 I'll start it up now. Thank you. Good to go. Thank you. Good afternoon. Today is Friday, April 14, 2023. And this is an adjudicatory hearing before the Massachusetts Game Commission, relative to the alleged non-compliance of Encore Boston Harbor with Massachusetts General Mile Chapter 23N, Section 3, 205, CMR 247.01, subsection 2A2, in the Massachusetts Sports Waging Catalog, I will refer to Encore Boston Harbor as Encore. My name is Kathy Judd-Stein, and I'm Chair of the Commission. And I'm joined today by my colleagues, Commissioner Eileen O'Brien, Brad Hill, Nakesha Skinner, and Jordan Maynard. The entire commission will preside over the hearing and decision of this matter. This hearing will be conducted in accordance with 205, CMR 101.01, General Laws, Chapter 30A, Sections 10 and 11, and 801, CMR 1.02, the Informal Fair Hearing Rules. This hearing is being conducted via remote collaboration technology. Before we begin, I'd like to explain the process that will govern this proceeding. First, notice of hearing was provided to Encore in advance of today's hearing. It identifies the alleged non-compliance incident that will be the focus of the commission's attention at this hearing. In the relevant statutes, regulations, and catalog, a pre-hearing conference was also conducted. Pursuant to Massachusetts General Law, Chapter 23N, Sections 4 and 16, and 205, CMR 232, the commission may hold this adjudicatory hearing that the conclusion of the hearing may decide to issue a civil administrative penalty, impose conditions on Encore's license, suspend Encore's license, revoke Encore's license, reprimand Encore, and or assessifying on Encore. At the conclusion of my opening comments, this proceeding will commence with a presentation of the evidence in this matter. Specifically, the commission will first call Zachary Mercer, IEB Enforcement Council, and any other witnesses listed on the notice of hearing or witness list. Encore may ask questions of any witness who testifies. Encore will then be called upon to make a presentation and to call additional witnesses to any. Any commissioner may question any witness who is testifying at any point during or after this presentation. Encore may raise any objection it desires at any time. However, the basis for all objections must be clearly stated. Finally, at the conclusion of all the evidence, Encore will be provided an opportunity to make a closing statement to summarize its view of the evidence. Before we begin, understand that there are pre-marked exhibits that have been prepared in advance of this hearing. Those exhibits are identified on the exhibit list that has been circulated. They are as follows. Exhibit one, investigations and enforcement bureaus what's wagering non-compliance incident review report dated March 8, 2023. Exhibit two, notice of April 14, 2023 here. Are there any objections to exhibits one and two being marked and entered into evidence today? Ms. Crom? No objections. Thank you. Thank you. Those exhibits shall be admitted into evidence and in order to maintain a clean record, I ask that the documents are referred to by an exhibit number. At this point, I will ask if Encore would like to stipulate to exhibit one, the IEB sports wagering non-compliance incident review report. We would like to stipulate. Thank you. Thank you. If Encore would like to have any additional documents entered into evidence during the course of the hearing, I ask that they be properly introduced and marked. I will add that no final decision will be made at the conclusion of the public portion of this hearing. Instead of the conclusion of the proceeding, the commission will privately deliberate and ultimately issue a written decision. If at any point during the commission's deliberations, it determines that additional testimonial or documentary evidence is desirable. It reserves the right to ask Encore to provide such evidence prior to a final decision being made. I'll now swear all the witnesses in. Anyone who will be testifying at this proceeding, please raise your right hand. Thank you. We solemnly swear that the testimony you will provide before the commission at this proceeding will be the truth, the whole truth, and nothing but the truth. I do. I'm seeing all affirmation and record should reflect that they have all responded in the affirmative. Before we begin, does Encore have any preliminary issues or objections? We did not. Thank you, chair. And would Encore like to make an opening statement, Miss Crum? No, we do not need to make an opening statement. Thank you. Okay. So with that, I asked Mr. Mercer to present exhibit one, the Investigations and Enforcement Bureau, Sports Wadring Non-Compliance, it's a review dated report, excuse me, dated March 8th, 2023. Thank you. Thank you. Good afternoon. Once again, Madam Chair and commissioners, Zach Mercer for the IEB on February 21st, 2023, E.B.H. Senior Vice President and General Counsel, Jackie Crum, Notified Sports Wadring Director, Bruce Band, that E.B.H. had inadvertently offered wagering on two unauthorized events through their Sports Wadring Vendor, WinBet. E.B.H. reported to the IEB that on February 15th, 2023, they became aware that unauthorized events had been added to their offerings, but those events had not been all activated for wagering. WinBet disabled these events and contacted its vendor, Gann Nevada. Gann is a technology platform that provides event management and other services to E.B.H. and WinBet. Despite the actions taken to disable these events, those events did not, in fact, remain disabled. Wagers were placed on an NCAA event featuring a team from the Commonwealth. These unauthorized wagers were ultimately discovered by a WinBet trader on February 19th. A trader is an individual responsible for setting odds on an event. That trader discovered that wagers had been placed on the February 19th Boston College Women's Basketball versus University of Louisville game. Following the discovery of this unauthorized offering, WinBet discovered another earlier unauthorized event that had been offered for wagering as well, specifically another Boston College Women's Basketball game, this one being the February 12th game versus the University of North Carolina. The IEB has learned the following key facts during its review of this incident. The timeframe that wagering was allowed for Boston College versus University of North Carolina, it was available for approximately four hours on February 12th. For Boston College versus University of Louisville, that game was available on February 19th for two hours and 13 minutes. As for this total stakes and amounts wagered, there were three wagers totaling $163 on B.C. versus UNC on 212 and four wagers totaling $50 on B.C. versus University of Louisville on February 19th. The total patron winnings were the one partial winning wager on B.C. versus UNC as part of the parlay. The ticket paid $53 in total winnings. $12.37 of that were specific to that game. There was also one winning wager on B.C. versus Louisville with a total of $9.09 in winnings. All in all, the total of bets placed was seven and all seven of those bets were placed at kiosks. As for the reported reason for the error, the IEB was able to review reports from both E.B.H. and GAN. From the GAN report, they explained that the issue at hand was due to the submitted titles for events from feed providers and how they're processed through their exclusion list. GAN maintains a list of excluded teams or events. The feed provider in this case, Genius Sports Media, uploads all market and wager types, and those are then filtered by GAN. GAN reported that Boston College was on their exclusion list. However, Boston College Eagles Women was not. Genius uploaded the events in question under the title, Boston College Eagles Women, and a lack of a match to the specific exclusion list title allowed the erroneous availability of for wagering. This issue was further complicated by an upload uncharacteristically close in time to the start of the event, whereas events are generally uploaded two days prior. This incident was uploaded roughly 30 minutes prior. As the delay in the discovery of the February 12th wagers, E.B.H. explained that due to the initial deactivation of the game for wagering, it did not appear in their first daily audit of offerings. Likewise, the second daily audit was conducted under the auspices that the game had remained disabled and thus was not discovered to have been activated. In regard to remedial or mitigating information, GAN has placed Boston College Eagles Women, BC, and BC Eagles on their excluded team list. E.B.H. has also reported that GAN is in the process of implementing additional access for WinBet traders to have additional control over posted offerings in the WinBet database. The intent of this is to add an ability to suspend markets or wagers earlier on. GAN reported that the measures and audits that have been in place following an earlier incident had successfully identified and excluded two BC women's basketball games on February 5th and February 9th. E.B.H. indicated that twice daily audits conducted by its trading team are still in place following this incident. Those audits are overseen by Max Berlin, manager of sports book operations of WinBet. Finally, at the time of this incident, E.B.H. disabled all wagering on NCAA women's basketball until the issue had been sufficiently remedied. Thank you. Juan Corre, do you have questions for Mr. Mercer? We do not. Thank you. Okay, thank you. I'm