plans obviously want to be realized. This audience we've already built and will continue to grow on digital. You can see that social all our growth over time and kind of the unprecedented rise we've had capturing audience on digital and obviously this again in short form video strategy built around fabulous talent and other chronic romantic creators is something we'll continue to lean on, especially in Massachusetts. So at the end of the day, you know, I mentioned this, but really building this brand awareness through this organic campaign. Well, at the end of the day, we think we'll build brand affinity as well that will really lead to easers and thin growth on the product side. What does that mean for Massive 2.6? You know, we've stated $3 million estimated emotional and advertising plan in year one. How would we get there? Obviously through these organic content initiatives which would, you know, be Jake going into Boston, watching the other Avis talent, interviewing Boston legends, going to the bars, doing live shows, really investing in this content production and the people around it. I think Elizabeth mentioned earlier, but investing into these content, these local content creators, production and staffers as we build out that media hub within Massachusetts. Obviously to custom bonuses and campaigns, working ballots and the product team and our growth teams to think of, you know, different ways in which you can capture their audience and fit them in through these bonuses and then lastly working with Elizabeth on partnerships with local sports teams or businesses, as she mentioned earlier as well. Let me go to the next slide. Through all of this, as we mentioned constantly, we'll all be done through, you know, responsible gambling, being top of mind and first and foremost in everything that we do in content creation, production, advertising, and promotional planning. Ashwin Krishnan, again, we wanted to conclude our presentation by referring back to our successful efforts to get licensed by the Ohio Casino Control Commission and receive approval to launch their Universal Start date January 1st, 2023. We've really enjoyed the open and transparent relationship we've had with the OCC staff and have appreciated their questions and feedback every step of the way from our initial application, navigating the licensing process, discussing our ideas for responsible gaming-related initiatives, pre-doing consumer communications and marketing materials with them, and ultimately receiving the license and their approval. We hope to have a similar relationship with the MGC as we have found such collaboration and close communications be extremely useful for both operators and regulators alike. I'll just note that in addition to better receiving an entity-level license from the OCC, key individuals from better, including Joey Levy, Jake Paul, Alex Ursa, Mike Dinevy, Adrian Figueroa, and myself were also individually licensed by the OCCC. And through their previous employers, Joey and Alex were licensed in several other jurisdictions. As we stated in our application, neither better nor any of its key persons have ever had any gaming-related license denied, suspended, revoked, or non-renewed, or have ever been found unsuitable in any jurisdiction. I'll turn it over to Joey now to conclude our presentation. Sorry, it was on mute. Appreciate it, Ashwin. In addition to getting licensed in Ohio, as you can see here, we have already been praised for our responsible gaming efforts and look forward to the potential honor and privilege of receiving a gaming license in Massachusetts where we would plan on continuing our leadership position in responsible gaming and welcome any dialogue with you all over the course of potentially receiving this license and going live as we're eager to continue this leadership position on the responsible gaming front, as noted earlier, seeing this as a critical initiative for us to preserve the long-term viability of the industry and ultimately enable consumers to engage with sports wagering in the way that it should be intended to, which is to enhance the consumption of sports. So with that, we'll conclude the presentation and really appreciate you all providing us the opportunity to tell you more about our business and appreciate it. Thank you. So we'll go to the demo next. We need just a couple of minutes to set up because you want to make sure everything looks fine. Yeah, just so everybody here, we're turning to our product demo and just getting a couple of minutes to set up. That's fine. Take, I was looking forward to it. I will join the meeting from my phone and then we'll do a screen share of his phone. So I need to... Now, can you all see the screen? You can. Perfect. So we will do... We will go through all the journey. We're going to start with the sign up. We will use for the sign up identification process initially like song and the information and in executive session, we will add more than happy to also show you success and flow because we will need to use a real personal information to be able to pass the KYC flow. So we're going to not pass KYC in the public sector if that's okay because we will need to use someone's SSS. So I'm going to use actually our test build which we have shared with GLI for testing purposes. And Mike, I'm going to use your phone number if it's okay when we're going to sign up. So we're going to sign up. Email, let's call it Alex. First, you can see test. Better go. As you can see, we're giving patients information about how they can set up a strong password. So we need to have one letter, one number, one special character and at least eight minimum characters. After this, I need to enter my phone number. Mike, it's 408-315-9895. This will be a check. Hopefully you didn't use your phone number but we need to be unique. So you cannot create two accounts with the same number. You should receive a code right now, usually with auto-populate 7474-9917. As you can see, users can also have face ID on if they want to re-identificate when that's such an experience. We're going to press next. And also you can see we have two-factor authentication on by default. So that means when a user signs up, we will enforce that. They have the ability to disable but we're open if the commission sees like we're open to enforce this and not allow customers to disable it again. For now, we allow customers the option to disable. At this point, the account has been created but my identity hasn't been verified. The next step would be to verify my identity. So I'm going to start the identity process. And we're going to start with the last four digits of this. And again, this will not be a successful path because we cannot use your information while streaming. Use this. I'm going to use my real name. As you can see, if I try to use an age that's below 21, I'm not able to pass this specific test. It's giving me information that, you know, I need to be on above 21. And if I would be under 21 and I would try to use the birthday that's above 21, I will be failed because we are enforcing strict identification with exact match for year of birth, month of birth and date. So we're going to use the date in the future, in the past, sorry. Then the next step would be to have my an address. Let's say two. Two. Three. My name is Lory Da. 51, 27. Also, we are doing a cross reference between state and city. So if someone would use like a city that's not associated to that state or to that city, we will fail them as an invalid information. Next step, basically, I can review the information. I entered in if I need to make any edits. I'm able to do any edits. And I have the acknowledgement screen if I need to read and acknowledge. And then at this point, once I press continue, the age verification, sorry, the identity and age verification is happening. It's instant, instant. I failed because I used wrong information and I could try again, but now I would enter the full source of security, not just the last four, I could review or edit any information that I previously entered. I'm happy. I'm happy. And I will need to acknowledge again, and I could pass again. We're going to do the path in executive session if you would like, so you can see also how you can set up a deposit limit and a way to limit one's path verification. Now, I just pause for one minute because I think I'm hearing that you might do part of your demonstration portion of it in executive session. I just want to get clearance from our council and he understands that everyone has an understanding of expectation. And just to clarify your questions because we're going to use an actual social security number. So for privacy reasons, we'd like to do that portion in the executive session. But that's the only portion we would review basically. Everything that we would continue to do right now, we haven't verified the conduct so they need to go through all the flows. So it's just a demonstration of security numbers. Is that what I heard? I'm sorry. Yeah, the social security number of an actual social security number. Correct. We can decide if that's an important element. I'm so sorry, an element of the demonstration. I just wanted to make sure that that was the only piece. So we can continue the demonstration. I just wanted to make sure we were in mind. Yeah, that's the only piece again because we will use actual personal information and we will want that stream. I'm so sorry that you took down the demonstration. My apologies. No, I will log out now and I will use an account that's very refined in advance. So we could, let's say, pretend that the previous account has acidification and this would be shared experience once they pass that. Thank you. Madam Chair. Yes. I have a question about the piece of the demonstration we just saw. Yes. Mr. Ursa, am I correct in understanding that an individual 21 and under can create an account for the verification, the KYC verification is applied? So once they will fail, basically they will be blocked if they try to create for two reasons. Once they cannot select an age under 21, so they don't have that option to select an age under 21 and if they lie about their age, we are doing age verification. So that means when, let's say, I am 20 years old and 11 months and five days and I use, I put like 22 as my age. So I use the same month and they will change the year. When I change the month, I would fail because the date of birth needs to match exactly the public record. So there's no way for a user under 21 to be able to verify deposit or wager. Yes, but you're not getting the age prompt until after you've created an account. And just before the KYC check is... Yes, so. Correct. And that's in line with, I would say, what we have been seeing in the industry. We're more than happy to make the flow continuously if that's something the commission is looking for. Definitely, we don't see a downside on that. What would be the utility of a person 21 years of age or under to hold a better account? There's no utility in that. All right. And I understand you just said you'd be willing to adjust those practices. Should a license be granted from Massachusetts? Thank you. Yeah. Yeah. Okay. I didn't realize I wasn't sharing my screen anymore. So I would go back and I will use an account that has been verified. I need to look enough to create an account. And I was saying 21 and under but 21 is the legal age to gamble. So under 21, just making that correction. But I think it was understood. Yes. Yes. Thank you. Okay. So at this point, I have to factor authentication on. I would need to enter the call. So that means I need to have my phone with me when I use my platform. And now basically, I am in the passport. What we're going to go, I have a list of clothes that we're going to go through together. We're going to start with a deposit. I can make a deposit with a debit card. I have a few debit cards that are already saved. As you can see, a lot of debt for testing purposes. And by the time we will launch in Massachusetts, we expect to have also online banking and PayPal ready for for users. So we will have three methods that will will be available. Then the next flow would be I could go now that I made a deposit and see my transaction history. So I can go and see all the time, financial access. So deposits, withdrawals, adjustments, or bonus awards that I can see in my transaction history with information about the day, the hour, the amount, the transaction ID, and the type of transaction. Then what we could do is we could scroll through our three leads that we have right now. So first one is NFL. On top of the screen, you have the live visualizer. So this is like, these are the games that we are now. These are in place that are in our test environment. So we can demonstrate the live betting. So on top of the screen, we have real time data visualization of the game, basically all the events of the game. We could also hide it if we want. Or if we can also open into a text mode where someone can follow the game just on a pay-by-pay basis as you would see on ESPN for example. The next that we have two types of markets, team players and for NFL, we also have player props. In terms of team available markets, you could bet on the drive result. What would the titans do with this drive, which is the second drive of the game? Score a touchdown, a bound turnover or a field goal. I could say this is going to be a touchdown and I'm going to bet $5 on this. As you can see, there's no bad delays, there's no spinning wheel. We, if the market is available, that we allow the customer to bet that amount. Then I could go to the next market if I want to have a different bet and say, will the titan score this drive, score no score? And again, I could say score $5. As Joey showed and presented earlier, our markets are question based. So a sports fan can bet without needing to go and read about what a money line is or what a point spread is. Other examples that we could have is what player would score a touchdown this drive. I could choose the player here. And then I can go and see my bet. So my bet basically shows me my active bets, bets that I just placed that are not settled and I can see the information about the bet, the market, the team, the wager, the multiplier, the potential payout, the event and the score right now. And I can expand also and get more information about the bets like the unique bet ID and then unique bet identifier and also the day and hour when the bet was placed. If I go to the set of bets, which are bets that I placed, let's say yesterday and I already settled, I could go and see the same information, but I could see the result. Like I had a bet that the Titans will I said that there would be a punt that's right, but actually it was a turnover. So my bet was a loss. And then I have I had another bet which was a winning one when I said that Cincinnati will not score a touchdown and I was right. So I can see that the bet was a winning one shows the payout shows the final score and also the same information of the gaming for bet ID, market ID when the bet was placed and when the bet was settled. In case the customer has any any questions we are able to identify those bets based on those identifiers. So this is the like the NFL experience. Before I go to MBA, do we have any questions about this one? Thank you. Have a question, chair. Thank you. Under what circumstances does the multiplier change? So as Joey said, our markets, most of the markets are automated by trading algorithms as they would be with any other market on any other sportsbook. So if something changes, for example, you have a drive result, you know, touchdown pounds turnover field goal. This is really dependent on what's happening in the game. So for example, you have these these odds, but if the titans will advance and we'd be closer to scoring a touchdown, that means that the probability of having a touchdown is is higher. So those odds will change. And if the odds are changing while you try to place a bet, we notify you that there's a change and you need to accept before you can bet that the odds have changed. Thank you. Okay. I will go next to MBA. So MBA again has two types of markets, team markets and player markets. Team markets is we have possession results or like you that you that just what would be the result would be a two pointer, three pointer, three throws turnover or a missed field goal. And then for players, player props, we have just one type of field goal point with the player maker, two pointer or a three pointer. Very important for our college operating, which is right now just college football and we aim to bring college basketball in type of much madness. We have just team drive and play. We do not offer college player props. So you cannot bet on a college game on how many points, sorry, how many yards of pass would be or how many yards the player will carry. So it's just only team specific best. Going further, what I want to show you is our account screen. You could see your balance, your bonus deposit withdrawal. You have access to the house rules if you want to access them. We have access to the responsible gaming. We have access to the features roadmap. We give customers the ability to see what features we're bringing in the future. So we're always proactive about what we see. Then you can see now the reality check because I've been using the app for a few minutes, tells me I've been using it for 50 minutes and I've waited $20 doing this time. I can also access the terms and conditions of the app right away. And also I can delete my account, see my personal information on or turn off or turn on to back out on the situation. The most important features that I think we should demo here is the responsible gambling section. So we have a section dedicated for responsible gambling where we show the tools that the customers are able to set and also additional resources. These resources today are Ohio specific mostly, but we will incorporate Massachusetts ones if we get a privilege to get the license and operate in Massachusetts. Again, we are open to provide more information if MTC has specific requirements about who like if they want to show specific message, video and explanation. In terms of the tools, I think you already seen all these tools during the presentation, but we offer deposit limits where you could set up a weekly or a deposit limit. And again, the same rules apply if I decrease the limit, it will apply right away. If I increase it, it will need to go through a cool off period before I can confirm the changes. Wager limits, again, how much I can bet during the day, a week, for a month, I wouldn't be half. Let's put this 8,000. This has applied right away because I decreased it and I made it more strict. Mr. Ursa, would you mind going back to deposit limits, please? Yes. I applaud better on the innovation of the deposits for the 21 to 25-year-old cohort. Can you show that? I'm wondering, I understand it's a default. Can that be overridden by the player? Right now, we do not allow that, but we actually, we have scheduled the work to allow players to, you know, if they want to remove it, they move it. But right now, that's an enforced limit that we are looking to allow customers to change it. But again, we are open here for accommodations. Like if MTC believes that we should not allow until the age of 25 is passed for the customer to remove that limit, we could look into that. And so in Ohio, if I were a 21-year-old playing, if you're 20, you will not be able to play. I hope that was the test that I passed it. But if you're like 22, you create an account, you have a deposit limit enforced, then you cannot edit. But that would be, for all jurisdictions, all products, not just Ohio. But if the commission sees that they, we shouldn't do this, like we would definitely, we will need to do a bit of work on our side to cater for like, let's say, not impose those limits in Massachusetts, but we, we would do that if that preference. But right now, we believe that, you know, from an archive perspective, we want to introduce that across all products and all jurisdictions. Thank you so much. Yeah, I think my screen, I need to reshare it. Sorry again. Oh, really good questions. Then I can, as I said, I can have a max bet with single wages. So basically, if I set this limit, let's, if I put it to 65, I'm not going to be able to bet on, on more than 65 in any one bet. Next one, cool off and self exclusion. This is a cool off period between three days and 365, where you can basically be unavailable to use the app during this time. And then self exclusion, as I said, could be one year, three years, five years of lifetime. And if again, what we've seen in other jurisdictions, sometimes the, that might be custom period that the specific regulator is looking for and we would be more than happy to do it together for that. Also, reality check. You can see it, it's on by default for all customers. Also for full transparency, the time on site, time on the app per day, it's, it's currently in develop, development. And we believe we will have it in time for the GLI certification for Massachusetts if we have the honor to get the license. So that's something we currently do not