 So nice to see you. All right, Dave, you let me know when you're all set. Yep, I just said go live, so we are ready to go. Okay, good morning everyone. We are convening a meeting of the Massachusetts Gaming Commission and we're doing so virtually, which requires me to do a roll call of my fellow commissioners. Good morning, Commissioner Bryant. Good morning, I'm here. Commissioner Hill, good morning. Good morning, I'm present. Good morning, Commissioner Skinner. Good morning, Madam Chair. Good morning, everyone. I'm here. And good morning, Commissioner Maynard. Good morning, Madam Chair. I am here. Excellent, we're gonna get started. And today is November 14th. Today is public meeting number 401. We have a special meeting today. We have our round table addressing media and advertising issues. I wanna thank you, all the participants today for assisting the Massachusetts Gaming Commission in its current work to implement the new sports wagering law here in Massachusetts. As you know, we're working hard to adhere to our timeline to launch retail sports wagering at the end of January and online sports wagering at the beginning of March. To help formulate our regulatory framework, we are holding this round table of experts and stakeholders to address sports wagering, advertising and marketing across the various media markets. I'd like to now introduce each participant and then I'll circle back to each of you and ask you provide a snapshot of your background most relevant to today's discussion. So I'll do a brief hello and you can raise your hand and then we'll circle back. Good morning, American Gaming Association's senior vice president, Casey Clark. Good morning to Massachusetts Broadcasting Association's executive director, Jordan Walton. Good morning to New England Sports News, Nessan. We have two representatives here today, Sean McRail, Nessan's president and CEO. And we have, good morning. And we have Kazmita Shulman, senior vice president of broadcast and digital partnership. Good morning. And then from Major League Baseball, we have their vice president and deputy general counsel, Marquess Meeks. Quest, good morning. Good morning. And we also are very fortunate to have our outside counsel here today. We have Mina Meritless and Christina Marshall. So this is a remarkable group of the experts and stakeholders and we thank you again for participating in this critical discussion. Next, Anderson and Krieger. As I mentioned, our outside counsel will set the stage offering high level guidance on constitutional limits on restricting advertising. I welcome again partners, Mina Macarius and Christina Marshall at this time who will remain at the table today to offer their expertise and insights as the discussion unfolds. Good morning again, Mina and Christina. Oh, and actually I was gonna circle back to each already. I forgot my, anything else. Yes, thank you for the prompt. I could see it in your expression, Mina. Let's circle back to Casey if you would like to just give us our snapshot, thank you. Thank you, Madam Chair and members of the commission. It's very nice to be with you this morning to talk about this topic that's near and dear to my heart. I've spent the last five years working on behalf of the US casino gaming industry on all sorts of issues, significantly focused on areas of responsibility and research, including focusing heavily on sports betting and proliferation of legalized sports betting over that period of time and our have a game plan that responsibly public service campaign, development of our responsible marketing code for sports wagering and our engagement with partners across the board. So excited to be here to join the conversation today. Thank you. Thank you. And again to the AGA, we thank you. This is your second time you've contributed substantively to our round table discussion and we appreciate all the good work that you do. Now turning to Massachusetts Broadcasting Association effective director, Jordan Maltin. Hi, good morning, Madam Chair, members of the commission. Thank you for having me. I'm Jordan Maltin, the executive director of the Massachusetts Broadcasters Association, representing the over the air television and radio broadcasters in Massachusetts. We do a lot of advocacy work, regulatory work in Boston, on Beacon Hill and in Washington, the Capitol and with the Federal Communications Commission. And happy to be here, discussing how gaming and advertising effects our broadcasters. Thank you. Thank you. Turning now to Nessan. Good morning again, Sean and then Cosmina. Good morning and welcome to everybody on the calls. Very nice to be here. So at Nessan we oversee two, I oversee two different products, Nessan and Nessan plus both 24 hour services that are broadcast to all six New England states. And we've had a long partnership in gaming over the last 10 or 15 years, but much more actively in the last two years with the pending legislation. So as part of that, we've created cooperative relationships with the American Gaming Association as well as others and taken some very, I think proactive steps to educate our audience on gaming. But we can touch on more of that as the call goes on. But it's a pleasure to see you all and be here. Thank you. And Cosmina. Hi, I'm Cosmina Shulman. I'm the senior vice president of Nessan's broadcast partnerships and digital partnerships. And a little bit about my background, I've been in advertising sales for 10 plus years and I've actually worked with every single regional sports network throughout the country and selling their products. So that's just a little bit about me and where I come from. Excellent. Thank you. And now I'm turning to Kess. Good morning. Thank you so