sure that you want to direct questions to Mr. Mercer and of course can get clarifiers from Juan Corre as well. Mr. Mercer, thank you for your presentation, commissioners. Thank you. Mr. O'Brien? Yeah, and I know I asked this when we were here on a lead violation earlier involving genius sports and uploading, but can you go over that one more time? And Zach, if this is something that needs to be deferred until when, let me know, but trying to get a sense of exactly the interplay between genius sports media, GAN, E.B.H., is there a direct contractual relationship from E.B.H. and genius or is that a sub through GAN? I could defer to E.B.H. in regard to that just to the specifics of the relationship. I was informed as to the nature of the way that these things operate down the line. However, their particular relationships I did not acquire. But genius is a currently registered sports way that is not in the same standard with the MGC, otherwise in good standing, is that correct? That is correct, to the best of my knowledge. That's correct, I can confirm that, yep. Okay. And then in terms of the, and again, this might be something I need to defer. The 30 minute, the genius upload 30 minutes prior to the game that we're at issue here, is that the same timeframe in terms of the upload that genius did on the 2-2 matter? I'm not certain I'd have to defer on that as far as the 2-2 matter. Thanks. Other questions? Mr. Mercer. Now that the commissioners all look at their notes and process this before we dismiss Mr. Mercer. Make sure we don't have any other questions for him. Sorry, Madam Chair. I had one other one. And I don't know if this might also have to be deferred, but the notification that went from EVH to Bruce Band on 2-21, there's no time stamp on that. Do you have a time for when that call went from Jackie from to Bruce? I don't have a specific time. I do know that there was a phone call between attorney from and Mr. Band. And then a follow-up email. I do not have a specific time for him as to the phone call. No. I think I believe it was in the late afternoon commissioner or Brian, Mr. Mercer. If you know this, otherwise we'll circle it back to Ms. Chrome. With respect to there were three bets placed. For the North Carolina. Game. And then. More placed. For the Louisville. Can you tell me. Now the winnings. Redeemed or they redeemed at the ticket. That's the only way they can do it. Correct. I'm not. I don't believe it's the only way I'm not 100% certain in regard to that. I believe that EVH would likely be able to shed some light on the particular, particular mechanics of that. My understanding from the IAV is investigation. I was that due to the need for the IAV, I don't believe it's the only way. I don't believe it's the only way I'm not 100% certain in regard to that. The only way I'm not sure. I believe it's the only way I'm not sure I'm not 100% certain in regard to that. The only way I'm not sure. Is based on these investigation. I was that due to the nature of these being placed in person. That the tickets were redeemed prior to any ability to cancel or anything in that regard. album replaced at Kiosks. You mean in person. In the family. No, that's okay. Because that's a distinction that that's important. That's helpful. But. We'll get clarity then on how the winnings were actually. Distributed. any other questions from Mr. Mercer? I have a similar follow-up question, Madam Chair, but I think I will wait until we hear from EVH. Okay, any further questions and Mr. Mercer will stick around so if we need to circle back to him. But at this time I think I'll turn to Ms. Crumb and if you'd like to make an opening statement otherwise we have questions for you. I think we're ready for questions. Thank you Madam Chair. Mr. O'Brien, do you want to circle back? Sure. So going back to the last question I asked, Jackie, do you have a specific time on the 221 call out to Bruce Vann? I don't. I was actually just checking my phone logs and unfortunately it doesn't go that far back. I know that I believe I sent him the email in the late afternoon so I would have called him probably shortly before then. Okay. My memory of the last time we were talking about an infraction of violation like this, there was again the reference to the 30 minute load by Genius Sports being unusual. Can you speak to how that occurred again and what if anything EVH is doing in terms of the last minute loads by the vendor Genius Sports up to Gann and then on to the Catalan? Sure and I would ask Rob from Gann to weigh in on this too but I think last time when we were speaking and Rob can obviously correct me if I'm wrong about this. But we were talking about both, I shouldn't say both, we were talking about the instances that happened here as well as the instance that happened originally. So Rob maybe you can clarify whether that last minute upload impacted both instances or the second group but not the first? Yeah it there's a lot of variables that go into when we receive the data from Genius Sports. It's actually it can vary dramatically based off of the the sport, the league, the event itself. And so I don't know if there was a specific if the 30 minute or you know kind of a short notice if you are as occurred on all the events. I know it did occur on one of the events but the earlier event I'm not sure of. All I know is that it does vary dramatically. So for example like an NFL game we may get you know the data may come in you know six like literally the before the last game ends of this week it could be six over six days in advance whereas you know an event like a women's college basketball game that's not really widely wagered on may come in very late. But certainly not more than you know and plus they play games pretty close together so they wouldn't publish another game until the prior game was at least completed. So I don't know much of the actual schedule during that time of year but for example if they had played the day before then they we certainly wouldn't that new market wouldn't come in until probably pretty late probably you know an hour or 30 minutes prior to the game starting. So it's hard to say I could probably look back at some logs to try and figure out when that occurred. If you could because the representations appear to be made and maybe there's a miscommunication but that some of this error came from this last minute 30-minute ad being a bit of an aberration but it's sounding like maybe it's not so much particularly in some of the other sports like women's sports or maybe non-mainstream odds that are coming in and so that I'd like a little more clarity on that if you can provide it. Yeah absolutely 30 minutes is definitely an average but that's not that's not common at all but it wouldn't be uncommon if it was say three or four hours that's for sure. So but yeah we can definitely clarify that. And then Madam Chair not to steal your thunder but I had the same question you had asked Mr. Mercer which is it would seem that the redemption on the 13th and the redemption of the winning ticket on the 19th had to have occurred at a cashier's window? Is that fair to say Jackie? No we're actually checking on that you can redeem tickets at the kiosks as well so we're checking on that. I would want to know how they were redeemed because if it was a redemption with a staff person at a cashier's I've got some questions about whether you know why it wasn't flagged and what if any training has been taken as a result of absolutely. Jackie I can clarify I can answer that question I have the log so the the wager on the 12th or sorry it was redeemed for the partial win that was redeemed at the cash at the sportswood counter and the second wager was redeemed at a kiosk. So the redemption on the 19th is at the kiosk? Correct and a little bit of color on that wager at the counter so that was a round robin bet which is it has a lot of different variables in it it's not as easy not as simple as you know somebody didn't make a bet on Boston College right to win or whatever it was there were several markets that were in that the ticket's a very long ticket and I could see how somebody may not look at all the individual markets that were bet on in that ticket to what's their when they're redeeming it but just that's just a little bit of color into what the ticket that was redeemed to the counter. And in terms of training Commissioner O'Brien we have already instituted training to our cashiers at the kiosk so that they are aware of what the Massachusetts schools are and to check the tickets for any Massachusetts schools and to raise that obviously prior to any payments being made. Sorry Commissioner O'Brien. The round robin I assume was all women's basketball is that correct? No it was not there was multiple sports. Was it college or was it college and non-college? I believe there was some non-college in there as well. Okay I'd be curious to see the parlay actually also. Could I just get clarity again um the round robin was the North Carolina? No that's a parlay. So it was the Louisville one that was the round robin? That was North Carolina. North Carolina. Okay so it's a round robin with multiple publics. I'm I just I'm going to turn to um I'm going to turn to my um legal team we're asking for you know this is an adjudicatory hearing so to the extent that we can get answers during the adjudicatory hearing that's ideal we did reserve the right to circle back but I just want to point out that we remain under oath um when we're getting this this