offer, but we, we will have it in, in the upcoming weeks. That's something we are working right now from a development perspective. Okay. So these are the RG items. And then yeah, that's about it in terms of like the product and the station. As you can see, I will go back to the, to the games. Like we, we really believe that having this kind of an experience where we ask the player a question about the specific event they want to bet on and give them like clear answers with clear multipliers allows anyone who's a sports fan to, to be able to bet without their learning curves. Currently research shows that eight in 10 sports betting customers do not understand what American holds mean. How much you will win if you place a bet at plus 200 and, or what the money line or the spread needs. So that, that continues to be a firmly part of our presentation. Oh, was there a question? Yeah, this is Commissioner Hill. Can you place a bet for us so I can just see what how the potential payout shows up on your interface here? So let's place $10 on author, author. So the potential payout, you can see deals have been changing is the multiplier is between the potential payout is $108. We really, we strongly believe that offering this kind of experience will allow customers to learn really fast and have a learning fast learning curve. The feedback we got so far from users is that they don't need to go through an intimidating experience when they place their first bet not knowing how much they will win or what they will bet. And if I, if the next play had happened after this particular play, we can go back, sorry. Yeah. Yeah, sorry. I need to be sure of the screen. One second. So which one would you want me to open it? So if you go to the player. Okay, player, yes. And then I think before you had some choices on who's going to score, I think was. Yeah, I think that's here. Player to score the touchdown this drive. So as we get closer, so one play goes through, we get closer to the you're on the 10 yard line. These going to change or do they remain for the rest of the until they either get a touchdown field goal or kick back off? Is this going to remain? Like is is others going to stay at 14 or as I get closer for a touchdown or to the you know, five or or or 10 yard line? Do those change or does that remain throughout the drive? That's a good question. That's a good question that doesn't have a strict answer because as the markets are driven by machine learning and trading algorithms, they look what happened in the past in similar situations, similar games, similar plays, and they will try to price or offer the odds based on on that. So the odds change depending on on where the game where the ball is, who's on the field who is, you know, usually maybe scoring from that kind of of play. So that those are things that are taking into consideration. And yes, you know, those are changing. There's a lot of factors that's going into the pricing. What we can what we can tell you is that the pricing is highly accurate. We have been while launching launching in Ohio, we have been hitting our margin targets every day. So that gives us pricing confidence on. So just to be clear, can you go back to the player? Yeah, I think I think maybe hopefully clarify. So that the bet was which player was going to score a touchdown. So that's a little difficult to decide. But if the bet was, will they score a touchdown as they get closer? You know, the odds will change because that's kind of a a linear question, so to speak. The issue with the particular bet was there was kind of a variable question. Who's going to score? And there may be if you get closer to the red zone, certain players, we pick the other category. If we get closer to the red zone, certain high volume red zone targets, maybe their odds will go up. You know, that kind of that's what makes that complicated in terms of moving closer to the end zone. They do dynamically update. So literally every play, the odds are changing. Yeah, not just for every play. Potential. Every moment of the play could be changed because the play, you know, things are happening and that's the pricing. Yeah, I understand. That's the follow up. And I think I understood this in your answer to my earlier question, which was somewhat similar to commission sales. So you do use traditional trading services. Yeah, so as we said in our application, simple that is our trading partner and that's being really actively traded by by them using their own proprietary algorithms and others. Thank you. Madam chair, that's I've finished with my questions regarding this area of the presentation. Thank you. And Mr. Ursa, are you have you completed your presentation now all together before you change? Oh, I do want to ask my thought commissioners. We take the time to ask questions during the demonstration. Anything else? Because I think that helps to go back to an earlier page if you'd like. All right. Madam chair, I'm sorry. I keep my I usually use a mouse for all my activity and today I don't have my mouse with me. So it's taking me long. It's taking me long to hit the mute button and unmuting. In regards to this portion, I'm all set. If we could go back to the PowerPoint. I think it was the second page. I think I want to see the organizational chart that they have put up one more time. If that's okay. So that's the beginning. It's at the beginning. So if we can just keep that up for just a second, please. It's not going to make any sense right now, but I have a question later later on. And then it will all make sense. So bear with me just one second. And I'm all set. Thank you very much. All right. Thank you, commissioner. Excellent. Thank you for that. And I'm looking at the time. It's 1133. At this juncture and our agenda, we typically go to our in-house experts. And unless maybe folks might need a 10 minute break. And then hear from the in-house experts. And then we would pursue our section by section analysis of the application with a lunch break afterwards. How's everybody feeling? Commissioners, do you need a break now or should we go right into our in-house experts? I don't need a break now, but I might need a break before we go section by section. So we can go internal with the presentations and then I might need a break. Okay. So why don't we do the internal, why don't we do our in-house experts now and then we'll evaluate the rest of the rest of the day and make sure everyone's aligned as to our schedule. So thank you and thank you for the outstanding presentation. All right. So at this point we have some in-house experts who help us on technology on the suitability issue and then financial and economic impact. So thank you. And I see Joe this morning and gay. Good morning. So I'm going to give your shout out for those who aren't familiar with GLI. GLI is the first to write and set gaming technical standards which are now considered to be the industry benchmark worldwide. GLI has continued to respond to the industry by innovating new standards and testing, allowing regulators to feel confident that they're providing a state responsible method of revenue generation for their stakeholders and the preservation of integrity. So I turn to Joe and Gabe and I'll let you introduce yourselves. Thanks. Hi my name is Joseph Bonaveth. I'm director of client solutions at GLI. Today I'm actually going to hand off the presentation to Gabe Benedict, client solution executive at GLI and the representative from Massachusetts. Gabe. Thanks Joe and thanks madam chair for having us and members of the commission. As judges alluded, my name is Gabe Benedict and I am your client solutions representative for the common wealth. And I'll be here to give an overview of the submittal certification and verification process regarding mobile applications and other digital platforms approved by the commission. The submittal preparation includes the following. If it is a platform we are familiar with a modification list from the last submission to one or more U.S. jurisdictions will be requested and reviewed to set the project plan for Massachusetts considering any changes to the platform in all specific Massachusetts rules and regulations. If the product is new to the lab we will review the technology architect documentation which is a complete comprehensive and technically accurate description and explanation of the sports wagering systems. This includes a description of all hardware devices and virtual servers, a description of all server and client software modules including the software versions. The layout of all the network communications between the various software and hardware modules and an explanation of all third party integrated systems. Post the technical documentation review the critical files regarding compliance will be identified and documented. Then a complete project plan is put in place taking into account the unique architect and design of the platform and the specific Massachusetts gaming commission rules and regulations. The lab will run a supervised compilation of those source files, the signature of those files and the complication steps and the signatures of the compiled code. Once complete the source code can be submitted for testing in a locked down environment. GLI will review the player account management platform known as PAM for registration, age, identification verification, account controls, payments, reporting, responsible gaming controls, required disclosures, and geolocation. Now geolocation testing commences in two parts, a field test to verify borders through sampling along the entire border while completing edge case technical tests. The field test would also cover any other restricted areas defined by the Massachusetts gaming commission. A submersive work around detection will commence in the lab including, but not limited to VPN and proxies usage, GPS scoofing, code manipulation and man in the middle attacks. GLI will verify the sports book in total, if not tested previously for the retail deployment or review the integration of the sports book into the PAM for events, markets, point spreads, bed acceptance, and the corresponding time stamps and logging. Verify the enforcement of bedding limits in all edge cases and verify the pre event and live data feeds, post event bed settling, the corresponding time stamps and all logging and reporting. And then we will review the change management process and procedures. After all the technical checkoffs are met certifications can be issued when GLI verifies the changes made for Massachusetts specific deployments, including source code differential and change testing to the latest reviewed version. And GLI has evaluated that the product has met all the Commonwealth specific requirements. After certifications are issued in the Massachusetts gaming commission accepts them, field verification will be conducted in conjunction with the Massachusetts gaming commission. This procedure will be finalized in the upcoming weeks and during that time the following will commence. Verification at the production server verify critical file signatures. Reviews of internal controls for procedures to operate the book will check technology for configurations such as proper setup of roles and user right assignments and potentially interview key personnel to ensure they know and will follow procedures from the internal controls. And then at this point they will have met the technical requirements for operations of a sports book in the Commonwealth. That's all I got. Questions for Gabe. Gabe, can I ask a question? I understand that some bet has been licensed in several states as a platform. Is GLI familiar with simple bet as the betting platform? Yes, we are. Better and simple bet have been through GLI 33. I understood better. And simple bet is it's underlying platform. And then did you do all I think I've read maybe that you did all those certifications except for that's correct. Okay, yep. We're very familiar with the product in the platform. Okay, excellent. Thank you. Anything else for Joe and Gabe? Good to see you. Thank you. As well. Okay. Now we turn to our own IED Investigations and Enforcement Bureau. And today it looks like we have Councilor Cramer. Good morning. Good morning, Chair. Good morning, Chair and commissioners. The IED submitted a report regarding the preliminary suitability of better holdings, which is doing businesses better. This applicant is seeking an untethered category three license. The IED performs this review for preliminary suitability in accordance with the standards and criteria set forth in 205 CMR 215.01 subsection two. As a precursor to this review, the licensing division in conjunction with the IED formed a scoping review of the applicant under section 5B of 23N. And we identified one entity and two individuals that we designated as qualifiers in connection with better's application. Those qualifiers are listed on pages one and two of our report. The licensing division has performed a review of the existing submissions for deficiencies. And at this point there are no substantive deficiencies. There has been no ongoing communication over pieces between the applicant and licensing. As mentioned, the IED's review was performed in accordance with the reg. The governing regulation is set forth on page three of the report. I again note that this review was for a preliminary suitability. We did not perform a full suitability investigation. Our team was comprised of contract investigators, including former members of the state police gaming enforcement unit, which is attorney Mike Banks and his team, as well as contract investigators from the firm of RSM. Their work was being performed with the collaboration and the oversight of the IED. The review for preliminary suitability is summarized in the report and it includes a summary of better's licensing status as disclosed in its application, a summary of compliance history and other jurisdictions as disclosed in its application, a summary of pending litigation valued at over 100,000 as disclosed in its application, a summary of the open source review of the applicant, and individual qualifiers, but not entity qualifiers. And with respect to the RSM side, that team prepared the report that appears as exhibit one. They reviewed the disclosed financial information of the applicant. They presented financial ratios. They reviewed forecasting submissions submitted by the applicant and its general application. And they summarized the self-reported history of judgments. At this point, I would otherwise rest on the report. We have members of the state police side, the House and RSM, of course, for any questions that the commission may have. Commissioners, questions for Councillor Cramer. Madam Chair, I'm not sure if we want to hold our questions until the suitability side of our section by section or if we actually want to talk about a couple of issues that we may have now. And I'm just as happy to wait. Yeah, Kathleen, are you going to be available? Yes, I plan to be on the meeting so whenever it's convenient for the commission to start with me. If you wouldn't mind, I would suggest that we do have RSM coming up, and so this would allow us to address those suitability questions in conjunction with section, primarily section G, but also section Chair. Okay. Thank you, Madam Chair. Thank you, Kathleen. But Commissioner O'Brien, I thought I saw you leaning in. I know I did. I have I have a number of questions, but I'll hold them until we go through the section by section and hear from RSM. Okay, excellent. Thank you. I'll set Commissioner Skinner and Commissioner Maynard. All right. Right. So now we'll turn to RSM. I see Connor. Good morning. Hi, good morning, Madam Chair. Let me introduce RSM. RSM US LLP is one of the leading providers of audit tax and consulting services in the United States. RSM has been working with the Gaming Commission to provide insights and analyses to help us. I'd like to at this point turn it over to Connor Lothan and you can introduce yourself and I don't know if you have a colleague joining you today or not. Thank you. And I'm applying solo, but I also share my screen. Okay, excellent. Can everyone see that? Not yet. There we go. Okay, great. Excellent. Good morning. I am Connor Lothan, a director at RSM Strategic Finance and Financial Planning and Analysis Practice. I have 12 years of business restructuring, finance, and investment banking experience. 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. As Commissioner Judstine has indicated, the RSM team has been asked to join the meeting and make a presentation related to certain aspects of the applications. Please note, RSM is not presenting on all aspects of the application. Specifically, RSM has been asked to provide insights based on our experience and research into the following specific application sections. The description of better sports wagering operation. They're projected revenue for the state of Massachusetts and the applicant's financial stability and integrity to operate in the state of Massachusetts. We will also provide any general observations that we include may benefit the commission in their review of the applicant. The three areas RSM will speak to today include an overview of the sports betting market in Massachusetts and the US and how RSM utilized certain market data to test financial projections, applicant projected GDR market share and whole percentages. And finally, an analysis of the applicant's current liquidity position. We will reserve sections two and three for executive session. Similar to other presentations, I'll begin by providing some insight into how third party equity analysts are estimating the current market size and whole percentage in the US and Massachusetts. RSM utilized market research to test the reasonableness of each of the category three financial projections. As illustrated on slide four, we've compared the total applicant pool's estimated market share to how the market is estimating the current Massachusetts addressable market in terms of gross gaming revenue. As presented, the current applicant pool is estimating that the Massachusetts market will be approximately 300 million higher in 2027. Please note that no one has a crystal ball in estimating the total opportunity for the Boston addressable online sports betting market. And the combined applicant pool estimation may very well be appropriate. In addition to the market size, RSM also looked into the year-over-year growth trends estimates as provided by Truist and Deutsche Bank market research from the state of Massachusetts in order to again test the reasonableness of each applicant's projections. The chart presented here excludes 2023 through 2024 is this estimate, this is estimated to be beyond 300% in growth. Generally speaking, better's growth rate for 2024 through 2027 is on the high side but directionally in line with third party estimates. Moving on to slide six and seven, we wanted to provide some insight into the total iGaming market share. The current U.S. market is dominated by three major players. Fandall at 33% followed by Ben MGM at 21% and Drapkings at 19% are the current top players in the U.S. OSB market and iGaming market. Finally, RSN utilized information from other states and third party research to develop a benchmark for whole percentage. We have to deduce that a range of 8% to 12% is the likely range in competitive states which as you can see here on the chart that the 8% is likely the median whole percentage for these applicants and that's what they're likely going to achieve. I will now provide a high level overview of our observations regarding the applicant's financial projections. Better is a privately held pre-revenue company at the time of their application submission and do not have any active sports books in any jurisdiction having only received conditional approval of the Ohio Casino Control Commission at the time of its Massachusetts application. The applicant did provide historical financials since they were founded in August 2021 however the scope of the operations to date are extremely limited. Better did provide a comprehensive view of projected operations and forecast financials for the state of Massachusetts. As I spoke to earlier our assembly viewed the applicant's revenue projection information and compared it to the market analyses from Deutsche Bank equity research report and true security equity research. Game industry both of these reports were issued in October of last year. For our detailed revenue projection commentary and executive session is warranted as RSM's plan discussion contains non-public information in regard to better's estimated market share. For this public hearing offer about a high level better's financial projections will hold specific non-public information for executive session. The applicant's forecast methodology with estimated began with estimated a total number of paid users on its path followed by estimating the average handle and gross gaming revenue for each of those users to reach a Massachusetts market handle and GGR. Without any operating history it is difficult to form a full opinion on these projections but we can stay publicly and they anticipate capturing material portion