much. Good morning. I want to echo the comments of a few other folks that are participating in the round table and thank the commission for the opportunity to participate in this discussion. I'm Quest Meeks. Mark Quest Meeks is my full name, but I go by Quest. I work in the commissioner's office for Major League Baseball. And I'm cheaply responsible for our state government relations as well as domestic compliance. A particular interest to this group in the commission is with regard to sports betting, I oversee our internal integrity initiatives, training on those initiatives and lead our government relations efforts. And so I'm hoping that I can share some context about what we've seen in other jurisdictions, in particular on the topic that we're going to talk about today. But I also hope to share some of what we're doing as Major League Baseball to make sure that our fans who do decide to engage in sports betting do so responsibly in the first instance. And for those who need the additional help or fall into issues or problems with it, get the help that they need through organizations like NCPG. I also hope to talk about some of what we're doing that I think will focus or will highlight for the commission that we've already been focused on the topic of concern that is being thoughtful about the advertising that we expose our fans to and give some sense of the work that we and organizations like AGA and NCPG and our clubs have already done to get us down this road. So thank you again for the opportunity to participate. I look forward to the discussion. Thank you, Chris. And then now turning to the talk round of last 25. Well, thank you, Madam Commissioner and commissioners on this board. I have a background previously of working as a general manager at a television station in Las Vegas. So I'm very respond. Obviously working in that type of environment, you certainly have to know how to mitigate that minefield if you will. But I also, in that history, my tenure there in Las Vegas was worked with the NFL as the Raiders came into town. And obviously that's very sensitive as a major league sports franchise moves into a city like Las Vegas. So I was fortunate to be part of that. I have now been in Boston and a member of the Nevada broadcasters. And through my years of obviously working in radio television have been always been mindful of being a responsible broadcaster in areas and topics like this that certainly need to keen eye on. So that's kind of my history. Thank you. Thank you. Thank you. And now more appropriately, Mina and Christina, I'll turn to our outside counsel again to really give us a high level guidance on the constitutional issues that really would give us perhaps limits or restrictions or give us guardrails on what we can do as a regulatory agency with respect to advertising and marketing. Thank you. Thank you, Madam Chair. And by way of introduction for those who don't know us, my name is Mina Macarius. I am at the law firm of Anderson and Krieger here in Boston. We are outside counsel to the gaming commission. And so as the commissioners know, we've been assisting with the startup of sports wagering and the regulation of sports wagering here in the Commonwealth since the summer. And before that I've been counseled to the commission and other capacities. However, beyond our work for the commission we actually have quite a lot of experience with First Amendment and related issues that Christina will get into regarding the regulation of advertising from our work, both for public sector entities, including the commission, airports around the country and the cities and towns here in Massachusetts. And I can defer to Christina to say more about this, but Christina has also been involved in our work on behalf of several anti-tobacco groups and tobacco advertising and regulation. So this is an area of First Amendment jurisprudence we're well acquainted with. And as the chair said, our goal today is not to get into what the commission might ultimately do but as to set the stage for hearing from all of the other experts on what has been happening around the country and what you do in your individual organizations, what the guardrails are from a First Amendment perspective as well as under the Communication Decency Act. We partly for the commissioner's sake put this all as the sorts of issues that the legal team, both at A&K and internal with Todd and his staff are thinking about as we move to the regulatory phase. And Christina, I don't know if you wanna add anything to the introduction before we kick it off. No, I think you covered it all. Thank you and happy to be here this morning. So I think Mina is going to give some a general outline of what we're here to consider under the statute. And then I'll go into some of the details about the First Amendment and the CDA. Thank you. And so the Sports Wagering Act, section four, C3, gave the commission a mandate. And I hope everyone can see me. I just froze there for a second. So we're good. Oh, we're good. Okay, my computer's fight with Office Suite continues. So it has five categories of advertising, marketing and branding activities that the commission has been tasked with regulating as part of its oversight of sports wagering in Massachusetts. The first is advertisements, marketing and branding that is deceptive, false, misleading or untrue or tends to deceive or create a misleading impression directly or by ambiguity or a mission. And as Christina will get into there, there may be there's different standard of apply to that than to some of the other ones here. The second is use of unsolicited pop-up advertisements on the internet or text message directed to individuals on the self-exclusion