information so uh not it's fine I'm just wondering how do we get when when I hear we're going to circle back I'm wondering how that's going to be arranged. I'm actually currently looking for that answer right now so I can come back during this call. Okay um otherwise we'll we'll make the arrangements through our legal staff for outstanding questions um as we you know the accordance with all we reserved. Yes chair if there's any information that isn't going to come in during the live hearing um please send it along to Todd and myself and we'll make sure it gets to the commission. All right thank you. Can we just say clarity on the Louisville game which um ticket was redeemed at the counter? I guess I'm directing that to um Mr. Lakitas. I'm sorry it was very what is the question specifically? Each of the tickets from the Louisville game was redeemed at the counter. It was um a ticket with a total wager amount of 63 dollars and a partial win amount of 53. That's the North Carolina game right? Correct. Was there a ticket redeemed at the counter for the Louisville game that's the one I'm asking about. No ma'am the ticket was redeemed the Louisville game ticket was redeemed to the kiosk. Thank you. I have some additional questions ma'am chair. Yeah I see Commissioner O'Brien too. Okay go right ahead Commissioner Skinner. Oh I if Commissioner O'Brien's not done I can I can wait. No you can ask yours and then if you didn't cover mine I'll circle back after. Okay it's just about the timing on the notification um I didn't see in the report uh when when that reported the incident the incident to EVH can someone speak to that? I can research the time as we're talking um it would have been immediately before EVH contacted um Mr. Bam. Okay well it seems that according to the report Winbet learned of the incident on 219 but Mr. Bam wasn't notified until 221. Do I have that right or am I incorrect about that? My understanding was that the nota nota the telephone notification was made earlier than the incident report the incident report uh was filed subsequent but let me track the timing on that. Well just to clarify I don't think we have an incident report I the IEB report references phone call from Ms. Crumb and an email to follow and that was the that communications to place on 221 um but if you could if if someone could just you know go over the timeline because I don't want to be putting bits and pieces together when we have the information that we can get from you directly and on the incident on sorry on the email notification to um that went on 221 that did attach a copy of the incident report as well. Okay but that's not an I don't think that's been entered as an exhibit. Okay so I so commissioners haven't seen that so if you could just walk us through the timeline again my question is when did WinBet report the incident to PBA and I'd actually like to understand the circumstances under which WinBet discovered the issue. WinBet discovered the issue through notice from the trading team so the trading team at WinBet contacted the legal compliance team myself and advised of the results of the audit and at that time we were gathering information about the wagers and and the results to file an incident report but then we would have notified Jackie of that to communicate that with the MGC so I'm just trying to track down the time but that was done and then a formal incident report would have followed after more facts were gathered to have a complete report. Okay could you also confirm when the audit was conducted as well Miss Roberts? Yes audit was conducted based upon revenue reports for the month and so it that's when the prior incidents were discovered is looking at the revenue reports for for all wagers name and that's when we discovered it and I'm just looking for a timing a timeline on when it was discovered in relation to when it was reported to EBA. Sure let me track down the time that I was notified as well as the time that's EBA and Mr. Band were notified. I'm working on that right now. Thank you I have other questions Madam Chair but I can pause to allow other commissioners to ask questions. Thank you for that Commissioner Skinner. Commissioner Brian I'm just going to check in with Commissioner Maynard and Commissioner Hill first to see if they have any questions. Not at this time Madam Chair thank you. Commissioner Maynard are you all set? Do you have a question? I just want to see if have all the wagers have dissolved and canceled at this point? Is there anything outstanding anybody that's waiting around? Nothing is outstanding they've either been lost or the wagers were losing wagers or two wagers in particular that were winners were already redeemed there's no other just wagers in the system outstanding. Commissioner Brian. So some of the questions that I have are sort of follow-ups to what Commissioner Skinner has been asking about which is trying to get the timeline together and so I'm also trying to figure out you've got an alleged violation on 212 redeemed on 213 a possibility of a violation being seen and supposedly fixed on the 15th I'm trying to understand how the 212th incident is not picked up on the 15th. Can I add to that because I had a similar question and it's really around the daily audit that is being conducted and so in light of the daily audit and so maybe we just need to understand what that process is but a similar question how is it that the daily audit didn't identify the fact that that the BC catalog had been re-enabled? So the the daily audit is conducted for all existing and prospective markets that are being published and will be will be offered to the public this was an added audit of revenue that discovered that those wagers were placed and accepted so those it the market review and the audit being formed to make sure that prohibited markets are not offered is done on a daily basis for existing and prospective wagers so they don't look at past wagers but in this case except for when they're looking at revenue reports and that's when they notice the Boston College teams were listed on those revenue reports that they were reconciling. Just to give some clarity on the timeline from what I can piece together in this all took place over President's Day weekend so Jennifer contacted me on the Monday evening of President's Day weekend so that would have been the 20th to let me know that they discovered something and to let me know that they were investigating it. I contacted Bruce Bant the following morning we weren't able to connect at that time but he did return my call later on in the afternoon. And so I guess what I'm struggling with also is you know most if not all of us were back here we're here on the 14th discussing the earlier episode and the fact that we're in the two days leading up to you have a violation and a redemption at the counter the day before you're here on the first violation and you don't pick up the violation for you know more than a week later. To follow up on Commissioner Skinner's point of the sort of the daily audit I'm not so sure that gives me any comfort if the reality is these last minute ads aren't being in any way vetted or screened for compliance. So what had happened in this case was that the wages we had understood that the issue was resolved and what we had done is specifically disabled those college wagers in the system but what had happened is that the feed provider had basically reclassified them or renamed them to what matched up to what we had disabled and what had happened is that when it hit our system it because it appeared to be a new market it was enabled because we had disabled you know Boston College Eagles not Boston College you know screaming Eagles and so it activated it shortly before the the event had taken place. Yeah it's funny. Commissioner O'Brien can I ask a follow-up please? Yeah. Ms. Roberts so you know Commissioner Skinner and O'Brien are asking you know kind of an obvious question how did it how could it have happened again. What you're saying is that you took measures to disengage and just somehow your vendor re-engaged them. It re-engaged it because of just to coordinate the names. Is that kind of what happened Ms. Roberts? Yes it what had happened and I apologize I'm on an off-site location and my Wi-Fi is a little. I saw that you froze a bit and we're just fine with that. You look beautiful when you're frozen no problem whatsoever. So yes it because what happened is that we had classified those as prohibited wagers in the system and it came through the feed and part of the reason is that this was in play so it was during game as the game was happening and so that's part of the reason for the short timeframe for launching the the event but it came it was able to get through because that particular name classification wasn't disabled because it came through again under different classification than what we had identified as prohibited. So how do you avoid that happening again? We have to work with the feed provider and and GAN to capture every potential naming convention for all of the markets. Commissioner Variety have a follow-up to that? Well I do which is the cynical person in me says someone in the third-party feed tried to upload it it got blocked they tweaked the name so they could upload something because they're under a lot of time pressure. It could be done with some nefariousness it could have been done because they were trying to get the feed out on the new game with the last minute stats and so they're not