of the Massachusetts market. Additionally as better presented earlier better business model is different from other applicants as it will rely on providing what they refer to as micro bets rather than betting on the outcome of the full game. The offering will focus on bets on individual plays at bad at pitches etc relying on the consumer to be actively engaged during the scoring contest. In our experience in-game betting offerings have a higher whole percentage or margin in simple game outcome based bets. Based on this business model the applicant projects achieving a higher whole percentage than we would otherwise expect in Massachusetts but this is reasonable given the context. This isn't to say the applicant's projections are inaccurate but rather maybe you press is previously shared the applicant had no server track record in other states at the time of its application so there's no way to compare its projection against past performance. Additionally there is inherent uncertainty over the ultimate market size of sports way during in Massachusetts. With that this concludes RSM's current presentation. I'll remain on the line answering questions the question may have about this presentation or a written submission. If there are further specific questions on the contents of our written report we are happy to discuss those in executive session. Questions for Connor. Connor you want to bring down your slide. Yeah I'm trying to figure it out. I'll I'll log out of the meeting and log back in. Okay I don't want to lose you. Or I'll stay on just for a second. I have one question but I want to yield to my other fellow commissioners if they have any. Okay here you are. So Connor I understand that this is an adventure so that you didn't have the data of course they launched in Ohio. So it was a post the submission of the application. But they did explain in the application the fact that they launched this free to play program in 48 states. Are you able to extrapolate anything from the success that they there's no dollars attached but there's there's player numbers that are coming out. Were you able to extrapolate from that in any way? We we did not investigate that it's part of our of our analysis as we our focus was was generally on the application submission and just overall kind of market share to kind of step the bar for some of the revenue projections we're seeing. But that's something if you'd like us to take a look at we can most certainly do that. And that's fair it may have been outside the parameters of your of the stroke of your assignment. So if you Mr. maybe you can just we can put that in a parking lot and maybe that can be something we can address in our our section by section analysis. So thank you. Okay. Yes. Connor can you just kind of elaborate a little bit more about the in game betting revenues that you're seeing not only potentially here in Massachusetts but across the United States because this seems to be a theme that's being talked about a lot more certainly in this application but certain and in others as well. So can you just kind of educate us a little bit about this in game versus just doing the straight heading at the beginning of a game. And how you think it's going to affect revenues here in Massachusetts and this application. Sorry. Yes. Mr. What we've observed is that several other platforms are providing that same type of betting where it can be whether it's going to be a touchdown on the next play or whether the battery is going to strike out on the next play. And the odds around those can be very wild in the ranges a touchdown occurring on the next play with the odds would be very hot and hit that. As far as how to view what you know that's particular segment of revenues by applicant you know that that information I don't think is provided publicly by at least the public players like Drapkings. So it's hard to ascertain you know how that level of or that particular type of bet will perform on just you know a single platform. But you know it is something to say that you know all of the major players are providing that type of bet on their platform. So there there must be some type of popularity you know when it comes to betting on that type of game. Thank you Madam Chair. Any other questions for Connor? Okay let's do a check in then. Thank you Connor thank you to RSF. So now it's noon would we like to take a short break and then we turn to our section by section analysis before lunch or do we want to have a quick lunch? And Michelle Brown enough? Thank you. I think it might make sense to take the lunch break now and then see if we can hear as much as possible in the afternoon. Okay. Wait if people don't want to do it but that seems like that's the most sense. That sounds good to me. Okay and some Mr. Levy and team it's noon we're going to turn at 12.30 that would work for us how's that work for your team? Great. That sounds good to us. Okay excellent. And so to the public we will be returning at 12.30. Thank you very much. Thank you. Thank you. Hey Yvonne can you take down the screen and we'll see how we're doing. Great. Thank you. Great. I see we've got most of the applicant. Great. Thank you. Great. Well we'll get started. This is Massachusetts Gaming Commission reconvening and this is meeting number 421 and because we're holding this meeting virtually I need to take full call. Good afternoon Commissioner O'Ballion. Good afternoon I'm here. Good afternoon Commissioner Hill. Hello I'm here. Good afternoon Commissioner Skinner. Good afternoon. Good afternoon Commissioner Maynard. Good afternoon Madam Chair. I am here. Excellent. We'll get started again. Thank you to better for its presentation and demonstration this morning and to our in-house experts. This now leads us to item I guess it's 4C on the agenda and this is where we will begin our overall evaluation of the application that's then submitted by Better Holdings Inc. and they refer to their the company is better and I'm proposing that we walk through the application as we've done with respect to the other applications that have come before us over the last month or so but we would consider whether the applicant's response and proposal meets expectations exceeds expectations or fails to meet expectations. In this context though, since we will have to consider the applications holistically at the conclusion 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 that assessment is subject to modification once we have a chance to move through our valuations of each application and the broader landscape is in greater focus we have built-in flexibility commissioners and I'm reminded to each of you that one or more commissioners may seek supplemental information from the applicant to any component of their application. Part of this process we also want to keep in mind that we may consider composing any conditions that we might like to see in the event that a license is awarded to this applicant. And I'm reminded to all at the end of this process on or about the 18th or 19th that's when we will identify whether there's any variation between the applicant's proposal in this category as it's related to others and we'll be making a hard decision. So with that we'll get started unless there's questions or additions. All right. So let's look at section B of the application commissioners. Do you have questions? General question. It relates to SimpleBet and the ownership interest held by Mr. Paul and Mr. Levy. I understood in reading the application that you were using the better is using the SimpleBet platform but didn't really understand that to include trading services. I'm glad you specified that but it makes my question that much more relevant. How do you intend to handle any conflicts that may arise in the SimpleBet platform? SimpleBet in general that come before you Mr. Levy and Mr. Paul in your capacity as better executives? What assurances can you give that will demonstrate that you are maintaining you intend to maintain the integrity of both entities? Sure. I guess it's important to point out that I am 100% full time on better and only a fiduciary of better. So I am no longer a fiduciary in any capacity for SimpleBet Inc. I am an individual large shareholder of the company but my economic interest is far greater and better. I am a fiduciary only of better and yeah I think given that it's quite clear that we deliberately set this up such that trying to avoid any sort of conflicts of interest while creating a structure that was ultimately value creative to both businesses. And did I and I'm trying to find it I mean I'm working from a paper copy and so I have tabbed my pages but that doesn't seem to be helping me at all. But are there individuals at better who serve on the board of directors for SimpleBet? Or vice versa? Yes there's a couple of mutual board directors. So Greg Alinsky is on the board of both SimpleBet and Better as well as Jeffrey Wu Nikesa Badarian who is a board director of Better is also a board observer of SimpleBet. Ashwin is anything I missed over there? No no I think that's kind of the clarification that we should provide here is that SimpleBet is a significant shareholder in Better and is a key vendor of ours. But in terms of you know for Joey and Jake there's no conflict of interest there. There are board there are directors who are SimpleBet directors who serve as directors in our organization. But you know that that's the limit of the overlap there. But I am focusing on trying to focus on the conflict of interest aspect and just wanting some assurances that you have a structure in place to identify any if they should arise. Yes and so we that's part of our board set up in our charter is that for any transactions where SimpleBet would be involved any better SimpleBet negotiations. So these licenses were put in place well in advance but anything future on those agreements would be negotiated and dealt with from the board members that are independent of SimpleBet. Thank you. Other questions under section B. I'm going to ask Mr. Levy. I thought you might be wanting to respond to I think RSM's comments where there was a question about or those there were comments about in play bets being more popular now and and I noted my language I didn't completely understand so I wanted to clarification on that but I thought it would also allow you to be able to explain how your platform made us be different from the other operators platforms that are in play bets and the statement that I was that I said I should ask them to tell me a little bit more about this is like in play betting has been predominantly limited to enabling users to bet on price fluctuations of match outcome based betting markets during the event and I'm guessing what that means but that might be a problem or not. Thanks. So I'm sorry just to clarify that the question is is how what does that mean in terms of other other platforms really based the price fluctuations because they're relying more on match outcomes and I understand that that's not what you're doing here with your micro betting and then also the follow up would be a good opportunity to have more some more succinctly you can distinguish your platform from what really was stemmed from Commissioner Hill's earlier question about you know in play betting generally. Sure so with respect to the first question generally you know before the proliferation of micro betting which is still very much you know in its infancy in the U.S. market and you know we see better as the first direct-to-consumer company that is really pioneering this and simple that is obviously the technology provider that is focused on it but historically in play betting which in more mature markets like the UK for example you know it's been quoted to take up to you know 70 to 80 percent of total betting handle is still predominantly that match outcome based market like a money line of who will win or lose the game team A versus team B and users are placing a bet on who will win or lose that game at any point during the game as the probability of the outcome fluctuates as things in the game happen that would influence those probabilities and that's generally been the extent of in play betting across the global sports betting marketplace to date but part of the product thesis we had at SimpleBet and obviously it better is that U.S. sports specifically have a composition in cadence that lend themselves very well to not just match outcome based in play betting but to enabling users to bet on the discrete moments that drive U.S. sports consumption if you look at a baseball game for example it's driven by pitches and at bats with plenty of time between each of those occurrences to enable a user to place a bet American football is driven by plays and drives and you know there's typically about 35 or so seconds between each play of a football game and even basketball which is a more fluid game like soccer is still driven by dozens of possessions and a lot of scoring and a lot of superstar players and speculation over what those players will do next for example being able to bet that you know LeBron James is next made basket will be a two point or three pointer free throw is a product that we think consumers would be interested in engaging with and lends itself well to NBA despite it being a fluid sport from a product standpoint we're a big believer in having a very focused approach we view a lot of the legacy sports book platforms as I alluded to during the presentation as offering almost like a supermarket of different sports betting products and they're generally sort of displaying odds and a spreadsheet like format with dozens of tabs and dozens to hundreds of betting markets per page and we think to again we view sports betting as a way to enhance the consumption of sports and specifically in our case live sports and enabling and having a very focused user experience that makes it really simple and intuitive for somebody to engage with a particular product is something that's really important to us versus overwhelming users with again a supermarket of different sports betting products so we're very focused on the micro and in play betting experience because we think that it lends itself very nicely to the cadence and composition of us sports and you know that and from a product standpoint when you when you look at our experience it's pretty it's a pretty simple intuitive UI that that bakes it you know pretty apparent that that's the core product experience and we think methodically over time we can layer in match outcome based markets and the simple intuitive UI that that you currently see on the better app but but we believe in taking a very focused product approach which is why we like to describe as what we're doing initially at least as unbundling micro betting really focused on that experience and then layering in the the other types of betting markets at a later date versus overwhelming users with so many different options that they can't really you know interpret to begin with given what Alex previously noted about you know eight out of 10 sports fans don't intuitively understand that minus 175 means to bet 175 to win 100 for example so so we're just taking a very focused product approach and really trying to be the first operator that that has you know definitively found product market fit in this category before we we spent a bunch of money on on nationwide expansion and customer acquisition thank you other questions commissioners on section D Madam chair so I found the information around broadcast latency very interesting can you describe kind of the challenges for now and kind of how you see overcoming those challenges sure I would say there's a couple of primary challenges one is you know providing users enough contextual match state data within the applicant within the better app to enable them to have all the information that they need without zero without any sort of latency to enable them to place an informed bed and not feel like they're almost front running the the linear television broadcast and if you use the better app you'll see that we have the single screen experience with a visualization of the game for our American football product and we plan on releasing that for for baseball and basketball at some point as well looking at better as as really a single screen experience and that capacity ultimately we think better we'll also thrive as a second screen experience and I'll note that you know you could almost delineate micro markets and in terms of instant micros and core micros and I would say instant micros like pitch by pitch and play by play maybe you know candidly a little bit challenging and this interim period as a second screen experience with the current paradigm of broadcast latency but betting on an upcoming drive or an upcoming at that is still far less sensitive to brass broadcast latency as a second screen experience and we view that as a really effective tool for it to enable sports fans to enhance their consumption of sports one thing you know to note that I've spoken publicly about is we ultimately think that you know there may even be an opportunity for for companies like you know better and other sports wagering platforms to to even you know have live sports media rights in some capacity within our experience with within our consumer experience and you know we're pretty far away from from enabling that to to exist but but ultimately controlling the video capture and and having a zero latency experience within the app is something that we ultimately strive to to accommodate but but you know managing expectations that that will take some time given the expenses associated with that thank you were there other questions under section B here's your opinion so I noted that you're I mean we're calling them tethered proprietor base seems to be the phrase that Ohio uses so you are linked to a presence in Ohio for that license is that correct yeah and if you can answer this question is that the same for the other jurisdictions you're pending in or or any of them is it's where you would be untethered as we said yeah so so Maryland would be would be untethered would be very similar to the Massachusetts structure okay I was happy to hear that you have in fact launched because when I looked at this and as submitted I was concerned about coming forward on an app that hadn't actually launched so you spoke on it briefly but can you reiterate to the extent you can publicly how that launches gone since January 1 in Ohio yeah yeah so we we launched we did like a soft launch for a period of time to make sure things are working well especially being you know our first state to go live with a new wagering platform so that what that meant is we didn't took user deposits initially so we allowed users to sign up verify their identity and receive the post to play on the platform that allowed us to go through a testing period to make sure again everything works fine and to tweak any any any things to our systems which to be honest we haven't encountered any major issues I think you know we had some small settlement delays which we actually address on day one and we are actually right now the team doing the launch bigger now says they they are deciding to turn on payments today we are happy with what we have seen so far we're going to start a slow roll out on payments also we're going to start with David card only the post then we do it again because we want to monitor transactions we want to make sure the funds are flowing correctly in funds are flowing correctly out and we're just going to add the next payment methods in the next couple of weeks PayPal and online banking and again we're taking this phased approach to let's say do a self-control soft launch just to make sure everything is fine and consumers have a good experience with us because we are a new sports book and we definitely don't want to go we haven't going aggressive on acquisition just to give us time to address any any potential issues that we would see but so far we we are really happy with what we've seen so you're technically still in your soft launch right now kind of ramping up you're not full on that right so we will be full on before the end of the day today actually that we received all the green lights that we were able to receive money and money out and again we took this just to make sure we are taking the right approach and we're not putting consumers at risk in any way giving that's a new product and any new product usually needs a bit of you know I think I would lie saying that you do a launch first time launch and everything works perfectly yeah and I'm not saying this is a deficiency madam chair but what I would ask is that between obviously now and when they're back in terms of when we're doing adjudications and votes that if there's any material change based on the Volod in Ohio in terms of your ability to advise MGC so that we about it so what we could do Ashwin we could inform MGC and soon as soon as we turn on the policy and with the role which again we expect to be later today no other no issues that account that we have been testing this feature for the last week and again we are comfortable doing it today and again for full transparency we wanted