list for those who have asked to be excluded from gaming or sports wagering. Advertising or branding that the commission deems unacceptable or disruptive to the viewer experience, that's the language of the statute at a sports event. That's actually the full language there. Advertising, marketing and branding deemed to appeal directly to a person younger than 21 years old. And finally, advertising on billboards or public signage, which fails to comply with federal state or local law. So that's the mandate to the commission as part of its oversight of sports wagering. We would obviously have to make sense of that language in the statute in light of the First Amendment, which for Massachusetts purposes is effectively that the governing law, there's not much daylight between state and federal on this. And the communication decency act. And so I'll turn it over to Christina to go through that. Thank you. Yeah, so I just wanted to give a very general overview of how the First Amendment and the case law from the Supreme Court and further down kind of applies in this situation. Obviously this is an ever-changing and ever-evolving area of law, but at the moment, restrictions on advertising qualify as commercial speech and so they're governed by the Supreme Court's decision in central Hudson, the Public Service Commission of New York, that's a 1980 case. Essentially that case says that the government may restrict commercial speech if the interest to be served by the restriction is substantial and the regulation must pass a balancing test of directly advancing the governmental interest but also not being more extensive than necessary to serve that interest. There's a doctrine called the Unconstitutional Conditions Doctrine which essentially imports that regulation on governmental statutes and regulations into what we're talking about here. So speech restrictions imposed in a government contract or permit they're subject to the same First Amendment scrutiny. So very broadly speaking, I think there's some obvious ways that this applies to the statute and the sections that Mina just outlined. Mina previewed this one, the first prong, the ban on deceptive false or misleading advertisement, that's not protected by the First Amendment because that fails the first prong of the central Hudson test. Moving on to the next sections of the statute, there is case law out there that confirms that the government has an interest in preventing things like sports wagering by minors. You can analyze that to preventing tobacco use by minors which has been a longstanding issue in front of the Supreme Court. The Supreme Court's also accepted that government has a substantial interest in reducing social costs of gambling, primarily those that stem from pathological or compulsive gambling. So that's your connection to the self-exclusion list. So essentially the commission's charge here is to design narrowly tailored regulations that specific evidence demonstrates will advance the interests at play, which sounds a lot easier than it is, which is why we're here. And then the second statute that I think is relevant to a slightly lesser degree, although it could have some very interesting implications depending on what the Supreme Court does next year is the Communications Decency Act. We also refer to this as Section 230. The statute essentially gives immunity to websites where content at issue is based on information provided by another person, and the claim is treating the website as the publisher or speaker of that information. Lately, the trend in courts has been to limit this availability. Recently, last year, the Supreme Judicial Court in Massachusetts issued a decision, Massport Authority versus Turo, which is the first case in Massachusetts too, or the highest court in Massachusetts to consider the statute. The holding in that case is not super relevant to the regulations at issue here, but it confirms that the trend is since the internet is a very, very large place with lots of potential pitfalls that to the extent that companies online are benefiting or directing or making money off of certain things that are published on their websites, there is some scrutiny applied to that by courts. This is likely to come up before the commission within the context of algorithms and third-party regulations. There is a pending case in front of the Supreme Court right now about whether the Communications Decency Act applies to a website that essentially uses algorithms to make targeted recommendations to users of that website or if it doesn't, the Supreme Court just granted cert in early October of this year. So we anticipate that that case will be heard next year with a decision issued by the Supreme Court in early June. So we will be keeping an eye on that for the commission as it applies to these regulations. So that's the general overview and I will turn this back to the chair. Thank you. Thank you. But at this juncture, before we move on, I just wanna make sure that commissioners, do you have questions for Azamina or Christina at this juncture? Okay. So thank you for the general overview. And again, as I said earlier, they're gonna stay on and be part of our discussion. Again, recognizing that they too are interested here from the experts that we've convened today. So we're gonna turn now to our roundtable discussion prompted by the framework that Mina read into the record, the law that is guiding some of our regulatory mandates. And then I've also shared with you a number of questions that we have come up with as prompts that we hope will really spark an organic conversation among you. To facilitate this virtual discussion, and it is always tricky. I encourage you to raise your