really doing it thinking that they're not supposed to be uploading it it's a prohibited conduct and a prohibited event it's more I got to get this thing out there I'm under time pressure. So that to me is absolutely something that's a conversation with the third-party feed that goes into GAN and subsequently to you but there is another stopgap which is how it actually gets into your catalog and so this idea of well I'm just going to think of every possible permutation to try to block that I have a concern that again in the scenario that I'm describing it is that someone's just trying to get it in there under pressure to get it back up and through the feed it up into the catalog they might tweak it to initials that sort of thing I'm not so sure thinking of every possible permutation is going to do that what are the other safeguards that are going to happen in addition to that that would stop this if somebody's keeps tweaking the name what's the what are the eyes that are going to look at this before it goes in that says it's a PC game you can't do that. Yeah she just froze first I can push her skin I'll turn to you next after she unfreezes it would love her unfreeze and answer and I know that you were both I could have turned to either of you for a follow-up I knew you were probably thinking along the same lines. Yeah absolutely and I'll direct my question to Attorney Crumb we talked about the was a 2-2 by Lee excuse me Commissioner Bryan referenced the 2-2 incident we held the hearing for that matter on February 14th so at least on 2-19 according to the remedial measures Encore put in place there was a twice daily audit of Massachusetts college sports offerings to confirm that no Massachusetts regular season collegiate games are offered for wagering so my question is you know why wasn't at least the 2-19 game picked up by a member of the Encore staff or at least the individual who was responsible for conducting the twice daily audits and you know could Encore have identified this issue well before it was reported by Winbet in light of the twice daily audits that he put in place in the 2-2 incident. So my understanding Rob Jennifer said she just contacted you about something did you want to respond? We have two questions going which is not ideal but what I'd like to do Ms. Roberts if you could hold with the you be responding to Commissioner O'Brien's earlier question but I'd like to have Ms. Crumb answer Commissioner Skinner's question please. So Commissioner Skinner on our part our audit is done manually so we have traded we don't have traders I shouldn't say that the traders all exist at Winbet what we have is our team scanning through the bets that are available to determine if there's anything that catches their attention unfortunately we don't have access to the automated system we are working on that but that does require a change so once we get that audited system we can do it in a more but this is just a manual someone going literally through trying to make all the different combination of bets so our system of audit is different than the system of audit that's that's done by the Winbet team. So are you saying that the manual audit did not catch it did not catch the other named variations Boston College Eagles women DC's you think those built? They did not and I can go back and check when they actually conducted those audits it may have been in a period where the game wasn't actually offered so I need to go back and check with them when they when they conducted those and I can I confirm that and provide that in writing to you. Okay because then my question is if they weren't looking for those names what what name what name what what what were they looking for? I I did have the same questions. Thank you Ms. Crumb. Okay we'll turn back to Ms. Roberts. We again if we need to reiterate the question please Commissioner O'Brien can help. Thank you Madam Chair and Commissioner O'Brien I apologize for the Wi-Fi. Oh no. Oh no. Rob are you able to answer the question that was posed by Commissioner O'Brien? Yes she is. Okay I'm going to go off camera that may help with the Wi-Fi. So we were talking about the audits that are being performed and what other safeguards there are so we had the two perspective audits so a morning audit that did not on that day that that was offered on that day they did not see that the prohibited college was not listed. By the time they conducted the second audit that event was over so even in a because it started so late the perspective audit did not capture it but for other safeguards as far as naming conventions I think you know obviously we look at the variety of names that would come through as markets being offered and to identify Boston College or Boston College events and then Gann can talk with what we do from like their system does with vet genius as far as additional safeguards. So Rob could you add in your perspective as well? Yeah so I know in the last hearing we kind of refrain from kind of tying all these together we were focusing on the events at hand which was the February 2nd incident but in reality these are the the root cause of this was all was really tied to the naming convention which we were not aware of this secondary name until after some further investigation which result which came after this February 19th event. So on February 2nd took we caught that ahead of time and we thought that at the time the reason why that market got through on February 2nd was because it was we hadn't deactivated the women's college basketball until like it was like really a day before we went live and we thought that most likely that was maybe that event had already kind of gone through the system and was already kind of published and maybe that's the reason why it got through but so what we did was we went and make sure Boston College was deactivated and and that coupled with the twice daily audits which our team and Gann were up were doing as well we were doing an audit it's a different time zone so it was we recovered we had plenty of coverage we did pick up on two events that had that were deactivated and and that was between the February 2nd and the next incident the so once we realized okay if something's wrong we we we we could see that Boston College is deactivated why is this market showing getting through to the system and getting getting published for wagering and that it wasn't until after the February 19th incident that we actually realized oh it's because there's a different name that nobody was aware of Boston College Eagles that was available that was coming through from genius into our system and ultimately to to win for for wagering so I don't know if that helps clarify it but it really is all tied together and I could add some additional color as well as that that the the feeds are multi-jurisdictional so genius doesn't just feed in specific to massachusetts they're providing feeds to systems based upon the event and it will go to jersey massachusetts you know every every state where they provide to support spending system providers and it's our you know it's windbed it's gan it's a pbh responsibility to help show that those what is prohibited for that market and that's where I would say that there was no intention to offer a market specific to mass they were offering the market specific to everybody and we did everything that we understood that we could to prevent it from coming in but it still got through because of the naming convention measures I guess I just follow up I think it is curious to me maybe somebody can explain to me the technology that's being used here that in terms of how these events are being described that the fact that the team's name is attached to the university throws off you know the system such that you know boston college eagles seemed distinctly different from boston college women's basketball you know the fact that eagles is in there i'm hoping that system catches up to uh so that you'll capture you know if it's harvard university crimson and not harvard university that that's not going to throw your system you understand what i'm saying because it seems peculiar to me that the naming conventions have to be so precise otherwise because you know so the statutory requirement that we you know are looking for 100 percent compliance measures I think I don't know if there's any follow-up questions you want to ask about the technology but what I'm hearing is that from concourse sort of their redundancy that's manual and uh gan is is um automated or technical yeah follow-up on the what commissioner uh what chair sign just time was saying is that that's the the frustration that I'm getting is those those checks are prospective it appears so you know because in theory you would have picked up the game on 12 I believe it is in the afternoon audit but it must have only been a prospective review otherwise you would have seen the bc game pop up and it would seem to me that unless and until these things are coded in a way that regardless of the colloquial name attached to the push through from the third party you know that let's say college 217 is bc and it's just blocked in massachusetts that would seem to be some technological fix but until that happens it seems that there has to be something on the receiving end for win bet to be able to have eyes on it or something that's a block because it's particularly here as the chair said this is statutory requirement so the the the checks don't seem to suffice if some of these things are coming in from