actually to do it yesterday to come today and say hey we have the policy and with the roles but as a production system is to go through we had some confirmations from the bank that's actually processing the payments that they wanted to make sure everything is on time and we received this like so good we'll provide an update under the 19th of the 20th of your date so we'll we'll provide an update prior to that okay thank you other questions under section B I'm going to follow up on give you the opportunity to let us know how the free to play program that you launched the 48 States how that informed what you're doing in Ohio what you're proposing here in Massachusetts and then I guess the second question I would ask is I presume that there was maybe I'm wrong no age limit on that because it was free to play and is there any intention of using any of the data that you accumulated during that free to play period in Massachusetts for instance sure I'll I'll address the the first part of the question and I'll hand it off to Ash and Alex to address the second part of that question with respect to free to play as noted during the presentation despite not really any paid user acquisition spend we have over 120,000 downloads the engagement on that experience has been generally quite quite positive and but but I do want to to note that you know this product experience we we didn't design a bespoke free to play game for free to play purposes and then have a different experience for real money betting we very much view free to play as a way to one register and onboard users nationwide so that we can you know have some sort of customer base in jurisdictions as we get market access and licenses and as those states legalize and to to provide a you know a bit of an interactive tutorial for what what's a pretty new product experience that hasn't really been released in the market yet without American odds displaying betting markets as intuitive multiple choice questions with a focus on micro and in play betting so so you know candidly not really taking sort of any sort of cohort analysis with the free to play experience with any sort of not viewing that as having any sort of like profound business implications we we we've launched that experience for those two purposes predominantly and you know otherwise have been satisfied with with you know how that product is performed Ashwin Alex I'll let you address the second part of that question yeah you know as we said in our presentation all of our products are 21 plus so the so the same requirement applies to the to the free to play product yeah I think again looking at the free to play market for all operators in in the U.S. for free to play usually there's a self-certification you're 21 there's no comprehensive age age checks via third parties and again we are open to discuss that with M.G.C. and if you know we find that that that desire approach we we can enforce the comprehensive identity and age verification also for free to play but what we've done so far is really in line with the industry without naming other operators basically we took the same approach where you know customers can sign up and self-certify their 21 and plus but we're more as just to conclude we're more than happy to enforce comprehensive identity and age verification on the free to play experience thank you thanks quick questions so one question Krishna Hill you often ask it but in terms of customer service I wondered if you do you want to ask that question Krishna Hill I can certainly ask it it's something we're all concerned about if there's an issue for a consumer customer what is your customer service hours of operation is it done through chat is it done through phone number both how do we move forward if there's an issue so we offer customer service 24-7 right now the way it works when you reach out you have two verticals one is a self-service portal where you can read the most important you know items we know we might reach out to us for example how long will take for my withdrawal to be approved or how long why is my identity not verified so how do I reset my password those things that usually a customer can self-serve then if that's not enough they are able to turn on and engage with us basically the experience that is we're offering again predefined categories which the customer can choose do they have an account issue a payment issue like a password gambling question and so on and so we can filter out and provide them first a set of articles and answers right away and if they are not satisfied with those solutions we give them the option to reach out to us right now what we do is we create the tickets as emails and we treat them as live chat we are looking to move into live chat ones who are out of the soft launch period but right now for us it has been more efficient to basically to receive the tickets as emails you don't need to write us an email it's the same experience as a chat but we basically it's a it's a asynchronous communication between us and the customer Misha Hill all set yep all set thank you ma'am chair okay so can I just follow up on that and maybe I just missed it as you were speaking but is there an option in terms of if something goes awry in the account maybe you've lost control of the account to contact someone by a phone immediately right now no but I we are definitely open to I think engage with a solution that again is on the market with with an instant callback yeah I mean because I think the fear is the damage that can be done in the time that it may take to get a response in the other methods of communication you just talk about yeah we totally understand that and that's one of the reasons we are enforcing two factor identification for example so you know we while that customer can disable disable it we believe that that should eliminate about 95 97 percent of contact over situations and then I'm sure everything's in English do you have any plans for any other language besides English in terms of being able to communicate for customer service right now not officially the good news is that some of our customer agent service actually are fluent in in Spanish coincidence just because like be living in in Miami having people employed in Miami that's a large Latino community here so if someone would reach out for example in Spanish we will be able to to serve them at least to address but not other language and we necessarily do not plan to do that officially right now okay thanks so Libby what's the size of the better workforce how many employees are you moving on I'm sorry I'm sorry no this is this is this is me interested in relations to to follow up to one of the questions around customer support okay I thank you so much yeah I can jump in there as from Christian again we currently have 27 full-time employees and how many of those folks are responsible for customer service responses is it four of us six six and thank you thanks commissioners getting my apologies so other questions for section B so I just want to make a note as we continue on reviewing the application there are points in time where the the applicant and in the presentation even looks as though they may be responsive to the series of meetings that we have and I just want to give your team credit because everything the best was in the application and preceded the presentation so in so many ways you anticipated many of the issues that we have been bringing up in our last meetings and I wanted to give you credit for those who haven't read your your application so and that will come up particularly in the in the next section so thank you for being responsive in that way without without even knowing our particular direct questions we've been asking over the last seven weeks so I need to take the find out if we have a consensus on B commissioner Hill I would be comfortable saying that this applicant has met expectations for section B I agree the applicant meets I would agree with that okay if I could just make one comment madam chair before we go to section C I am a little concerned at what I just heard about the customer service piece of this applicant and I would hope that you really take into consideration what we have said today regarding being able to get to a customer service rep a live person a little quicker than I think you're allowing today that's something we're concerned we're concerned about for all applicants and I would hope that you hear loud and clear that that's something that we hope that you will re-engage in in your conversations yeah we heard that feedback well what we can commit to is as we if we get a privilege to launch messages we definitely will add more agents to our team that's not our existing team for full suite of products and as we grow we add we also have a I would say a mentality that's customer focus so if we see something that's a top issue like that's not necessarily solved by throwing more people we need to solve that issue first so that's one and then secondly we will be more than happy to communicate our clients to grow the the customer service team and even give clarity on our plans that in the future thank you for allowing me to make that editorial madam chair I'm ready to move forward and we can build on it if you'd like but I think to just add commissioner Hill's point I know that we think about whether someone sees that their account it's being packed and we want to be able to make sure that a customer can get immediate help on that front but I'm also and I suspect all of my dog commissioners showing me that we worry about the customer who is in stress because of responsible gaming problem gaming issues and so customer service component that live person could be truly truly instrumental in a period of stress and so we have seen many of the applications where there's trained folks on RG matters to be able to assist in that so the customer service component sometimes we know the applicants can get that right but it is complex of peace with respect to mental health so I don't know if we want anything supplemental on that Commissioner Hill I think I'm hearing that they heard us yeah yeah yeah we we heard you and very important for us excellent thank you all right then Commissioner Skinner I did not I thought you were jumping and it was my my apologies that made perfect sense your last question I turned to questions section C and if you would like I'd give you the first question if you if you're ready and if you're not somebody else can go I just I know that you typically ask questions around this section Commissioner I Madam Chair thank you I would like not as much a question as a comment than an observation I've kind of beat the drum on the along with Commissioner Skinner and others on the lottery question and when I was reading your application you know when we were talking about this issue in September you hit exactly kind of what I was wanting to see and in terms of really thinking outside the box and how you can collaborate and so I appreciate it whether it comes to fruition or not I appreciate the fact that you're thinking that way and that it seems like you are really committed to engaging with the with the treasure and the treasurer's office follow up on that commissioners that was one of my I would say the same thing yeah it's one of a few that have actually been specific about concepts as opposed to just a statement of intent and it was fully developed in the application so thank you for that I think the presentation today clarified to me what you had in mind a bit too in terms of the innovation um looked like Commissioner Hill was going to go I talked plenty I'll defer I will always yield to Commissioner O'Brien I think it was Commissioner Skinner who actually was first I who's yielding to who likewise I will always yield to Commissioner O'Brien so now the expectations are there right I I had a couple questions that I realized some of this maybe what we're going to get to in executive session but some of the responses in terms of projected revenue the analysis the assumptions were rather vague some of them refer to eye gaming potentially which we don't have in the Commonwealth I'm sure you saw how long was for sports wagering to be legislated in so I don't know that that's a sort of a viable assumption to put in at this point and in your answer to C2C1 about projected revenue when they we asked for any studies or projections and the basis for it you know the response just that you're assuming a 20% tax rate and so I'm looking for more information on that and I know that some will be coming us from RSM but I Madam Chair I just wanted to flag that that I'm assuming we're going to be getting more detail on that in executive session yes we're more than happy to discuss all the financials and the projections and all the assumptions in executive session as we believe it's appropriate I think RSM noted that they expected that in the end the details to be in executive session I think what they did reveal is the very public correct commissioner Brian so well that I just yeah I'm not seeing anything even that we were able to review in advance and so that's the concern that I have I see and then as far as the rest of C I have some other questions I don't know they they pertain to some of the other offerings in terms of you know the the anticipated or the possibility of another you know brick and mortar location with employees based out of here was all very specific and very you know nice to hear again that's not a lot of specifics that we were getting from particularly mobile only so I did want to lodge you for that and if if in fact you are here that would be good to see come to fruition I think there was a couple other areas I was hoping for I was hoping for a couple other areas I was hoping for more specifics on but in particular I want to ask about I think it was C5A in community engagement of 106107 where you talk about the relationships with some of the schools in the area and if this is something that's not out there publicly and this is better for executive session for some reason let me know but as I scan through particularly the university letter of intent I had been hoping to see something more targeting underprivileged communities for opportunities as opposed to an institution itself so if you can elaborate on how that's going to benefit the community beyond the rather well-undowed educational institution I'd appreciate it Yeah, happy to do that and thank you for the question I think in our effort to show that this was a serious commitment and something that we really wanted to show that we were serious about we wanted to show that we had gone beyond just conversations with people but they actually formulated something and I know the letter itself is big but given the kind of short window we had we reached out to folks that we had relationships with and so I certainly have relationships at Harvard Law School and I was able to kind of get some framework of a commitment down but we fully intend to work with way more than just that we reached out to UMass Eisenberg's Sports Management they had a great program there that we'd like to be part of those are the natural ones that came to us but certainly we understand there's plenty more underserved communities and groups that we want to be involved in the the issue is you know sometimes when we start these conversations we both get very excited about it but then we realize you know it's kind of a it's taken in the egg situation of we need to get our license and know that we're operating there before we kind of really get into further details and specifics of what we'll do and how we'll benefit each other but I think we as you see throughout our application our presentation today we're very much committed to being a Massachusetts being on the ground and working with underserved communities there and partnering with the right you know universities secondary institutions wherever we can they kind of make a difference particularly in those communities that are more vulnerable but this was kind of our first cut at folks that we had relationships with and we're able to at least kind of get something on paper to show that we were serious and not just you know floating names out there okay thank you yeah I will yield the floor to whoever is ready to go Commissioner Skinner there you go so I would typically ask the questions relative to employment opportunities within Massachusetts but I want to echo Commissioner O'Brien's sentiments in noting that the piece of the application that speaks to that is very thorough and I appreciate that noting in particular the letter of intent with the real estate brokerage and looking forward to developments in that area I also want to take the time to thank Mr. Paul for participating in this proceeding today and it does demonstrate in particular in my mind a commitment to Massachusetts thank you you know I'm excited to be here Madam Chair Yes so when we're talking about employees in Massachusetts or proposals for employees I want to be very clear that we're talking more on the better media side than we are the better gaming side I think you said that in your presentation and I just want to make sure that we're clear about what employees you're looking at at this point I think I heard you say that most of those that would be hired here would be would benefit the media side more than the gaming side is that an accurate statement it's yeah it's all yes if I can just jump in I'll turn it over to Elizabeth in a second but yes you know this was an initial cut of trying to identify where opportunities were and the immediate ones that came to us were on the better media side but again it is all one company I know we're looking at the org chart earlier but it was actually it's all one company and Liz can certainly elaborate on some of the better media opportunities we identified pulmonarily Yes I think as Ashlyn said you know we are looking at you know crawl walk around in our hiring phases within the Commonwealth so looking at near term six months immediate hires would be on launch activations production resources at a local level as well as you know from an integrated marketing standpoint which is reflective within the what are the LOIs within our application a company based in new report and we're sure as well as others that we're looking to identify for subject matter experts within the state of Massachusetts Okay I just I just wanted to be clear about that at this point but and I also want to just give some kudos to the group for your application in regards to reaching out to the community that's something that I really is near and dear to my heart and I saw the organizations that you hope to to be part of and we feel as a commission that this is important that you have community involvement and through your application it looks like this is a priority for you folks as well so kudos to that and and hoping that that comes to fruition should you be given a license Sarah Massachusetts Thank you Thank you Yes, thank you Other commissioners? I apologize for circling around in this section but some of the other comments from my colleagues brought some brought some memories to the forefront I don't know if the percentage is out there or not publicly but I will say that you have some philanthropic goals that you want to hit over a five-year period I wanted to to give you an opportunity to talk about that and I did notice that you said this would be local not just you know company-wide and then I wanted to know and we heard a little bit about it Mr. Paul but how you plan on bringing boxing bullies to the Commonwealth I was very interested in that program Mr. Paul Hey, do you want to start first? Go ahead I think you get off Yeah, no Yeah, so I mean boxing bullies we have funds and a staff of three full-time people and what we do is we identify a gym typically like in a lower income area or gym where there actually is a lot of boxing activity or boxing interests and what we do is we get in touch with the gym owner and we offer them a complete renovation of their gym and sometimes even an expansion and higher general contractors to go in redo everything brand new equipment supply the gloves because a lot of times and if you have been to many boxing gyms it's very very outdated boxing had like a law period for about 10 years 15 years or so after sort of like the Mike Tyson era and now it's you know it's back up on an upswing but we go and renovate the gyms and basically make it so that anyone within our like outreach program or anyone who wants to come into the gym then it is it is free and there's no fees for anyone coming into that gym moving forward and it's covered by boxing bullies and like a partnership program with them and then typically I'm making my rounds to each one of the gyms to do an in-person event we've already done it in Miami Arizona Cleveland I'm blanking out New York I'm blanking out another big one but yeah I'll go in person and use my social media outreach to let people know where this workout is going to take place and now that this gym is available for usage and then usually there's anywhere from 50 to we've even had up to 200 kids show up and I'll put them through a workout and give them a