hand to lean in to use the reaction emojis however you wish to straight. And I encourage my fellow commissioners to help me make sure that I include you in a timely fashion. And if I miss you somehow, please forgive me. We wanna make sure everyone is heard and it's worked in the past while so I have confidence it's gonna work out just fine. In terms of the questions, I'm also going to maybe exercise some discretion to change the order. If I see that that's going to be helpful. Commissioners, you've received the questions and questions were also posted in our public notice. So the public also has a sense of the kinds of things we're hoping to hear our experts address. So I am going to pick somebody. I went to law school a hundred years ago and we had the professors would call on someone unexpectedly. That's the only time I'll do this, I hope today. So the first question is, if you could help the commission understand the mechanics of sports wagering, advertising in the national, regional, and local media markets. And Mr. McGraw, given your role, I think you're a great person to start with instructing us on the mechanics here. So good morning again, Sean. Good morning. So thanks for the opportunity to discuss this with the panel. And I think there are a couple of thoughts here. On a national level, obviously, sports wagering has been approved in many states for a good deal of time. So on a national basis, this is occurring on a regular basis and coming into the marketplace on a regular basis. Obviously, regionally, there are different laws and applicable standards in each state, but we try to treat it a little more universally. And I think from a regional level, we've taken a very prudent approach on how to handle gaming. So before gaming was approved in Massachusetts, we actually engaged in some campaigns to educate people on gaming and also to encourage responsible gaming to an adult audience. So I mentioned earlier our partnership with the American Gaming Association. So we engaged by creating a program with them, responsible gaming programming and trying to educate an audience prior to gaming becoming legal. So whether or not it be on the network or on our website or on our direct-to-consumer service, we've done educational videos to educate the public how to responsibly gain, really sticking to a budget, keeping that place social with friends and families and colleagues, really being informed in learning how to wager and we've done a lot of educational videos on that front and then play with a very trusted source, a domestic source that you know well. So we've tried to embrace that thought process and philosophy and then we've run a number of gaming educational spots and awareness spots in some of our different feeds. For instance, in our Connecticut feed where gaming has been legal for some time, we've been running spots to educate the public on responsible gaming over the last two years and to give you a feel of scope and scale in that feed to the state of Connecticut, we've run over 4,000 spots this year alone on educating public and informing them how to responsibly gain. So on a regional level, we're treating it on a state-by-state basis and bifurcating our feeds appropriately. When Massachusetts comes online, obviously we'll enter this market in a very similar fashion and I think we've taken the same approach on our digital properties. Again, stressing education, be very careful to abide by gaming laws and regulations and setting standards on the network that minimize or avoid a lot of clutter from our gaming spots. So on our own and in collaboration with MLB, we've placed self-restrictions on how many spots can air and game. And for instance, with MLB, we will only put six spots per telecast in our overall advertising. Similar thing to with the NHL. We've self-imposed regulations on pre-game, in-game and post-game activities. And we've done this proactively before any of this was required. So I think from a regional level, we tried to be extremely responsible. I think from a national level, you'll see the national broadcasters are adhering to very similar campaigns. And again, the whole thought process is to have people be able to wager in an entertaining fashion on an adult audience. Incidentally, our audiences for our two pro-products in particular is in the 87, 88 or 9% range of plus 21. So again, we've tried to be very proactive in who we advertise to and who we educate. Thank you. Thank you for that. Just a reaction. Again, one of the things of the commission and commissioners speak up, we wonder about the overlap of national, regional and local and how the mechanics work and how they coincide. So the reaction to that, I don't know if anybody wants to raise their hand otherwise I'm happy to call. Commissioner Hill. Well, go ahead and quest because you might answer my question. Sure, well, that's a lot of pressure. I'll do my best to try to use my clairvoyance. I'm just gonna share from the perspective of Major League Baseball, we have restrictions that we put in place on sports betting advertising that apply across the board nationwide and local. We at the league level distribute those rules and guidelines to our national partners and then our clubs distribute the same guidelines to the regional sports networks who are their direct partners. And I see that Mr. Brown, you have your hand up. You might wanna build off from each other. Yeah, no, I wanna kind of piggyback off what Sean said because as a local broadcaster, Sean spoke of regional as a local broadcaster with radio and television, we are definitely local. So we are broadcasting obviously in the Boston, what we call DMA and employ obviously a lot of people in Boston and