a fee to happen out before the game yes so to clarify each team name has its own unique id so but uh if if it comes from our data provider genius so when genius provides us with boston college women's basketball that let's just say this team that's id one two three four five if they add eagles to it now it's one two three four six so when we go through we actually deactivate by id by that identifier now there's two ways to deactivate one is like if we for example if we completely hard coded and said boston college or let's just use for example boston university can never under any circumstances ever be waged on in the hit massachusetts from here on out unfortunately that's not the case because you could bet on boston on boston university hockey during the tournament and during the the beanpot and so there we have to have the ability to activate that or make that active make that available during certain situations so um i do want to also add that there's in addition to the audit there are some additional technical features that we've that we've been working with the wind that team on to have these markets come into their core so because wind that operates not just in massachusetts but in multiple jurisdictions the same data feed that comes in so it comes into wind that's core and then wind that activates those per by jurisdiction and so now they have the ability to activate or deactivate by jurisdiction uh whereas if i'm not mistaken and i'm maybe uh somebody from the wind that scene can can verify this but at the time i don't think that the core for wind that was actually active and we were just working off of the the massachusetts environment specifically but um kind of lumping a bunch of things together um hopefully i'm being clear but um it's it's not as easy as just saying boston college and then everything boston college is gone because there's these these unique identifier uh identifiers that are associated with each team name mr i guess oh sorry i need a follow-up mr o'Brien i guess my my response and my reaction to that is well understand it there's a statutory provision there are certain specifically enumerated exemptions and certain criteria are met so to me the better approach from a regulator's perspective is you ban b u in that circumstance unless and until you can go manually and make an exception say during the being time and so it seems like the its functions now to sort of expediency let's get through let's keep eyes on yeah maybe some get through once in a while because i'm a tweak to name as a regulator i'm not really happy with that method as opposed to what you said which is we're going to ban b u and then you can go in and say all right but now we can go into these criteria because they've been met that's my perspective yeah i i understand completely um and i just i just want to point out that obviously there were other masters as college teams playing at this time we did not take any wagers none of the other teams were published during this time so it was strictly related to a naming convention that we feel very strongly that we've resolved that problem at post february 19th now that we've identified this naming convention problem we the the systems that we had in place effectively worked to block every other masters as college team from being available for wagering and that that's that's a testament to our system and the and the win bet team and everybody auditing it i don't even think another team got through to even get to the auditing process they never even hit the system actually and i think we in terms of um remedying the situation when we did find out about it albeit later um immediately blocked women's college sports to determine what the root of the issue was so that it gave our team some time that nothing could get through uh to deal with the with the issue christian hill you uh you had had your your microphone off i did you have a follow-up and then i'll turn to christia maynard so a lot of my follow-up questions were answered um through other questions i i think what i'm struggling with here and i just want to make sure that i'm clear about this and all the dates are mushing together right now for me but my understanding is we had a naming issue early on in another situation and we were told pretty clearly it would be fixed and it wasn't and i'm trying to understand how that really happened like it was the same name i think the naming issue was this this incident that before it wasn't a naming issue it was actually just Boston College women's robbie you can correct me if i'm wrong but the naming i remember the naming was part of the issue meaning eagles eagles was yeah i i wondered um if that needs to be corrected for the record um i think we i think because we spoke about this issue at the first adjudicatory hearing um but rob correctly if i'm wrong i don't think it was a naming issue the first go around that's right we did not we did not know that it was a naming issue until after the February 19th incident we knew so the last hearing was actually following that incident so we we had known about the naming convention during the last meeting the last hearing and so yeah i mean this this is all specifically tied to that naming issue it's not if we did not know about that following the first incident commission hill i think you deserve a good follow-up question because i think your expression is one of confusion like mine but what i'm hearing today is that during the first adjudicatory hearing they may have expressed it as a naming uh as they may have conveyed to us that it was a naming convention issue but they might be trying to correct that but i'll let you ask you've asked i that's not how i remember it but i certainly can be corrected the same as me so can uh can i do a follow-up and pressure hill my follow-up is if it wasn't a naming convention can i know you've sort of stated it today can you remind me what was the problem the first time rob do you want to take this yeah i understanding go ahead yeah so um okay so the the last hearing we were i think everybody's in agreement that we were we were focusing on the issue at hand of the february second incident and in that hearing was after february 19th i don't know the exact date of the last hearing but we were asked to specifically address the february second incident the we addressed the february second incident as a naming convention issue during that the last hearing we did it was this it's the same issue as these two it's these two other incidents but we were asked not to really we were asked to save the discussing these two incidents until this hearing so uh much is that right i think i just heard you say that it was a naming issue in the first hearing did isn't that what you just said yes it's all this it's all they're all naming issue i think rob i can help clarify um when the first issue happened and commissioner thank you um this is jennifer uh when the first issue happened and we reported that we didn't know that it was the naming convention we had understood at that time when it was reported that there was this issue it somehow got through it was a computer um glitch that we had understood that it was able to get through um and it wasn't until the later incidents that we determined oh when we discovered it it was the um naming issue that caused the glitch that we had understood that resulted in the first incident during the adjudicatory hearing when we were addressing the first issue we it was the explanation was that it was the naming convention that caused the first issue and and now we're also identifying that as the cause for the subsequent issues that were reported and but at the time the incident report was filed we didn't know it was the naming convention that was the glitch or the computer issue um that when we reported it for the record the hearing was on march 14 so what you're saying is the testimony was based on experience that occurred after the incident um but at the time of the incident when you were investigating you really didn't understand the the origins of the glitch correct we understood that the feed got through the system and it was a computer related issue that the feed was able to get through we just didn't know it was as a result of the naming convention i think christian hill would you like to speak to anybody on our team to ask like bruce or anyone like that to understand what was reported at the time is that important to you or no and not at this time it isn't i'm i guess what it all comes down to is there was supposed to be some protocols put into place so that this would not continue to happen and it did and that's what i'm struggling with here and i can tell you that after february 19 protocols were put in place once we identified you know in february 12 protocols put in place which was sorry february second protocols were put in place for which was an audit and the audit is still in place february 19 after february 19 the digital protocols were put in place and since february 19 we've had two hearings about two three separate incidents but all the protocols are in place and as of february 19 um there has not been another incident thank you rob thank you madam chair i'm okay right now okay mr mainer thank you madam chair and thank you commissioner hill i was feeling like i was having deja vu all over again um can i go back to the idea that the round robin um and the idea that the wager can get lost or buried in a ticket um what's the expectation the employees who cash tickets