message about bullying and it's very near and near to my heart because when I was a kid I was a bully and then growing up I was bullied for my social media videos and such and cyberbullied and I see how big of a problem it is with people making fake accounts and fake usernames to talk about you know peers within their school and so I've been on both sides and I usually give a message to the kids and encourage them to take up the sport because boxing gave me the confidence needed to feel with to feel whole within myself and to mature a lot within myself and so just usually share that message and then we also have online help where kids can you know be sponsored for their fights we send kids off to amateur tournaments so if a kid starts to take it very seriously we then give them the funds to continue their amateur career and send them ship them to tournaments flights hotels we pay for all that we have two actually amateur champions right now which is which is really exciting and growing but this has all been in the past 18 months two years and we're rapidly expanding and have really big plans and are ready to go so would love to you know figure out and identify a gym somewhere in Massachusetts we have we have a bandwidth ready and and just continue to expand so it can move pretty quickly thank you yeah not to clarify if you don't mind a couple of things I think in any of our efforts and reinvestment into the community you know if there there's an investment in which we want to make into communities and projects and in various things that we included within our proposal and those aren't necessarily directly tied to the better brand those would not be a marketing effort in any way it's more just a reinvestment into Massachusetts which personally I hold very dear have a lot of family in and around the Commonwealth and I think to Jake's point on Boxing Bully we certainly want to look into areas in which we want to build a gym and again that would be under a completely separate entity and brand especially as it is helping youth community which is not within better demo to any degree do you want to touch on the last part yeah or not I can quickly touch on you know quantifying that helping quantify that as we'll go further into detail maybe an executive session but you know part of our application of course is our commitment to philanthropy at the local level on Massachusetts and that's something now we're certainly looking forward to and you know we made the commitment over the length of the license to donate locally 10% of NGR and that gaming revenue and that's something that that we hold firm on that commitment and are really looking forward to and again we can get into more specifics on on those productions in the executive session thank you thank you they offered um that perhaps an executive session would be appropriate from our detail are you satisfied with their answer I'm satisfied with with your answer today along with the materials thank you all right um other actually if I could follow up on that madam chair before we move on so one of the things I'm conflicted on on this application is you've got tremendous plans and opportunities in the Commonwealth and what you just described as one of them and I appreciate that you're saying you're going to try to draw this line between the charity work and the the betting component of your business and this is something that I'll touch on again later but I may want more information on how you plan to sort of divide those spheres because Mr. Paul is a big part of what is the draw for the betting business and then he's also going to be a big part of those appearances in the charity and so I have a I am struggling with that dual role of a figure that we will again you know Mr. Paul will talk about when we get to suitability but I may need more information on that in terms of and maybe just comes in the general area of suitability but I don't want it to track from the charity work itself and from the mission and from the prospect but I did want to bring that up as a concern that I have to build on that to build on that and help with Madam Chair just to build on on what Commissioner O'Brien is concerned about I'm also concerned about Mr. Paul as an athlete in terms of what the offerings are and the bet that our platform yeah I can answer that right now we do not plan to offer any any combat sports we don't have that on the roadmap so any kind of boxing on MMA at the same time we haven't given other regulators to clarify that you know what would be the offering and it's it's obvious for us it's clear for us that we will not be able to offer any events in which Jake either takes part or is a promoter or supporter of like fighters or cars so we will not offer fights in which for events that Jake takes part or organized Madam Chair since the issue has been brought up and the door has been open I do have a question regarding that and Mr. Paul I appreciate you being here as well I heard one of my fellow commissioners say that earlier this is this has been an issue that I've been concerned about since I've seen the application and it's a great application I'm very worried with the fact that you actually have a partnership I believe and help me with the professional fighters league I believe it is and the MMA is one of the biggest sports for betting and I find it hard to believe that your company would disregard that entire section of betting as it is something that you would make money on I'm hearing that that's something that you're saying will happen I find it hard to believe that that will continue to happen once we start seeing how much money can be made with MMA fighting do you want to touch upon it now or do you want to wait until we get to the suitability please it's Mr. Paul for 20 minutes I think it's very fair I think it's an overlap to commissioners purchase as a very fair portion to answer I would I if I could if I could just ask a clarifier and then turn to Mr. Kirshen and Mr. Levy and then Mr. Paul but Mr. Levy your application suggests right now that the offerings are going to be limited in scope because they are most germane to micro betting you know basketball football baseball and I'm missing another one that's what we have today yes your business model is based on a very much more limited number of events or sporting events than what we've seen with respect to other applicants do you want to clarify about whether or not that's going to expand as your business grows in that model and then I suspect there's a legal answer to how you would be putting up guardrails around any events for Mr. Paul but I don't want to speak for you but Mr. Levy on the first point that'd be really helpful sure yeah so so as noted American football both college and NFL baseball and basketball both college and NBA are the extent of our product offerings today as I've also alluded to we're taking quite a different approach to quite a different approach to product than some of our competitors where we really want to stay focused on our core experience initially and really get to a place where we feel good about our value proposition to consumers and that we have product market fit and then over time we will invest resources into adding other offerings but as Alex noted we have a very focused near-term product roadmap that we anticipate on sticking to in the near to to mid-term but we do plan on expanding to other sports and we're going to be very sort of methodical with how we do that particularly with respect to MMA and UFC and PFL and boxing and some particular IP that Jake who alongside myself is the largest shareholder of this business may directly be involved in because we would not do anything to potentially even provide the sense that integrity with that IP may be compromised in any sort of way Yeah just to piggyback on that since you asked for a legal answer that that's exactly right we didn't intend to say that we're not going to offer MMA altogether any fight that Jake is involved in interested in in any way as a promoter anything that of that nature yes will not be on our platform but anything that he's not interested in in some way but is MMA you know we put on our roadmap so just want to clarify that not the whole category is out just anything that Jake would have a conflict Yes and I think to add to that is like always leading with integrity first and not just seeing dollar signs and and you know get just getting excited because of that I think all of our decisions are based around integrity first but one thing that I'll add to to clarify here is you know we did have a lot of success launching a free-to-play game called the the pulse so the ticket around Jake's last fight and that was free to to enter and there was a prize for consumers and it ultimately proved to be a a great thing for for fans that were engaged with that event and also a strong customer acquisition tool for us so I wanted to point that out as an example of you know us taking advantage of of the relationship with Jake and all the enthusiasm our audience has around combat sports while you know airing on the side of caution and not doing anything with respect to to real money sports wagering that may may you know not be viewed as having the the utmost amount of of integrity Commissioner Hill did you have a follow-up question once you heard those responses? Not at this time Madam Chair Commissioner Skinner you and Commissioner Bryan you I did actually to the to the point of and I'll tell you very candidly that makes me very uncomfortable that you're going to have you know a large shareholder and a potential mobile bettering company actively participating in a market where he on occasion would be one of the product offerings even if it's temporarily blocked in your platform and the question of conflict of interest is you know what is the board and or the standards that are out there for MMA, martial arts, etc that would then be the arbiter of whether or not there was a conflict of interest apart from just his clear participation in an event it could go and extended to other things so I'm curious what the framework is for identifying those conflicts Yeah I mean I as I think we've all alluded to this is far on our road map nowhere near kind of in the near term will be offering MMA or anything that Jake could potentially even be involved in but we would certainly look to work with the commission look to work with any other you know regulatory body that we would need to to make sure all those safeguards are in place we don't have them at the moment because that's not kind of a current issue but we would absolutely make sure everything was done as Jake and Joey alluded to with the utmost standard of integrity and making sure that everybody knew that we're not you know that that's our guiding principle and you know we would absolutely work closely with you to make sure that was paramount So am I reading the answer to the question that there does not exist at present conflict of interest rules or guidelines by the MMA or the players association Yeah I'm sorry so the leagues themselves may have the UFC may have conflict of interest will say they have put forward but that would be you know that's not something that's not something that has entered our ecosystem yet because we're not offering any can you actually relate we're not offering any fighting related in terms of our product offering commissioners I we have our folks from GLI who have come into the picture So actually Madam Chair before we move on I just wanted to I can close out the query with basically saying that I I can appreciate what you're saying but as a regulator who's being asked to give a license the sort of what you will deal with it later idea is not a doesn't give me great comfort in this area and I'll leave it at that for now And Commissioner Bryan I didn't mean that I'm wondering if Joe is going to share something Yeah I just to return to you Commissioner Bryan Right Yeah we're not closing this out yet Can you guys hear me? Yeah okay just I just I think it's my our you know GLI's place here to just kindly note that under 205 CMR 247.03 the petition to sport for sport event a wagering category that would the MGC is actually in control of the events to be wagered on here so if better wanted to actually put this on their product they couldn't do that just by themselves they would have to bring this forward and you guys would have to look at the how the Mr. Paul's event or whatever it is doesn't matter would you know how it's sanctioned and how the event is verified and the integrity behind it so you guys are full power here that part of the wagering catalog is coming up I believe this week first yep and and so just a brief reminder that it's clearly written in the the regulation that you guys are in full control of the of the events to be wagered on so okay Madam chair yes although I understand that we we look at Mr. Paul in this case in other jurisdictions and what goes on in other jurisdictions when it comes to suitability and I have a very big concern when somebody who has partnered with somebody and in this case the PFL and could be somebody who would be involved in a fight even though it's not happening now nor is it being proposed that moving forward it doesn't pass the smell test as we used to like to say and I I know I would use this as an example although I know the PFL and I know UFC are two totally different things but if LeBron James for example was a major partner in a company that did sports betting there's no way the NBA would let him be playing in the NBA under their rules and regulations and I guess I am not as up to date on what the rules and regulations are of each week and in this case PFL or UFC and maybe I need to educate myself a little bit better on that but I can't imagine for a second that this would be allowed or that concerns would not be brought up and then my last question Mr. Paul you received your Ohio license did you get your license before you made your partnership with PFL or were your you already partnered with them when you got your license here we were we were already partnered on paper with the PFL but it wasn't publicly announced so I think the follow-up question would be I don't know Mr. Paul and we don't want to put you on a spot but perhaps council was it did Ohio the right to deal with it perhaps that's most helpful no yeah the answer would be no and I think just like the thoughts here are if there is any conflict of interest it's not like we won't even go near it and if it's something where the PFL has to be excluded then and I think Joey would say the same thing like we that is not in our it's not a concern to us at all yeah but it is but it is to us oh I think Mr. Paul is saying it's not a concern that they would just not be involved understood I think he's hearing me yeah so to reiterate it what Jake said if if if it were determined that prohibiting betting on PFL would be required to you know pass the smell test as you put it Commissioner Hill we would be happy to abide by that and you know to do whatever it took to operate with the utmost integrity and not have any sort of potential appearance that things weren't totally above board here and I want to point out that you know even with the USC there are let's say their partnership with DraftKings there are still fighters around the organization who promote DraftKings through separate deals and then go and fight so I don't know exactly how that works but it is a frequent practice that I see thank you Mr. Pollard Commissioner Skinner I want to circle back to you because you also had an increase and then I might circle back to Joe's point yes so I agree with Commissioner Hill I think this is an area where we could all use a little bit of education because you know I think it happens you know more than we realize just across the across the industry in terms of sponsorships and the like by athletes I also wanted to circle back to what Joe was was raising relative to our discussion this Thursday and I'm happy to hold that until that discussion but we have a set of regulations that we are preparing to review on Thursday and I just I want to be sure and I believe we have the actual offerings right that so I don't know if there's a decision that's going to be made on Thursday but I guess we may not we may not but we deserve the right vote yes and and just to know I see that Kevin's here to come you know another legal perspective so Commissioner Skinner nice yeah so I just want to make sure that we do build in the framework to to hold so I guess my concern would be if we approved an offering whether it's this Thursday or subsequent to Thursday does that mean that it's fair game for all of the licensed operators but that's what I'm struggling with and that's what I hope that we can hammer out on Thursday at least start to and and Mr. O'Lally from GLI thank you for joining and I see Joe is here still to Commissioner Skinner's point you know there there will be a presentation on potential offerings and it might might include boxing it might include MIA so how would we put guardrails off on any athlete you know that has an interest in an operator or some participant in an event from you know this this kind of conflict of interest how much you manage it and I have you seen it it's more Kevin I don't know Kevin is live right now Mr. O'Lally yeah I'm sorry I didn't oh there we go yeah I would just echo what Joe said earlier and this goes to the nature of how different this new category of gaming is from what you are used to and the concepts we've talked about about relating to operational risk control you know before you had slot machines you had software you had very prescriptive regulations you lock it down you tell the casino how the money goes through there here's how we're going to audit you we're always going to do everything the same this you know the marketplace is changing rapidly there there are new consumer preferences and consumer behaviors and these operators are going to react to that with both changes to the interface in which the consumers are engaging and the types of wagers in which the consumers want to place all of that is under your complete oversight and control and will require your prior approval and there's going to be more of that than you are used to with you know with the occasional debt transaction or a change in ownership or the other things that you're used to on the casino side these things are going to be more frequent so I don't think that anything I'm hearing here is surprising to me but I think that the regulatory construct that we have proposed to you and you have been reviewing and and as the regulations come up approving gives you a large ability to control this and to have prior approval and sign off before it goes live can we just just ask for a clarifier on your point so on on Thursday let's say the global list includes MMA and we're going to have this on top of mine there's an ability for us to carve out for particular operators and allow for other operators correct yes that would be correct however I would like to make a note here in real clarification while MMA is a very big and wide sport there is different governing bodies within that actual sport and Mr. Paul can correct me I'm wrong but I don't think he's fighting for the WBC heavyweight championship next week he's there's different levels in sanctions that that that govern those bodies so there's MMA but then there's USC that governs that piece so that those specific things are will be brought up you know like there's NBA I mean I think there's close to 300 plus professional basketball leagues or even more in the world but you know there's the big ones that will be brought forward on Thursday as to prove for the catalog so that so just so we're clear I understand all of that and the concern that I have is more akin to what Commissioner Hill raised which is the appearance reputation the integrity the broader understanding and the fact that we've had to sit there and dissect is part of the part of the conundrum of this we can go into this and suitability too but the investment of certain NFL players in the company as well I've got a lot there's a lot of layers of this concern for me to go beyond just a particular event and a catalog okay other questions then under section C we didn't um Commissioner Maynard did I miss it did you mention the response with respect to spend that's usually in section D correct oh my mistake all right thank you okay I had no good enough everybody all set then with respect to section C I know we just had a discussion I'm not sure if it's exactly involved with section C if it's more a section G issue so I'll take the temperature on this section C did the applicant meet expectations Commissioner Maynard I think on C they met expectations thank you Commissioner no I agree they have met expectations for section C thank you Commissioner Skinner Madam Chair I'm very pleased with section C so I think that the section exceeds expectations did you say it exceeds thank you Commissioner Maynard I believe section C meets expectations okay so and I agree again I thought it was very a very good response and I noted in one section it was probably the best response that we've