the area. But we're a commercial license. So we have to and always have been monitored by federal and we have to, our number one rule is obviously to protect the license. So anything, we're very mindful of obviously content and gaming or even alcohol or anything or even content that may appear in kids programming. So we're, and we also have limits as Quest said from the league of what we can air within our broadcast to especially our high profile sports. So for the local level, we're very, very regulated and very responsible in our approach and in our broadcast. Thank you, HEEA or Jordan, do you have a response from your perspective to what you've seen from a policy level, Jordan? Yeah, thank you, sorry. I just think it's important to note and now I'll piggyback off of Todd is the relationship that local broadcasters have with their networks is a little bit unique. And I'll take Sunday football on Boston 25, for instance that feed comes in from the Fox network and Boston 25 has little to no say for the vast majority of what comes through on that feed. They do have local avails for advertising and promos and that type of thing. But that network and affiliate relationship is a little bit unique when it comes to the advertising landscape locally. Thank you. And commissioners, do you have a question that I'm gonna ask HEEA? I do actually. So my question is, if we were putting in something that a national ad was gonna run afoul of in Massachusetts, what would happen? Maybe either Todd or Jordan could answer that, Todd? Yeah, I'm sorry, what was the question again? If we have a ragged mass that bars a particular type of advertising and it's in the feed that the network was anticipating sending the mass, what happens in that circumstance? I'm a pass through basically from Fox or any network. So I really can't, it's hard for me to kind of jump that affiliation agreement to do anything like that or to limit that. So that's probably see that happening already because there are giving messages that are taking place right now. So can I follow up with a question? I'm sorry, Gregory. So can I follow up? You asked the very question that I was going to ask, but I'll ask it I think in a different way. If we have a national commercial coming in where maybe we as regulators, for example, we put in our regs that you can have a young celebrity going after our 18 to 21 year olds, whatever the language might be. Now all of a sudden in another, I guess what I'm asking is there another jurisdiction? I can't believe that this hasn't happened in another jurisdiction where a regulation has been put into place and a national feeds coming in to a state that wouldn't adhere to the regulation. There's got to be some type of experience with that so far. And I'm concerned, I'm hearing you say that it would be allowed to come through you think. Is that true? Yes, that is true. As a, I'm kind of like a, I guess a McDonald's franchisee if you will, right? So I'm the franchisee for Fox. And so, if they want to serve Big Macs, I have to serve Big Macs. So that's just, it's their agreement with Fox's with the NFL and certainly that NFL broadcast. I think the NFL and the network is very responsible, but no, as far as the content of those ads and where they're placed, I don't as a local affiliate have the power to circumvent that. Casey, you must have some experience with this and with the American Gaming Association. Really, we're kind of looking at our second question. How do we, how do the varying state sports, wagering laws and regulations reconcile with national and regional advertising campaigns? It's a really good question and probably one that my colleagues from the sports business or the broadcast business can better detail how they manage that because as operators, we're kind of buying available inventory, right? So it's being, the standards are being set by leagues that are being adhered to by broadcasters at a national and an affiliate level and a local level. And so, and part of those standards are only being set during the course of a broadcast or a sports broadcast. And so what happens outside of the timeframe relevant to a sports, particular sports broadcasts is probably up to a different standard that the affiliates or broadcasters might be setting. But as an operator, we are looking to create opportunities to advertise our products, to bring consumers into the legal market. I mean, I think part of what you've heard from my colleagues before over and over again is that people in Massachusetts are betting on sports today and they're just doing it illegally. And so advertising does play a really important role in informing consumers, not just of the responsible gaming content, which we're seeing significant uptick and recognition for and appreciation of in great partnership with Neston and Major League Baseball and DraftKings and MGM and Delaware North and other great companies with strong Massachusetts ties who are helping carry that, could be some message and responsibility. But also how do we ensure that consumers understand what's legal and what isn't and where they can get, if they're interested in betting on sports, what they can do to get into that legal market. Mr. Hill. I hate to put quest or be specific to quest, but quest, have you not run into this within the last few years in regards to other jurisdictions that already allow for sports gaming and I'm gonna be publicly say this, I know for a fact MLB does a great job with the responsible gaming piece of this, but you must run into a situation where there's been some type of a regulation put into place that might run afoul of the jurisdictions regulations. So if I can take a step back, I think I will share some