out or settle wagers i'm sorry what's the expectation yeah are they supposed to look at the whole ticket are they supposed to look at half the ticket top the ticket bottom of the ticket no they should they should be looking at the ticket that they're cashing out okay um i remember at the last hearing i was talking about um how i asked question about how in state college teams are toggled on and off for a lack of a better charm right are there audits that go in place before they're toggled on and after they're toggled off what i'm getting to um counselor crumb is that i'm trying i'm trying to figure out this this issue of the reason at least one of the incidents wasn't caught was because the event had already taken place so is there any way to look at what's what happened for the entire day at like an end of day report right or you know is there is there any audit that goes especially i i'm really concerned about the events the college sports that go on the book and off the book right and i'm trying to figure out how does this not happen again right um any remedial measures in that place jennifer do you want to talk about how the that process works manually or up or not manually how that process is set up to toggle essentially toggle on and toggle off i mean i i know it's the disabling and enabling within the system and a lot of that takes place through um gan to notify what is prohibited in a specific jurisdiction rob do you want to talk about the how you disable markets and then if you need to re-enable them and then i can have max berlin on our side talk um about the how wind bit handles that as well yeah so there's there's really two two different ways where you you would disable or two different ways in which a market would be disabled one would be that it's actually hard coded into our system like for example you know we we operate gan provides sports book and other you know various solutions to operators outside the us where let's say political elections you can wager on where um uh that that stuff never hits the us it's it's hard coding our system it can't come in here right there's one way to deactivate that way if we did that then there would never be a situation where anybody could bet on any masters just college team whether they were in the NCAA tournament being hot or not um and and then there's another way another way to deactivate to deactivate a market and that could be that would be done in the wind bed side where for example hey i just don't want to take any more bets on this game it could be anything from a college basketball game to an NFL game and that is done simply by it's it's a toggle really you know deactivate you'll take it off the board essentially deactivate it so um now for markets that come into this from our from our system into wind that's core wind that has the ability to um enable them or disable them by market so um and make max can speak to that it and i'm not sure if the full functionality is there because we are only operating in one jurisdiction currently with wind bed but that functionality if it's not there should be there for the next jurisdiction um where they could say okay i i don't let's say the next jurisdiction doesn't allow betting on mls soccer they can deactivate it from their core so it it does come in to their system and they could say okay i want to take bets at mls in massachusetts but not mls in tennessee for example or whatever um so there's various ways of activator or deactivating um across the board you know and we did address this in the last hearing was you know um that we we we did take the action to deactivate what we thought was everything a forehand so that never actually hit wind that's back even their back office where they couldn't they couldn't they couldn't publish that event if they wanted to that's that's that's really the best way to do it that's what we've done so you know uh effectively with the exception of this one team but now since february 19th it's deactivated in that manner can you remind me was it the same and i appreciate ms roberts for helping me with the language the same naming convention for all three games that tripped you up but where's it you know different often college women's basketball boss in college eat women's eagles what were the naming conventions that seemed to be at the heart of the problem the same but three different ones two different ones and two the same one different i believe they were all boss in college eagles i just confirmed they were all boss in college eagles women thanks i was able to answer um chairwoman on your question about i believe is you the question about that round robin what events were included in that round robin um thank you it just uh there was um iowa hawkeyes basketball uh men's basketball there's men's basketball maryland women's basketball north carolina and boss in college women's basketball michigan women basketball the celtics and the the eagles and the superbowl those six events were all part of that round robin i have one more follow-up just because i want to make sure i've got my notes right can you remind me how those at the parley uh how that was paid out it was there was a so it's a round robin is a little different than a parlay yeah i i knew there was a round robin but our notes say parley there was no parley at all or before on on the on the february 19th uh event there on the third there were sorry on the february 12th event there were two parlays in one round robin robin was the partial winner the two two parlays lost okay thank you and on the february 19th event there was two parlays and two singles and those and they won they the only the single one oh okay so and then in terms of the round robin maybe it's a good question for us to ask too if it hasn't been answered does the round robin paid so um it's essentially there is uh on that round robin in particular there was there's six events but there was 63 unique one dollar bets uh associated with that and so various outcomes um determined the win amount um so in that particular round robin bet there was actually six singles 15 doubles 20 triple holds 15 four-fold six five-folds and one six four-fold like it's um happy to so and just how did you address the disqualifying event so that might be me being not not terribly swift in terms of understanding the actual mechanics of the payout that that customer was paid for that with that winning wager the whole the whole winning wager one of those six events one of the one of the six events they had wrong the they won five of the six out of that six leg round robin including the boston college game would you just repeat that last line please they won so they of the six events in that round robin yeah they lost the but they lost the super bowl bet and they won the five other wagers in that round robin including the boston college north carolina game and so they were paid they were paid for that wager that's correct that was the wager that was redeemed at the sportsbook counter for a 50 for a win amount of 53 50 and and i i believe someone had asked the question earlier regarding uh whether that bet had um just woman college games or just uh sorry just nc uh just massachusetts colleges or just women's it was a combination of a bunch of things so it was nba it would do nba okay yeah we got that list and so so um so the the individual who cashed that out went to the calendar we know that in that person walked away with wager that um we can't get back even though it was a prohibited event whatever allocation was um whatever was attributed to the bc game they were paid out for that prohibited bc sterl is shaking his head there was no way to recover that well actually that might require more digging depending on whether that person had a win rewards card and we could identify the person yeah that's kind of what i'm getting to jackie if when they're having and i think probably commissioner don't want to put word to your mouth but when an individual is going to counter to be paid we have in this case a wager that was made and there's no way to really go back if you knew the identity of the individual what would you do jackie we could actually refund the the total amount of the the bet so there would be a way to make them whole for placing the bet but uh i can't tell from the information that i have in front of me whether we whether that person used a win rewards card whether we'd be able to identify that person yet the total amount specifically tied to that one game in that round robin that was won by the customer was $12 and 37 cents um this has been a question with just a comment for me um the prohibition and statute's pretty clear so it doesn't matter if it's $12,000, $1200 or $12 but i'm not going to speak for my fellow commissioners um right uh commissioner maynard you want to do a follow-up oh i think you you actually said it really fairly one penny is against the law yeah so i was just referring to the the report provided that's why i just wanted to point that out is it actually in the report thank you um i'm going to go off uh i just want to go back to the naming convention i think the answer to your question um you asked about whether there was one naming convention convention involved with um one convention involved in all three of the games whether it was the same convention and i think the answer was yes yes i'm nodding and so i would have expected the answer to be no because is it am i correct in that february second incident um you disabled that naming