seen the idea that you're going to come to Massachusetts and you're looking for for space that's certainly it's responsive to what you noted as the legislators and intent at least under the Spana Gaming Act to make gaming and economic engines on I hope that too can come to fruition so thank you and for any jobs so thank you we'll move on to D section D any questions Commissioner Maynard would you like to lead on that then you want me to roll this over from section C I know that all of us have asked the question about diversity spent especially around supplier diversity which is in the application I would take this time to commend the applicant on their answer is the most aggressive answer that we have seen I will note that if you miss your mark by half you've more than doubled the most aggressive answer that I've seen yet and so you know I'm a true believer that you know to do anything you've got to set a goal so I like seeing the goal and it's kind of fun to do the impossible so I'm interested to see how this plays out I agree with Commissioner Maynard I would also request that you provide your spend your current spend so that we can put your goals into context I didn't see any any raw numbers included in your response though I do think like my fellow commissioner that it was one of the more responsive pieces that we've seen to this section of the application thank you just sorry just we will follow up with that Commissioner Maynard thank you other other questions under section D just going to I'm satisfied with the numbers the workforce the diversity numbers and within your workforce I'm hoping that you can narrow down the stats for LGBTQ plus disabled and veteran groups if you can and feel free to supplement that as well I know you have a small team but be interested to see what your numbers look like in those areas as well we will do that thank you I noted my overall comments on section D were very very positive particularly as an emerging company so I'm happy that you're thinking in the right at the launch on this it matters very much to me I noted and I think it was connected with the supplier spend that and this might be a little bit of being responsive to Commissioner Skinner's earlier question is that 75 percent of your organizational partners are small businesses and 25 percent are large and that seemed striking to me because in many cases we hear that the applicants are struggling on how to get to any diverse numbers and suppliers spend because they're national organizations that are technology based and so it's hard to to develop that you are in the early stages so that may be one of the reasons why you have those stats but to the extent that they can continue to be cultivated and expanded upon that's that's very significant and I know Massachusetts small businesses would welcome the opportunity for that partnership great thank you and we're excited to work with the supplier diversity office yeah they're they're doing a great job there all right great um other questions on section D I don't have any questions I just wanted to reiterate that I like the candidness of the answer in terms of there was a lot that could not be put forth necessarily because of the age of the enterprise but I did appreciate the goals and sort of the candid discussion about what you were doing and I was struck also like Madam Chair just said on we've had other applicants come in and claim they can't get smaller businesses or diverse businesses and so I was pleased to see that you guys have managed to do something in that area thank you commissioners okay how do we feel about section D did it meet expectations I believe it met expectations Madam Chair excellent thank you I agree thank you commissioner Brian I think it exceeds expectations Madam Chair both inform in substance thank you commissioner Maynard I believe that they met expectations thank you and I will join commissioner Skinner thank you so we've taken the temperature on section D now we'll move on to section E responsible gaming commissioner's questions so E and G are what most trouble me about this application and I will start off by saying there's a lot of the rest of the application that was unique and in depth and really good to read but I have a lot of concerns about responsible gaming and G and they are connected to something akin to what I brought up with another applicant which is sort of this inextricably intertwining a media branch with a betting branch and we have in Mr. Paul someone who has a large social media presence and I lawed the company for being out there without not taking credit cards saying that you're going to you know the 21 to 25 recognizing the extra vulnerability of that population but I have a lot of concerns about the social media audience the following the demographics of that and sort of the priming them to then jump into this and follow somebody when they hit 21 and so I have questions for the applicant about if they can tell me what are the demographic breakdowns in terms of the following there's a lot of pumping up in terms of how much Mr. Paul has out there and how much better has there as a following and I'm wondering what the demographic breakdowns are on those various mediums and if it's something that is somehow competitively going to put you at a disadvantage I'm happy to talk about in an executive session but I would like answers to that. Yeah we would prefer just because it's internal proprietary data we would prefer to share that in executive session but we're more than happy to walk you through all of it. I would like to have a more public conversation about in general the concern that I raised which is the overlap of sort of Mr. Paul's social media persona that crosses over the lines with him being the face of a bedding company that would only be 21 and up. Yeah in terms of Jake and marketing strategies around him I think it's not just the Jake Paul company he's obviously a huge part of what we're doing but also looking to bring in dozens of other creators to create this organic content on a 24-7 basis as outlined before and then testament to the growth that we've had so far I think as we'll talk about in the executive hearing demographic numbers in line across industry with overwhelming majority being over 21 and that's who we're always marketing, featuring, targeting to and everything that we do on the better channels. Yeah it doesn't doesn't necessarily assuage the concern that I have in terms of the media company's efforts compared to the bedding and that there's a possibly a conflation in the minds of the public I guess to follow up on a more specific question another applicant we talked about the social media posts of a media branch of their branding and then they have a whole team that spots it and checks it basically for responsible gaming messages and that sort of thing and that that will soon open up to sort of a more broad review of exactly what's out there and I want to know what the team has presently and what the plan is going forward in terms of that messaging. Yeah on the RG side I think you mentioned a little bit earlier in the presentation but top of mind in everything we do every piece of bedding content promotional content features a responsible branding and card and captions in our copy so you really can't consume any of the content that we're creating especially that is on the nose gambling and or promotional towards a state like Ohio or hopefully Massachusetts without you know being inundated with the messaging to you know responsibly if you have a problem we'll call the 1-800 helpline and to you know 21 and over is key for us as well and included in that message here and commissioner and Brian just to build off of that a bit further is that the application predated our go live within Ohio and since then as Michael alluded to and said specifically we have been called out explicitly for over community over communicating responsible gambling and messaging and again just to reiterate for you know any organic content that we create we will not include any influencer any person any staff member that is under the age of 21 we don't want to make betting so much aspirational we want to make it entertaining as the app is meant to do as well so we're very conscious of that and we we're really engaging our predominantly male and again we can get into more specific numbers in the executive session but the majority of our audiences is well over 21 right I guess to go back to the main point of my question though is what about review on the media side because that's an integral part of the branding for your betting side and so my question is what kind of betting standards review do you have on the media side got you we set out a work with Ashwin and Robert to set out guidelines for exactly how we handle all of our posts and what needs to go into each and then every post that does get posted is reviewed by our social media team which is being built out and already has eight to ten members within that team and there's a leveling up process to the social lead for all of those posts these posts also come through compliance myself and my partner who's not on the call we also review these posts sometimes before they go out sometimes we do spot checks after they go out to ensure they meet the standards but we do impose standards we have standards for that are really gaming standards that we impose on the media post and we enforce those and I appreciate that and I do want to say that I did note the lauding that you got in terms of the responsible gaming messaging and again I think a lot of your approaches really speak to that it's the standards and things I'd love to see are not just restricted to gaming it's sort of in general the the idea of and this again we can defer some of this to suitability but the idea of meeting to have honesty and integrity and a reputation that's integral to a licensee in this field I would want it to go beyond just the gaming standards yes ma'am and we have a we can share with you some of those standards as well great I appreciate that and I should note that I appreciate too that you have your independent compliance committee of all individuals independent from the company that I believe probably Mr. Warren should there be non-compliance well first off I am presuming and Mr. Paul has a big following and that's that's part of his brand but it does come with an additional obligation because of the issues around age and responsible gaming for the company to keep close audit of the media social media postings and that's you're not unique you're not unique every company really relies on on varying it's not influencers just marketing approaches that require that social media watch so I'm presuming that falls to you Mr. Warren and then should there be any issue you have your independent compliance committee Ms. Haig who has a great deal of experience out of Indiana and the other two gentlemen so Mr. Warren is that do you have a direct communication with them or how is the structure for compliance purposes yes ma'am again I communicate directly with the social team as a social team we came together actually to create the guidelines together so social team will do their review notify me I'll do a review social team we do have I trust the social team in the sense that I've trained them well they go through RG training they abide by the guidelines that we set forth but then I still do an independent review of the material that's posted should there be any issue I'll directly address the issue or you know dependent you know certain criteria we've only been operational for a month at this moment but you know quarterly we'll have our compliance meetings and that's when we'll come together and see if there are any issues that we need to concern and we'll do it that way too as well and Robert and I escalate to the compliance committee that's the that's the chain there and then link to the compliance committee that helps oversee and provide guidance in terms of these areas and make sure that we're on top of these things for the reasons you mentioned and back to your original question Commissioner O'Brien this also happens in real time we've set up a structure to to feel comfortable but if there is anything of question it has always raised in real time as well to posthum and other other questions on section E responsible gaming I have one more but I'll defer if anyone else has questions no go ahead I do have a question but go ahead Commissioner O'Brien okay I was going to let Commissioner Skinner just to see that prompt some more thinking then I'll turn back to you Commissioner O'Brien if it's a follow-up I prefer that Commissioner O'Brien go okay thank you thank you it's not really a follow-up but it's more a discrete I think it's a yes or no which is page 135 you talk about having something into this commission within 60 days prior to launch in terms of an RG plan and my question is do you have sort of a corporate RG plan in general already proved at the board level we do because we did have to submit something to Ohio so yes we do have something approved and we would submit that we obviously wanted to take into account and even learn as we went through this application process with Massachusetts but we do have something that we could submit assuming that there's no changes required for Massachusetts I have some mass specific ones but I'll defer Commissioner Skinner and I'll come back okay thank you Commissioner Skinner so I like the concept of micro-bending that you're choosing to focus on I like the philosophy that you identified in terms of the entertainment factor and not a means to make money but are you concerned that in your targeting specific targeting or marketing to folks who are not traditional sports wagers will create a gateway of sorts for those individuals to expand their gaming practices or wagering practices beyond the micro-bending platform and if so how do you how do you balance your philosophy with responsible gaming yeah so I think right now our focus is on in-play play we plan to introduce some level of P match beds but again with the same user experience where we ask customers for example who will be teammate or who will be very simple to understand without the concept of you know the money line plus and minus really giving the opportunity for a customer to make make the decision between at the best again looking at the industry not just in the U.S. but also in other jurisdictions since the industry itself is moving you know slowly but moving towards in-play we need to make sure we we enforce the same responsible gambling tools across the board and if together with MGC or any other regulatory body we identify other tools that could help in prevent problem gambling or actually encourage responsible play we're we're definitely interested in expanding that that's why you know we go back to the example decided deciding to ban credit cards and introduce the deposit limits on a certain age we think that those are so measures that will be helpful and will allow us to basically educate customers towards a responsible play and I think there are other tools that we mentioned that we we're looking to introduce and it's our responsibility to make sure we we bring the right audience and you know if there are problem gamblers like we and other operators need basically to address that that issue and with intervention and I mentioned this earlier relative to the under 21s and their ability to create an account without going through the KYC verification process I raise it and and from my perspective it seems an area of vulnerability given you know what we've heard over over time where you know if violations occur it's as a result of a system's failure or switch that didn't get turned on inadvertently things like that and so just my suggestion is to consider whether or not you want to maintain that practice and I know we as a commission have heard from at least one other applicant that does not allow under 21s to register for an account I we appreciate the feedback and we definitely take that serious in consideration I think we have been talking about it and we I don't think we have like the right answer but if that's something the commission feels strongly we will definitely introduce that you know full transparency that makes you know sign up harder but we we understand that also I think it's public knowledge that some of the operators that you already reviewed you could go and create an account without actually passing age verification like we were more than happy to insert that and make sure that with better if you create an account you're taking directly to the KYC flow and before you see the platform you need to pass the KYC checks like we're we understand your your feedback that we appreciate and I think that's something we could definitely look and work together with you and I'm doing that if I could pick it back up ask you in real quick sorry what he said was absolutely right and I just want to make the distinguish I want to distinguish between the account and the active account when you create an account you create the free money account quote unquote so you would never be able to deposit or withdraw or place a sports wagering bet without going through the KYC process at all so I just wanted to make sure I mean I understand again we totally understand the need the the perception of there being an issue and so we're going to explore you know it going straight to the KYC but at the moment I know you have an issue with them even being able to create the account they do not create active accounts thank you and then finally madam chair just an honorable mention of the proactive a step of meeting with mass council on on gaming and health so that's much appreciated and thank you for noting it my post would be we are so delighted to have partnership that we have the council and look forward to you obtain a license for your close relationship with our very very capable director of responsible gaming here who works so closely with learning workers so and in our game sense program so we're very fortunate to have them as our partner Michelle Bryan if you have a follow-up now it's somewhat follows up on what Commissioner Skinner just gave which was I was happy to hear that I think it's the only if anyone's done it no one else has mentioned it and I'm in part happy to hear that because the the question in section E the very first question of E one one I believe specifically asks for the answer to reference back to some of the Massachusetts responsible gaming framework that sort of stuff I didn't really see a lot of that reference in the answer so I would hope that if you are granted a license in your back presenting us with a plan that you will take note of the fact that the plan should you know duly note your conversations with them and then also what's referenced there in E money absolutely and that's why we reference the game sense logic model we we will absolutely work with the Massachusetts specific resources to to update our RG plan thank you other questions on this section Commissioner Maynard and Commissioner Hill are you all set Commissioner Hill can I take the temperature on this section I would say in section E they met expectations thank you Commissioner Maynard I believe they did Commissioner Brian I'm going to defer until I hear the specifics on the demographics and executive session so let's discuss where we are with respect to executive session I think very beginning Council Grossman we we acknowledge that in order to really get an understanding of projected revenues in the financial situation of emerging company we would need RSM for some report which needs to go in executive session Commissioner Maynard I think you had a an earlier one and I should have written it down and I did not can you remind me of that seeing or or Council Grossman I think it came from Commissioner Maynard it had to do with section C and the clarification on the revenues so it was related to what RSM will provide as well yeah C2 C2B1 and C2C1 thank you Crystal okay and and just now the demographic breakdown on the very social media platforms and that's something that we can discuss I mean that you'd be able to address if the executive session is appropriate I believe so I think that the representation was that that would be competitively sensitive information that would put them at a disadvantage if they discussed it publicly thank you very much so Council Grossman does that all sound good so far yeah so far so good absolutely there was one other I have that I'm not sure if you're interested in they came up at the very beginning as part of the demonstration there was an offer to make a demonstration with specific personal information I'm not sure if that's necessary at this point but I just wanted to circle back I think it was going to be the use of someone's actual social security number and not to say I don't I'm okay not not seeing that you may not share your social security number with me but I think we're all set I think the technology demonstrated and we're familiar with that function am I right commissioners we're all set on that agreed thank you I think I unless the applicant deems that a critical component of their