thoughts that I hope will be instructive and maybe give some context as to why we're struggling as a group to wrap our hands around the solution to this problem. I think as a start for us as a foundation, we'll set our internal guidelines for advertising and broadcast partners. And for us, that's not necessarily a floor as to what they can do. It's just we set some baseline as to what we think, but they're always gonna have to comply with the laws and rules, whether it federally or for local jurisdictions. So that's a start. I think the context I was going to share, which might be some of the reasons we're struggling to wrap our hands around the solution to this problem is, I think in most instances, and I reviewed just last night, the white paper that was put together by the commission's outside lawyers, and they have a helpful table in there where they kind of break down the regulations by jurisdictions and where different jurisdictions focus kind of on what the restrictions and prohibitions are. I think in most instances, there is significant overlap between the prohibitions put in place by other jurisdictions regulators, the self-imposed restrictions by sports leagues, like MLB or say NFL or the NBA, some of what broadcasters do on their own, which the other panelists around table have been a member was talking about. And so there's overlap. So we usually don't have those sorts of problems. And I'm talking about things like some of the prohibitions are, you obviously can't do advertising that targets minors, right? Like you obviously can't do advertising that targets folks who are high-risk groups, like folks who put themselves on a self-exclusion list. So in those instances, you're not dealing with a scenario where one jurisdiction may be more permissive than another jurisdiction, and then you're trying to reconcile. I think some of the difficulty we're having as we try to be helpful to the commission with the statutory guidance you've received is I think it's that piece that talks about the commission putting in place regulations for any advertising they deem unacceptable or disruptive to the viewer experience at a sport event. Based on our internal research, and we looked after the statute was passed, there is no other state that has language that puts that sort of burden on the regulator. And so I think it puts the commission in a tough spot of trying to figure out exactly what that means. And I think that's the particular statutory language that would make it difficult or the situation would arise whereby the commission might say, we deem to be disruptive to the sporting experience, exactly the hypothetical that was posed, using someone who is a teen celebrity as part of your advertising, and that wouldn't necessarily, in all other jurisdictions, fall under the prohibitions that have been outlined. And so I think that's some of the difficulty, but otherwise, in what other jurisdictions prohibit, I think we've all been pretty aligned because everybody agrees you shouldn't be targeting minors, you shouldn't be targeting folks who are high-risk or otherwise on self-exclusion lists and things like that. Very helpful. Just one correction, because I do wanna give our research and responsible gaming division credit, the white paper was actually done by them and not our outside counsel. So Mark Gandalin, our director, who's widely known and respected his team as we talk about that. Second, on that provision, and I don't know if this is helpful to the commission, so the language isn't necessarily entirely clear, but it does suggest any form of advertising marketing or branding with the commission themes, unacceptable or disruptive to the viewer experience at a sports event. So as opposed to a viewer watching TV, so it seems a little bit, from my perspective, more restrictive than generally disruptive, which might be helpful to us. Not at all pressure the lawyer here, so I don't know what you're thinking about that. Well, Madam Chair, if I could share some thoughts on that. I think the way that you're thinking about it is aligned with the way that we're thinking about it and we think consistent with the spirit of the statute and the legislative history. We actually read it to kind of limit the purview of the commission's regulatory authority to those in-venue advertisements and in fact, the bill language before what was ultimately passed did contemplate an included language to say, viewers remotely watching or otherwise listening to the experience, and that was not put in the final statute. So then they honed it in to be in-venue. So we view it and read it the exact same way that you do, Madam Chair. I only speak for my opinion right now. I haven't been persuaded by my fellow commissioners yet, of course. Thank you. So just to build on really the reconciling of that tension, is there anything else that we wanted to add to that discussion? As Meena, I don't know if you've seen it in your advertising world. I'll turn to you, make sure that you can pass or contribute. I don't want to put any on the spot. No, that's fine. I think in talking to other regional sports networks where this is already live, because the leagues have done such a great job in regulating this themselves and being really mindful of the restrictions that are put in place, not only the 30-second commercial units, but also the integration of features and how we speak to the audience that way. I think that it makes it a little bit, quote-unquote, easier, because the leagues have kind of already taken some of this stuff into consideration for us. So, as Quetz was talking about, some of the limitations they've already put on in the MLB, the NBA, NHL, and NFL have very similar regulations