convention in the system such that the wages could be placed on any other games with that naming convention do i am i misunderstanding the way the disabling process works because it it stands to reason in my mind i think if we disable that naming convention in response to the february second incident then the february 12th and 19th incident did not have happened yeah uh commissioner oh go ahead so again we did not know it was a naming convention issue until following the february 19 incident so we did not we did not make changes to the system following this february second incident because we did not know it was a naming convention on february second or february third we didn't know his naming convention issue until february after february 19th after further investigation into what we thought was resolved but was obviously not resolved and we realized oh there's a second name here that we've been getting we thought we had deactivated it and that's how that was just gonna you have a follow-up on that i'm sure i do because i think we heard something different earlier in the hearing and i it just it could be me um i i thought it was stated that and i'll leave my fellow commissioners to help me out um commissioner hill made the point um and i think one other commissioner made the point but the naming convention issue was referenced in the february second um not the february second i'm sorry the hearing march 14 on march 14 so it just helped me reconcile that so we had the hearing on march 14 um the incident occurred on two two incident occurred on two two twelve and two 19 and so after the two 19 incident that's when you realize that that the naming convention that was that play for each of those games uh was the problem that correct is that correct not correct do you not understand the question i can rephrase it i i think jennifer is going to respond to this that is correct from uh from wind bed on core's perspective and and our communications with gan is that that first incident we understood it was some computer system glitch that it got through we didn't know until after the incident um and after the february 20th incident that uh it was as a result of the naming convention so we just thought it was a glitch we thought oh i think we think you know it's not going to they address some technology that they thought prevented it came through again and we realized oh it's not a glitch that maybe we thought it's because of the naming convention the reason it was discussed in that first meeting is because we knew the reason of what caused the first incident which was also the same reason that caused the subsequent incident and commissioner skinner i also have information about the timing when you're when you'd like me to respond to that okay so before we get there i i guess so once the remedial measures were put in place after february second we're talking about one naming convention and so it seems to me that that's an easy one for the audit to have picked up or the individual is responsible for the twice daily audit to have picked up we're not talking about i don't know what the naming convention is that was involved in the three game but i mean if we're talking about i think someone said boston college equals basketball yeah that was it boston college equals so that that's easy so that if that's what you're looking for then that should have been identified during during the twice daily audit that were implemented the february second incident they weren't looking for bc they weren't looking for what are the other ones here that you have bc eagles they were looking for just that one naming convention so that i'm even all the more confused about how the two incidents these two incidents that we're dealing with today were able to have occurred so commissioner skinner this is jennifer i can when we first identified the issue the first incident we thought that there was a computer error and we didn't know it was resulting from the naming convention so we implemented a an audit system where twice daily our trading team goes through and reviews the wager the the markets that are being offered but what happened in in the subsequent cases is that you know we had disabled boston college as a market however the system was coming through as a different name and the reason we didn't catch it in the the audits is because the morning audit the game was not posted and in the later audit the game was concluded because normally you get a minimum of two or more hours for a market to happen before an event but in this case it happened 30 minutes before the event and so we weren't able to catch it in the audit because again the perspective audit didn't the timing of them didn't capture this very short term period that it was offered under the name that we believed everyone believed was disabled i hope that skinner yeah i think some clarity yeah i think there's probably a little bit of a follow-up here to encore that given that it had just happened with this exact name it just notwithstanding any computer glitch notwithstanding any manual review it just seems rather peculiar that it just got missed again but i think we're understanding at least now may have occurred at our march 14th hearing but it's the fact that it was the same name all three times makes it particularly peculiar mr skinner you do you have that sort of feeling yeah just to clarify too the twice daily audit so just to be clear the twice daily audit from february 2nd to february 19th did not include it we weren't we were not aware of the naming convention issue during that period so the audit was not of a naming convention audit it was of all masters of college names can i do a follow-up question to that pressure skinner please um when you say that it wasn't on that naming convention somehow right away and and i think jackie miss crumb i think you identified it very quickly that it was any a prohibited event that got bet on and you shut it down it was boston college eagles women that popped up right when it was basketball that's what popped up right so i think i'm struggling just as without understanding the technology involved but not exactly the same name that later tripped you up and one would think if you're doing an an kind of an audit manual they'd be looking for exactly that language that's what that that's what i'm struggling with and then commissioner skinner help me out here yeah just and just a follow-up i mean if if if that name was identified after the february 2nd incident as prohibited um it was disabled right i think i understand that it was how did it how did it get we how did it get enabled it was my uh after february 7 a named boston college eagles we did not realize that there was a boston college eagles and boston college we did not realize that there was two names until after february 19th but there was only there's only one name that we're working with in connection with all three of these games is what you've indicated so so the two names i'm not i'm struggling with the two names that you're referring to should we call the question on this at this point um do you think maybe um if there's any further clarification from either miss crumb or miss roberts to help um mr akides out jackie jennifer jennifer do you want to talk about my understanding is there was a there was wind bed hats when they went through they caught something and sent it back manually do you want to talk about that process to be lose her not sure do we have max song yeah i'm here can you hear me yes max do you want to talk about the audit and how it was done and and yeah because i think that'll clarify well wind bed trading audit um was simply us going through in the morning between 6 a.m and 8 a.m and then the evening between 7 p.m and 9 p.m pacific time and we would go through the slate of women's college basketball games for the day and ensure that we weren't seeing any boston college women games any umass women games so on but unfortunately a downside to the audit would be that we could only identify that something came through we didn't have the ability to block anything from the feed that was coming from gantt so the audit was merely a way for us to identify an issue quickly or ideally shut off a game before it was offered and obviously we weren't able to do that because the feed turned it on commissioners do you have a question from mr perlin i'm sorry did you say that those that 687 and 9 references pacific standard time yeah yeah so we would have the the morning shift sometime between 6 a.m and 8 a.m they would go through in our trading platform and look at all the college basketball games women college basketball games that have been loaded do we see boston college is it offered and then we would do the same uh during the evening as well and max during those audits you did not identify your team did not identify those games being offered we were seeing them come through and we were turning them off right this is after gan had informed us that they had disabled it after the initial incident on february 2nd so we were seeing the fixtures come through a fixture being possibly just the two teams with a date and a time and no markets and our traders were actively going in and disabling that and then we also informed gan through a shared chat channel that we have that we were seeing these games come through so mr perlin my question is the twice daily audit that you performed why didn't that that why were you not able to identify the february 12 incident so you i think you said