presentation we we wanted also to show like the full no what it says what happy with with it oh yeah thank you all right okay so we're all set with that so now we're going to section questions on section at commissioners that the general observation you use your two platforms for the bedding and and their p.m. and but you do use geo comply and I do have partnership with U.S. integrity too I think I recall that so you are using some of the best of class specialists on security issues yes so we have a comprehensive and know your customer partner that does multiple checks and they are looking at age also they are looking at specific flags like pack or full fact so the customer can fail due to that if you want we can expand into executive session who the partner is and then in terms of geolocation yes we are using geo comply the industry leader in in the space which is providing us location services and then for sports betting integrity we use U.S. integrity basically we we have a direct feed from them when certain mark you know if events are suspicious they are letting us know and at the same time we perceive suspicious activity or not last one we contribute to that the good news is that from an integrity perspective being a you know largely in play operator if there's integrity is usually those are flag well before the game or a math start and games are if it comes to that point games are disabled by the time they are on our platform just because all operators contribute to this integrity platform commissioners have quite a comprehensive response any questions is that commissioners on F? I think I'm ready to say that F has met expectations madam chair we agree I agree which is going to fill okay I agree okay then we'll move on to G and I know that as we move into G and suitability there may be issues where we need to think about the discussion arises so we'll keep that in mind am I sure? Madam chair I had a couple of questions about the litigation matters that were included in the IED report and so hoping we could just get some additional information about the substance of each of those particularly the defamation Mr. Crosso Mr. Crosso is that something that you can in second session or is that public? Yeah I would ask you know there's there was a list in the IED report of litigation matters and I would ask that we could address those in executive session we feel like these may constitute an unwarranted invasion of personal privacy or otherwise maybe subject to confidentiality obligations or pending legal matters which are not appropriate for public comment so we would ask that we try to address you know all of that first in executive session and if it's determined later that you know something can be addressed in the public session we work in that order so that we can be as transparent and forthright with you on all the circumstances regarding those matters that's that sorry sorry Marcia Skinner so did you want to pursue does that if it's acceptable to go into executive session did you have another question on that or no I just wanted to be clear for the record which items I'm interested in so it's that one relative to defamation and then the one relative to sexual assault yes those would fall under the statement that I made previously other questions under so I have another question about another litigation that's in the public domain I can find the notes and I don't know if it was in one of the open source articles or not believe it's a February 2022 yep litigation in which Mr. Paul is named amongst others in connection with SafeMoon cryptocurrency and that's right before the last page of IEB's report yeah I believe that's still active litigation we would appreciate the opportunity to discuss that fully in in executive session and and you know again if there are things that we can be public record have to go back to the public record and address it there but would ask that we go first to executive session to hopefully give you as much context and information as we can actually this might be a good time to jump in and say that we actually do it the other way around we first talk about how much over much we can in public and then if there's further detail to supplement the public information we can consider going into executive session and the reason for that is that most and I'm not saying all but most matters of litigation are public complaints are filed of course in courts and there are matters of public record most of the pleadings are public information so we are going to first need to pinpoint the specific cases and identify which parts of them are matters of public record certainly to the extent that we're interested in understanding what defenses may be raised and things of that nature that's certainly protected but before we do that we do need to review the matters of public record okay understood and I would ask Mr. Abrams and to help weigh in if we want to go you know go through these specific items in the order that commissioners raised them or however we'd like to do it Councillor Grusman the challenge for me on that is that if the commissioners start to ask questions no we have one article and you know perhaps we don't really know what is in the public domain and what is not so if we start asking questions we could be going into an area of litigation that is protected and so I feel like we've done the reverse recently but I might be wrong I feel like we just had where there was pending litigation there was request to start and then come back where we might understand the matter better and know what is in the public domain which right now we don't really know what's in the public yeah I mean the best way to do it is to get a copy of the complaint so we can see what is in the complaint I don't have the complaints here so I can't answer that question and then we can figure out what further information the commission might be interested in oftentimes the complaint tells the whole story and that that will get you where you need to go other times there are follow-up questions so I don't remember doing it the other way but it is possible we did that at some point in a specific circumstance I thought I heard that in one of the recent hearings where they requested to go into the executive first so that we could give you more fulsome explanation because certainly what's in the complaint you know certainly in these headlines is not representative of we think all the facts and we'd like to be able to provide that which you stated touches on defensive and potential responses that are sensitive I think the only thing that we've been pretty consistent about that was referencing to them publicly to the extent that they can be referenced publicly so that we know and the public know why we're going into executive session so to the extent that there's docket numbers that you're aware equate to the references we're talking about they can be referenced so that it's very clear what we're going into talk about yeah I agree that's at least a good place to start I'm having a hard time looking through the IEB report and even seeing where these cases are well they're not yeah it's it's part of that that reference them that's that's what's troubling me Mr. Grossman is there it's a it's an article it's not the you know IEB summary of any kind of pending mitigation so I want to be mindful of their boundaries I also need to make sure that we are fully in compliance with our obligations and you know when we do want yeah I mean some of this because I have read any of the articles so I don't I'm just going off of the headlines that have been included in the report so I don't know what's in the public domain and what's not so I did link and some of these I don't believe actually have cases associated with them and some of so one of the challenges is a lot of some of the other applicants affirmatively disclose litigation even if it was not technically you know knowable that it may risk a hundred thousand dollars or greater at the end of a judgment and the answer here was nothing was identified nothing was self-identified and so that's part of the conundrum that we're in is the open source does in fact then bring up related litigation so I don't know if you have you the team that better have the public docket references in relation to these articles or not but again there are there's one or two I don't think are even litigation Commissioner Bryan could we there's there's many I think to be to be there is there a precise list of that you could ask about without you know adopting so because of position or or yeah which is I'm making a declaration about then so I had I had three matters in particular that I wanted to discuss you might have gone on yeah one I know is litigation to are probably privacy concerns and two of them have to do with sexual assault allegations that are referenced in the IB report and the third is the litigation that I reference filed in February of 22 relative to the cryptocurrency in SafeMoon which I know that at least is in the public domain and I don't know Commissioner Skinner there was something beyond those three that you cut they caught your eye in that article list so those are three and now Commissioner Skinner the two items that that caught my attention have already been referenced by Commissioner O'Brien although I I don't understand that there are two separate sexual assault allegations there are two articles that reference that those are the ones that I'm talking about a single or a simple or simple incident media media media presence I should say okay and so the other one I'm sorry was the defamation lawsuit so and Madam Madam Chair I wanted to add number seven to that list which I think is appropriate for this discussion um and actually number eight now that I'm looking at the list too I didn't realize that there was a suit associated with that there's part of it that might be in the public domain but that's the defamation claim that I was referencing I believe I don't believe that's defamation no it's on a little different looks like a civil settlement maybe again these are news these are news accounts so just I want to emphasize that and it's the same you know just what's been picked out it's not IEP some or say summaries or things like that yeah I actually have to retract what I said earlier I did click on a couple of these I think number seven was one and I think there's a little bit more detail in the article which I I do want to say it's regards defamation but this is part of the problem we don't know what we don't know what is out there so it would be helpful to just kind of get a walk through of exactly what's pending in terms of litigation so are you pointing out my concern commissioners get about what we're going to talk about publicly here without is that what you're saying okay thank you I'm sorry yes no that I just wanted to echo your concern Madam Chair and that's where we're going to have difficulties going between the public record and executive session in terms of straddling the line on all of these items and that's why we had suggested we go to executive session we give you as much detail as we can and then we can return to the public record if we determine the pieces of it are are public and after you have a full understanding of of what these matters are council aggressive well again and I I it's it's best to do it the other way but if it would be helpful to do it this way we can try to navigate that so can I just say from where I'm standing in an initiative of transparency and trying to balance though that the references one through eight I believe are all news articles so they're out in the public domain so at a minimum I think if we say the page number and then you know even the date and the publication in the native in the article because that is in the public domain and it would specify without going into further detail that would potentially not be within the public domain well sir stuff I don't have it for a reason my pages are not known so so these are I believe mostly on page 10 of the IAB report is that that's what we're talking about top of page 11 and that's exactly the issue they're all public reports so it seems to me that they can at least address what the allegation was yes happy to do that happy to address the article and the allegation I just assume that you would want to a more wholesome discussion of the defenses or more contacts in fact surrounding those circumstances some of which are going to go into the boundary of privileged materials of things that we don't think are appropriate for public discussion so I think if we go down the list and then you say the public consumption summary and then flag when you hit a hit a privacy or a privilege wall could I be that's a good idea but I do we I don't know if we have to go through all of them but back to the ones that are particular interest or are you saying you want there are 10 on the list and and some of them duplicate topics but to be blunt Madam chair it is a it's one of the concerns that I have with this application so I actually do want to hear about all 10 well I asked only because we had we went from three to now the 10 so well because to me in my estimate might be three that arguably with an venture into executive session territory but you know counsel for better may in fact have more information than I do about information that goes beyond what I know obviously and maybe it also will also satisfy interest Mr Rachel I think I'm going to ask that you manage this the best you can for your client does that make sense yeah I'll follow Mr Abramson to help navigate these items as you go through the list as well thank you does it benefit you at all to take a short break to get the list together are you guys ready to go Mr Abramson I think we're ready to go thank you thank you Hi Mr Abramson you want to ask a specific question or well the question is the as you can see on page 10 I'm sorry if it's not numbered but it starts with number one a CBS news at the top that's not the list that we're looking at we're looking at the next number one and Commissioner O'Brien has asked if you could walk through each item to the extent that it's in the public domain without either compromising what could otherwise be subject to an exact procession of course we have to always check on that so yeah Jake do you prefer to give a statement to prefer that I do so I don't have a list in front of me of like what's one is listed at number one or two or whatever so I don't know me I wonder if someone can give a suggestion to have Mr Abramson yes you just say a high level what it's about I want to you know I don't know if there's also any way to get to follow the bottom of this you know the first time sorry I'm sorry do you have it now Mr Abramson I believe so the first one that the people dot com people dot com are starting Arizona mall that one yeah would you like me take this shake or um yeah yeah no I mean I think to set the stage I appreciate the commission for the opportunity to be heard on these matters and I respect this process I think just by way of background the reality of my life as a young and highly visible digital creator was quite different than the normal teenage experience the best way to sum it up is that everything is exponentially magnified you live quite literally under a microscope and you certainly get more opportunities but you're also taking advantage of more often mistakes magnified publicized and republicized and you become a bigger target for a frivolous claims lawsuits media headlines and many many other interests for for and and competitors and for people to make money off of off of your demise the public and media also confuse your public persona with your real life which is quite a lot for any human to balance but for many years headlines with my name garnered a lot of attention at one point we were specifically just with TMZ every time I was their most clicked article anytime they would publish anything about me and so I've become accustomed to reading many false or exaggerated stories about my life with catchy headlines four click bait and four monetary compensation for these brands from what I understand there's over 229 million search results just in the past 12 months and of course some of these are going to be negative articles and I've unfortunately become accustomed to being a target for unwarranted claims and like everyone I've made my share of mistakes and have messed up and have grown up in the public spotlight and done stupid things that from what I've learned from but as you'll see these matters generally don't warrant this level of media coverage and attention you will see that also in general nothing or very little has in fact come from these sometimes shocking headlines and crazy situations which are great for views and clicks and for me to be made an example of I've never been convicted of a crime and while frustrating these experiences have helped me grow as a businessman and a public figure and a human and I've become hyper aware of the projects I support the brands I lead the things I do the people I surround myself with and I'm grateful for all of my experiences and the awareness and wisdom they brought me and continue to bring and in terms of reputation I think we should differentiate from the fantasy world of social media where rumors run unchecked and in real life I have a stellar reputation in business and the professional world having worked with many brands boxing commissions talent the largest sports promoters Fortune 500 companies and organizations with absolutely no issue no disputes and in almost all cases repeat an ongoing business so I guess yeah I guess that is just to like set the stage before delving into any of these but can go back to the first one is it people people.com what's the about the Phoenix civil rights demonstration. Yeah no so I happen to be in Phoenix during the George Floyd civil rights demonstration and I left dinner at a restaurant outside of the local mall there and noticed a crowd of demonstrators marching into the mall and along with the group of people I was with we were curious and followed the demonstrators into the mall and we're in supportive of the George Floyd protests and my videographer was with me at the time we're always making videos and what I was witnessing was the the craziest thing I had ever seen and as a content creator made the mistake of wanting to capture that moment to document it and we were present in the mall but did not take part in any vandalism or looting and I resolved the matter with the misdemeanor trespassing police like for us to go to the next one next one involves the FBI warrant at your house yeah so my home was you know to my knowledge this was related to my presence at the civil rights demonstration in AZ no charges were filed against me as as a result of the search next item is a article relating to Justine Paradise yeah I was I was the target of an unfounded and false allegation that was posted by someone online though the post received predictable online attention and was I believe purposely put out the week of my fight to put a fork in that there was no truth to the allegation and at all whatsoever in no way shape or form complete blasphemy and nothing further transpired so I do have a follow-up question on that not on to sort of the substantive allegations in that video but sort of a sub detail in there that I would like to ask and counsel obviously you tell me if you think you're going to advise me not to answer but there was a representation made about sort of any documentation that might have needed to be signed prior to going into your home or your studios an NDA and non-disclosure agreement can you speak to that allegation anything relating to Jake's business practices in that respect we'd like to take up in executive session so it's a business practice for a second okay the subject matter would be a business practice okay can she just add that to the last time council president he's fraying at the business practice do you want to do a follow-up question to just take us in about competitive disadvantage our language that we would need for an executive session yes thank you so counselor Mr. Paul the exact there's two legal standards to consider to determine whether we can discuss this in executive session and the first is whether the matter is competitively sensitive to the extent that if disclosed publicly it would place you at a competitive disadvantage so that is the question as it pertains to the non-disclosure agreement at the issue that was inquired of the second possibility would be that it could arguably implicate Mr. Paul personal privacy and I'm not entirely familiar with the nature of the agreement itself or what have you but if it does implicate his personal privacy and would be an unwarranted invasion that is another standard that we can consider thank you and I think more more meaningfully we'd be speculating because I'm not aware of the document that Commissioner Bryant is referring to in the first place and so I'm not familiar with the article I'm not familiar with what what the quote was or the document so I thought you were asking about business practice more generally knows our representation