and restrictions. So, that's my perspective in just talking to some other regional sports networks. Thank you. Can I just ask one more question of Cosmeena? And you might be able to answer this and you might not be able to answer this. So, you get a national commercial command. We've passed a lot of regulation that may or may not allow one of those commercials to come through. You can't replace that commercial with a local commercial. Is that accurate? So, we actually don't have the same affiliation that Fox 25 does. So, that's actually a better question for Fox 25 than it is for us who is regional. They have the local and the national affiliation. We have different affiliations. Todd. Yeah, no, I do not have the ability to run my broadcast chain or the right to run over the top of what Fox broadcast. So, I'm really kind of a conduit, really, of like on Sunnys NFL game, it airs locally on Boss 25. I'm just a conduit of that game. I do have local avails, which I do control and I have controlled that content. But for the most part, no, I don't have the ability to regionalize or go over the top of any type of network programming. Which also includes commercial. I'm gonna turn next to Casey and then Sean. Casey. Yeah, I appreciate it. I think what I just wanted to add that the thing that we're hearing kind of repeatedly from my fellow panelists here is that we're all working together on setting standards proactively and voluntarily. And so the gaming industry was very front footed on that in 2019 when we put together our responsible marketing code for sports wagering and anticipation of some of these kinds of questions so that we were as an industry being thoughtful and considerate of what might come down the pike. So, our code prohibits things like targeting vulnerable populations and minors. So all the things that Quest was talking about and the things you're hearing from our broadcast partners as well is really, we talk very often about the sports betting ecosystem and all of us working together to make sure that we're getting this right. And I think you're seeing that really front and center on this issue particularly. Thank you. And Sean? Yes, I'm just gonna really echo that sentiment but I think with a slight derivation. So most of the regulations we see are not quite that granular. They're at a higher level. And again, I won't go through those categories again but it makes them fairly ubiquitous across different platforms. Now, being a regional network, we are in complete control of our advertising. So we would be able to respond to something like that on a state-by-state basis. And we do currently. So if there's a question about any spot that's about to air on NASA, it's flagged by our traffic group. It comes to me directly, not to the ad sales team so that we have a chance at a different level to review it. And we usually turn it right to our council for them to review it. So we do have a fairly robust process in place and not being a network affiliate. We probably have a little bit more control as a matter of fact, a lot more control over what airs on NASA. Thank you. Commissioners, that starts to help us understand the difference in the two markets. We don't have a national representative today, not because we didn't come to try but there may be some feedback. There may be representatives listening. We make this feedback once our round table concludes and we invite that from any visitor. Now, Sean, your hand is still up if you wanna add in. Okay. Sorry, I just didn't take my hand. I'll do it now. Okay, great. I just wanted to have another thought. I didn't wanna miss the opportunity for follow up quest. Go right ahead. Yes, Madam Chair, considering my comments and the particular question from the commissioner, I'd be absolutely remiss if I didn't highlight this from our own internal guidelines. We actually as part of our key messaging requirements do not permit advertising or ads that feature folks who are not of an adult age or old enough to vet. So kind of just back to that point of the reason I think we're struggling to find the answer for the hypothetical is we as sport leagues have tried to be really thoughtful about the restrictions we put in place. And as I think you've heard probably repeatedly at this point, we're working in collaboration with industry leaders and experts like the AGA, our broadcast partners and everybody's layering on top of everybody else's efforts to the point where we not only have the belt, we have the suspenders and we've taken a bit of extra string and rope to tighten it up as well because we all wanna avoid this potential problems that can come from not being as careful and thoughtful. Great. Commissioner's on this topic. All questions, commissioner Skinner, commissioner Maynard. Anything, would you like to ask commissioner Maynard? I would ask quest to your point, does that include athletes who are under 21 because I know that in the MLB and the NBA, there are multiple athletes that are under 21 would they not be in advertisement? So it's a fair question. I'll try to be thoughtful and as transparent and candid as I can to highlight the potential concern that would give me pause. So the way our requirements are written currently is flat out. You cannot use folks who are of betting age. The issue that gives me pause and I wanna be thoughtful about and I just can't really don't know the answer to you right now is as has been shared publicly in our most recently negotiated collective bargaining agreement with the Major League Players Association, players have certain rights to negotiate deals with sports books. We have not yet dealt with the issue where we have a player who is under betting age who's