that your audit could only identify something that came through so why wasn't that february 12 incident before february 19th i think the february i think both incidents if i'm not mistaken happened after kind of the time frame where we were checking so i think one of them came in 30 minutes before the game started which was around 8 30 or 9 am um where we wouldn't have checked we check first thing in the morning kind of the last thing at night and i think for one of the games that in play feed turned it on um so it would have been after we looked and again we would have only been able to identify that it was available in the system there was no way for us to stop it essentially once it hit the win bet trading platform but at least you would have been aware that it was something that was offered that you weren't able to stop yeah and again we saw the fixtures fixtures being just the purely the matchups coming through and we had informed gan but we were under the impression that they weren't actually being offered at any point so was the february 12th game identified by by by your team during one of the audits i believe um one of our overnight traders while looking at the day's revenue like uh i think jennifer mentioned this previously he noticed under the women's college basketball category that there was the bc eagles game um and then once he informed me i went through and did kind of a retroactive search and i saw that there were bets on an additional game as well and that was the february 19 or 20th i don't remember exactly which one was discovered first and then which one was discovered after the fact i apologize according to the timeline the 19th is discovered first which then causes a further search and unyields and i covers the 12 my suspicion on the 12th is because you're doing pacific standard time searches and it's coming in shirtwood where nine a.m eastern standard time um it it the game is essentially done by the time you guys do your to your prospective audit that game is pretty much over um i i think the games were starting nine a.m pacific from what i remember it was usually like a noon because they were weekend games um well it was a new standard time the bc usc game is going to be on east on east coast yeah yeah um but i'm sorry what was the what was the exact question i apologize no i was just i think it was it was more edification i think commissioner skinner asked was sort of flow mixes to how you didn't pick up the 12th and it seems to me that because of the timing of pacific standard time for some of these and maybe these things coming up um right before it hits the feed and it's and according to the report that we got that bet went live between at 9 48 a.m eastern standard time yeah so that i mean the audit was captured it before 7 a.m west coast time which if they hadn't started the audit it's going to it's going to miss that audit has an only perspective yeah exactly because it was turning on so late so traditionally with baseball nba nfl as rob mentioned earlier these fixtures are coming in these markets are coming in days before weeks before usually hours before in the case of these games they came in 30 minutes before possibly because um what the fee does is look for a consensus of markets from other operators and then kind of creates like an average that offering so because not too many operators do women's college basketball or offer it it's possible that the feed didn't have a consensus to actually open until extremely late before tip off um chair can i have one last question slash clarification of my own earlier question uh this mr berlin just articulated better than i did earlier my question to you miss chrome about shouldn't there be audits he said i saw it retroactively and and that's really what i'm getting at is that i know that that may be um if the event may have already occurred but i feel like had that been done earlier you wouldn't have had the later issues and that's really what i was getting at is is there something in place where retroactively people are looking to see if any illegal majors have been placed ergo to prevent any future illegal wage it may not may not prevent the conversation we're having here today happening again but it would prevent multiple events right and i think ultimately that's that's that's what ended up happening right once they discovered the one event they were able to go back retroactively and look for others um but that's uh max you said you were able to look at it proactively are you looking at retroactive comes when you mentioned there was a retroactive search as well yeah once um the overnight trader informing that one game he comes through i assumed that it was very unlikely that other markets other games hadn't come through so i went back and checked i mean i look at it as the difference in a window and a camera right if you're looking out a window you're only going to see what's happening right that second right in that window if you check the video you're going to see what happened before and i'm just trying to make sure that both ends of the spectrum are covered not just one or the other and it sounds like the answer is yes i yeah i just want to reiterate we did see these these matchups coming through we saw them coming through after february 2nd and we informed can as far as we were told they were not available for wagering and our trading team in las vegas was manually going through and disabling the fixtures in in action pressing that they wouldn't be offered max as well it wasn't just toxicology those fixtures that were coming through it was all fixtures including all masters of the college team for coming through you're and you can see the fixtures for harvard you can see the fixtures for bc i'm referring specifically to the client for massachusetts so so we saw what would be offered in massachusetts we weren't checking off the core because the assumption would be core would have all of the all the fixtures in there because it's not specific to a jurisdiction can i ask when you say you were told they were not live that's who is making that representation um you mean as far as they weren't actually being offered or they were able to be bet on yes i don't remember specifically who who again we have kind of a shared trading channel between the win bet traders and the began traders i don't recall exactly who told us do you recall if it was one individual or multiple individuals i think it was multiple i'm not i'm not entirely sure yeah from our side when we went we go through and we see you know we when we looked at okay are these markets available to be bet on we had a list of of of team names and i and associated ids with those team names that we were going through and saying looking into the system our technical team was going through looking into the system to make sure all those team id numbers that i mentioned earlier were actually deactivated and they were all deactivated the ones that we were aware of right and then it wasn't until after february 19th we realized there was this additional identification or id number associated with bus and college eagles that was slip kind of slipping through if you will um and that's why that was the only team that was getting through our call it you know the firewall if you will or the blacklist if you will to get through to the system to be about on other questions come shirt this isn't a question um it's really just a comment i think that you know i definitely need some supplemental information relative to these two incidents i just and i don't know how we get there madam chair i think commissioner skinner we could go into our deliberations and decide on what we would like to circle back to them on um as we today we've uncovered certain questions that we'll have and we'll have the benefit of our legal team working with us to to get what we need does that work for you commissioner skinner it does but i think we've heard a lot today um that i just need to sift through uh so you know i i know i i would be asking for you know some time to do that i would like the benefit of you know a review of the prior incident and and just to come up to speed and and perhaps just to just to digest the information before we undertake deliberation clear well what i'd like to do for right now is we're in the adjudicatory hearing if you don't mind i'd like to sort of wind this up appropriately then we can shift to our deliberations and decide what we want to do for the the rest of the day i think what i'd like to do is offer is there are no further questions to um any of the witnesses who have testified today offer uh on court the opportunity to do a closing statement so just very briefly in closing i think um this obviously raised some more questions for everyone and and i i understand that you do have um additional questions i think uh you know we look forward to hearing from your team and will of course provide any supplemental information that you need as soon as we can okay with that is there anything in addition that you'd like uh commissioners to ask or say we thank everybody for their time today with a mr. Mercer for your presentation uh to miss chrome um to mr. McKee's to miss uh roberts um and mr. Berlin all testified have been here thank you very much have a good rest of friday um in Boston it is beautiful so enjoy um with that said commissioners if we could just at least turn briefly to our um deliberation room that would be really helpful okay thank you so much thank you have a good afternoon