in the video itself that that's such a document we're not familiar with the representation so we wouldn't have any further comment I'd like to add because I don't take I never took this allegation lightly it breaks my heart if you know my character and you know I don't even like giving more attention and light to it but to add context the journalist actively solicited on the internet for a period of weeks for anyone who had something negative to say about me and that journalist that was involved with this whole situation was recently banned from Twitter for false reporting and again there's an absolutely no merit to this and again completely false and made up okay so I get I do have the same question though whether or not there's in fact an NDA required to enter the studios or the or the premises I would be speculating I don't have that information I'm asking Mr. Paul but I'm doing Michelle Bryan I just want to be careful yeah who are your I'm not I'm not sure I'm not sure what that's referring to okay yeah I think thank you Mr. Abramson doesn't isn't familiar with either the article or what is what you're described no Mr. Mr. Paul is and he's he just answered my question to my satisfaction okay thank you thank you and actually I think we ended up answering both these two items they involve two different individuals but the responses is the same our claim maintains it was a false allegation and there's no truth to it and nothing came of either of these two online allegations so that would bring us to the next item on the list I believe and the number for you Mr. Abramson so we are we're all okay I seem to have lost that document does anybody else have this five and six yeah I think you're on number seven and it counts yeah they were duplicate so that's a four five and six I think are just have just been addressed the next item it has to do with the matchroom lawsuit is that is that correct on your list as well yes okay yeah but number six number six I'm sorry is the he said that it was the same response to the same response okay yeah thank you yes thank you so so now we're entering an item which is the subject of pending litigation and so and it's very early on in the litigation context we're happy to get a copy of the complaint if you haven't seen it and provide that to you but I'm going to answer my client not to provide any comment on this pending litigation at this time other than that we're vigorously defending it I'd be interested in copy of the complaint but then also copy of your answer sir as well yeah there hasn't even been an answer for all of you it's my knowledge what did you expect to find an answer I would have to check with the council tell me that not thank you next item on the list I'm sorry I don't have a number but it's it has to do with a can I ask Mr. Abramsen can I ask Johnson Grossman and I don't know if Mr. Abramsen would be even a position to share this could what they anticipate the response to me the answer to be be something that we could hear at this juncture in the executive session if he's able to share that I think if they're comfortable in fairness it sounds like Mr. Abramsen is not at least the lead council in that case and I don't know that it would be fair to ask him to offer an answer to that question unless they're comfortable doing so of course I wouldn't have anything to add to that okay thank you okay been going on the next item is 2018 article regarding a rental home in California Jake got it yeah yeah this was during a time in my late teens when I lived in a rental house with a number of friends and it was completely blown out of proportion by the media and again my name was used in the headline to be shocking and garner attention this matter was settled and amicably resolved yep and then the last item is the safe moon matter that was referenced earlier in this fashion and this is also a pending litigation matter which is also very early on I'm not sure that an answer has been provided on this one either and the council's handling this matter is not present as well we'd be happy to get you a copy of the complaint and if there was an answer a copy of the answer as well that would be helpful okay commissioners now that we've gone to that list are we are we satisfied in terms of asking all the questions and obtaining any supplemental information that we need that would be with the extra both complaints will be forwarded to us I'm satisfied at this point thank you commissioners thank you same so it's okay thank you as am I yep okay great commissioners thank you else that was satisfied so and that's having gone through that list and section G and it's um full sum of review are there any other questions that are separate and apart from that exercise we're going to have on the financial stability we'll hear from RSM sections and then we we've discussed compliance we've also discussed on Mr. Warren's role in compliance and the compliance committee there anything else with respect to section G that we need to discuss I think the only other area of questioning that I had concerning me and insudability is you know Mr. Paul talks about his you know experience being on social media putting out you know the tiktok videos YouTube videos that sort of stuff and there was an article I believe as part of Ibiza report that talked about sort of that the repetitive references and some of the videos that you put out in years past that would be deemed almost predatory advertising and in said the UK the repetitive references to things and if I can pull up the reference if I can find the article think it was on in the verge September 4th 2018 and so if if if Mr. Paul or maybe somebody from better can speak to what if any changes are out there in terms of Mr. Paul's you know social media presence in particular when it comes to that kind of allegation I think it connects a little bit to responsible gaming like we talked about and and a little bit unsuitability what what exactly are the where the claim is like what does it say I thought this was linked into the Ibiza report you have it commissioner September 4th 2018 I don't see that I don't see that in the Ibiza report no link to that one maybe I was looking on my own I found that there's three articles mentioned about the the derogatory articles and I don't see a September 2018 one okay it may have been when I was trying to familiarize myself with Mr. Paul I guess what I want to maybe speak to have answered is for Mr. Paul and from better sort of in this piece a little bit to what you talked about and to post and things like that on social media but one of the concerns that I have in terms of suitability and responsible gaming with this applicant is again like I said the intertwining of the media branch with the betting branch so to the extent that there's anything you can talk about in responsible gaming and your marketing that deals with I guess what the UK would talk about in terms of pester power repeatedly referencing something to try to get somebody to want to try it or buy it is that something that's part of you know your sort of responsible gaming responsible marketing lexicon definitely I'll just say one yeah one thing on the other side and on Jake's side as well while we're you know marketing micro betting and showing people engaging in the activity of betting and micro betting with the club covering sports content the athlete who retires I would say 15% of our total content is highlighting you know micro betting give or take whereas we're on the on the media side covering sports in general so not super familiar with pester power but from what you how you describe it I would say definitely not yeah and I think like five years ago again the the amount of hit pieces and people trying to attack me it was absurd but but five years ago I also was a youtuber I was 20 years old not not mature and now for the best four years three and a half years I've been a professional athlete so I've you know gone away from from that world as to I don't really know what the article mentions but don't even put out nearly as much content and again my focus every day is is my training and focusing on my fights so I know I'm sorry I'll go I'll go professional Brian Mr. Scared no I guess what I the only thing I would ask is given I can make the reference again for the record September 4th 2018 article on the verge written by Megan for a monash it looks like F-A-R-O-K-H-M-A-N-E-S-H I just would ask that Mr. Paul and better take a look at that and if there's a supplement that they would like to give in connection with their application in that regard I would be I would really want to see it because it is part of reputation and character and suitability I think we would be happy to provide a supplement that addresses that and especially just given that the digital ecosystem has changed the marketing and advertising efforts significantly since 2018 and we're certainly keeping that in our in our focus and and making sure that all of our marketing and advertising efforts are given to those that are opting in and and willing and participating so we'll take that into into consideration we'll read the article and come back with a response great thank you thank you other other questions on section g okay hearing none in light of what we've asked for for supplemental information did they applicant meet this section Mr. Maynard hi are you may need of commissioner well I think we were still getting information in executive session from rsm some of that so circle back yeah okay for rsm that makes sense we'll circle back so in terms of going into executive session there's a little bit of a process before we we need we need going to executive session I guess I would just like to point out that as I look at this overall application I was impressed by by its thoroughness and it was a a long but compelling read to learn about what is an innovation in even though we know about in play this is a different a different product and I I want to extend my appreciation for this applicants recognition that there's clear space for disruption your word and innovation in a highly highly regulated landscape and so I appreciate that you recognize that and that the two can intersect and I'm I'm going to take Mr. Paul's lead I heard you and it just was with a huge responsibility to play in highly regulated space and you said integrity first and I'm noting that as part of section g Mr. Paul I heard you and so with that I would just like to close out this and move into our process of going into executive session. So Mr. Grossman we've got a list and then we just need to know if we can move on. Yes Madam Chair I have two possibly three I think just two items to raise for possible executive session discussion and the first and I would just note as was discussed it's my understanding that this is a privately held company which means there's a good deal of non-public information relative to the finances of the enterprise that are included in these reports and will be discussed. And so the specific issue for discussion in executive session relates to asking that RSM and the applicant discuss the financial projections and the relation to the overall stability of the applicant including a discussion relative to the market share percentages that are projected the revenues that are projected. There was not a great deal of discussion but oftentimes it's helpful to hear about the handle and hold percentages and get some insight into those figures and any issues that are associated with the aforementioned discussions as outlined in the RSM report. So that's issue number one and if I have that correct then that information would certainly fall under section 6i of chapter 23n in that it is competitively sensitive and if disclosed publicly would place the applicant at a competitive disadvantage. The second issue for consideration relates to the demographics of a couple of things and I want to make sure that we get this precise. The first I believe related to Mr. Paul's social media following on the variety of platforms and how the demographics broke down there. There was also some mention of possibly the demographic breakdown of betters projected patrons as it relates to the previous matter and there was I believe if I heard correctly some interest in hearing about the demographics of potential targeted targets relative to marketing as well. And I think there's a lot of overlap between those three categories but I just wanted to make sure I had that correct. And if so those would all again fall under the category discussed in section 6i of chapter 23n and that they all call for the discussion of competitively sensitive information that if discussed publicly would place the applicant at a competitive disadvantage. The only other issue on my list and I think we have this resolved related to litigation matters and it's my understanding from that past discussion that we just concluded that with the provision of the complaints and any associated filings that there were no further questions related to the any litigation or other media reports. Missionaries does that sound right? Yeah with the only caveat that once we get the complaints whether we have follow-ups you know would be still open for discussion. That would be part of our of our process on the 18th and 19th and there's a process that would address any outstanding matters. Okay. All right. So for those of you who aren't familiar with Massachusetts of the meeting law are required to read this into the into the record and I it's my understanding we're all under 6i. So the information was generated under 6i the executive session provision Madam Chair that I think you're about to address is actually in yeah. So it's for I don't think we have any N or C or section 7, 2016 of privacy and we don't have anything to do with public safety. So it's all just under competitive disadvantage. It's all 6i. Yes. And it's that's right. That's entry 4d2 on me. Okay. Yes. It's under the agenda item which is what Mr. Grossman was referencing is under 4d2. Yes. That's correct. Yeah. Commission anticipates that it may need an executive session in conjunction with its review of the Better Holdings Inc. application in accordance with general laws chapter 30a section 21a subsection 7 in general laws chapter 23 and section 6i to consider information submitted by the applicant in the course of application of its application for an operator license that is a trade secret competitively sensitive or proprietary which it discuss publicly would place the applicant at a competitive disadvantage. Do I have a motion? Madam Chair, I move that we go into executive session for the matters delineated by Attorney by General Counsel Grossman as stated by yourself. Thank you. Commission. Thank you. Thank you. Commissioner Skinner. Okay. Any questions? That is all right. Commissioner Bryan. Hi. Commissioner Hill. Hi. Commissioner Skinner. Hi. Commissioner Maynard. Hi. And I vote yes. Five zero. Now we will be transformed I believe or transferred into another virtual room. So just join that please. Thank you so much. Okay. Sorry. I was going to ask and we can do this in executive session but a quick break before 10 minutes or so. I think she probably froze because she was moving. I think we're all set. Dave and screen savers. All right. You're reconvening public community number 421 at the Massachusetts Gaming Commission after a short executive session and because we're holding this virtually I do need to take attendance. Commissioner Bryan. I am here. Commissioner Hill. I'm here. Mr. Skinner. I'm here. Commissioner Maynard. I'm here. All right. We're all here and I want to express my thanks to the applicant for its interest coming to do sports measuring here in the Commonwealth and for its application and the presentation demonstration today and very candid responses to all of our questions and for of course the executive session. I want to give the opportunity for you Mr. Levy and anyone else to speak before I turn to my fellow I'm good on my end as I reiterated at the end of the presentation really grateful for the opportunity to potentially receive the honor and privilege of receiving a license in Massachusetts and appreciate all your time here today. Ashwin anything bad? No just thank the commission and the staff for all the hard work and making this possible and we really appreciate the opportunity to be in front of you today. Mr. Paul. No thank you and I really respect this process and you know I think what we're doing is is really awesome with better and I hope you guys see that vision and I'm excited you know to potentially work together and today's been today's been really awesome and you guys are obviously really great at what you do. Thank you Mr. Paul and with that commissioners I give you a chance to add in Commissioner Maynard I'll have you go first reverse order. So I just want to compliment the applicant today you know the application includes some of the most robust answers substantially when dealing with goals on diversity and suppliers been and you know we have a lot of information that we go through when we go through this process but I will say that you know I think that you know we probe we're rigorous regulators but sometimes you know we can over probe and I just want to say that I believe that you held yourself very well today thank you Commissioner Skinner we're here I know you're we're well into this piece of the proceeding but did you want to take the temperature on sections oh thank you with Queen Regi first I said that's why we we need team right this is evidence of friends and colleagues right so as we just pause and I'll return to you Commissioner Skinner for goodbyes with recognition that we do have some outstanding information that we'll get on on suitability on on G are we set Commissioner Hill do you feel that the applicants met expectations for section E they have met expectations and G as well yeah did I I guess it was E and G because of the suitability piece sure thank you Commissioner O'Brien your nodding so I'll turn to you so yeah it's E and G and I'm satisfied with E as to G I'm going to defer until I see the information on the complaints but I think they'll probably have satisfied the minimum requirements so I can say that today yes you mean in terms of the overall application but you're holding yourself you're stalling pausing on section G thank you very much for that clarification now I'll go back to Commissioner Skinner so you you know that was Commissioner Hill Commissioner Skinner and then I'll go back to you for your regards I feel that the applicant has met the expectations relative to section E I'm with Commissioner O'Brien you know I will hold on my rendering of a decision relative to section G until we get the complaints okay Commissioner Maynard I think they've met expectations yeah and I believe they've met expectations on E and G and a reminder that should this applicant advance in the process there will be a full suitability investigation that's done with respect to our applicants so I feel today the applicant's application was very thorough in today's responses thorough so I say they meet fully the expectations from my perspective so now Commissioner Skinner what would you like to say so just a thank you to Mr. Paul Mr. Levy and team very thorough application I think it's a strong application I appreciate you actually taking the time to answer be responsive to all of our questions and the application and during your presentation today I have no doubt that you will continue to be responsive in the information that we've asked you to supplement and so I'm just want to wish you luck during this process and look forward to further discussion on the 18th and 19th Commissioner Hill thank you Madam Chair I too want to thank the applicants for a very thorough application but more importantly for the forthright conversations that we had today there was some pretty hard questions and I was very appreciative of the answers that we received from everyone so good job with that and I too look forward to a continued dialogue with you as this application moves forward and Commissioner Bryan thank you I've said it a bunch of times a lot of the fellow commissioners have said it as well there was a lot in this application that was unique a lot of detail about Massachusetts a lot of detail on the responsiveness in the product offering which I was very excited to see but I had equally an amount of concerns about it particularly when it came to suitability I thank everyone for their candor I don't think I did go too far anyone in this commission went too far suitability is is a serious issue I've been here five years and I know these can be very uncomfortable conversations and I laud everyone who candidly answered the questions that were put in front of them today so I thank everyone for their time and for their participation today with that again thank you thank you to the team in the room thank you to Mr. Levy and thank you Mr. Paul and I ask now for a motion to adjourn so moved second thank you Commissioner Bryan aye Commissioner Hill aye Commissioner Skinner aye and Commissioner Maynard aye and I vote yes again thank you have a great day thank you so much thank you thank you