negotiated a deal with a sports book and then thereby wants to do advertising. Myself as well as a small group of other folks in the commissioner's office grapple with those issues and make recommendations. So I don't have an answer for you today because we've not been presented with that issue, but I can tell you the way that we lean is consistent with what you've already seen or we've already talked about in terms of trying to be on the front edge of avoiding these sorts of problems. And if we are confronted with that issue, we will certainly be thoughtful and I think lean towards the perspective of we need to keep in mind that this person is of the age where the demographic that follows them and is part of their fandom is probably going to be lower in age. So to kind of wrap it up succinctly, we've not dealt with the issue yet, but we continue to, especially in the sports betting category, lean on the side of being thoughtful to make sure everybody's gaming responsibly. We're not permitting advertising to folks who shouldn't be advertised too. And so when we do confront that issue, if we do, we'll keep all those things in mind. I appreciate that. And I will likewise keep in mind that there could be a situation where the athlete has made a contract. Yeah. It's a really hard position. So I appreciate that. Yeah, and I guess I would, the last thought I'll share and kind of to close out my thinking on it is, unless and until we make a change to our rules to permit it, even if that athlete who might be underage makes that deal, the sort that they would not be permitted to be featured in advertising. So we would have to make a special change to our rules to do it and we would only do so after a lot of consideration and talk internally. Thank you. Commissioner, any other questions? You can always, you can go back to earlier points of course at any point in time. We're going to turn them to the next bullet in the, I would say Commissioner Hill and I, Commissioner Hill came on September, just over a year ago, and he and I are football fans. So we're watching the NFL and suddenly dawned on us, sports wagering wasn't allowed, but we were seeing enough, a lot of ads. And so Commissioner Hill raised it at a public meeting and that's when we really turned to looking more closely at advertising with respect to gambling generally and then with respect to sports wagering because we had always committed to preparing for possibility of sports wagering being legalized in Massachusetts. And I think pretty quickly, we had a consensus on the commission that we were concerned about what we described as the frequency and intensity of sports wagering ads and how do we address marketing saturation? I have a real fear that we will be inundated once we stand up sports wagering in a way that Massachusetts may not be prepared. We've seen some of this in the cannabis industry. I suspect sports wagering might even be more intense. And so Sean, you did touch on some of your policies around what I thought I understood correctly. I want to give you the chance to explain it because I want to make sure I didn't misunderstand but in terms of giving some limits on the number of spots. But how are you seeing one whether I understand advertising is or how you, your business model but how are you reconciling the issue around saturation? If at all in your words. So may I turn to you again, John? Or is it John yet? Thank you. Sure. Not at all. So I think a couple of thoughts on that. I mean, obviously, as we touched on earlier the leagues are very cognizant of this. The broadcast partners are very cognizant. I do think there was a time maybe five to 10 years ago that that would have been more of a concern than it is today when some of the initial gaming platforms came online and it was a good deal of saturation especially on national broadcasts. And I think the industry responded very proactively. MLB, the NHL, the NFL have all come forward with their own self-policing regulations and basically were collaboratively with the broadcast partners to make sure that those are reasonable and enforceable. So I think we've tried to be very proactive in this front. And again, as I mentioned, for instance in a three and a half hour Red Sox game you would only see up to six spots in that game. So a very small portion of the inventory would be permitted in game. So, you know, overall, I think it's a lesson learned from years ago about the saturation. And frankly, we've seen it in other categories too. We've seen it in the airline industry where certain airlines would like to buy out inventory and heavy up and it became a distraction. So we're very cognizant of our audience and we spent a great deal of time thinking about what's the impact on the audience and exactly how is this affecting the broadcast in our overall performance and brand. And I think that's central to every broadcast or stock process in every league stock process. So I think it's led to some of the very responsible guidelines that have been created to deal with those potential issues at a very high level. Thank you. And of course, I mentioned in 10.07 be so much on broadcasting. We see it more on billboard advertising. Quest, do you have your hand up or is that yes or is that come left over? My apologies. I'm appreciating it doesn't automatically clear. So let me undo that. My apologies. No, but it did. Commissioner Hill, you have a question. Before I ask my question, I certainly want to hear from our other experts, but I do have a question at the end. Oh, okay. So we'll circle. Who would like to respond next on the saturation issue? Jordan, from your perspective on policy, how do you work with your other members of your association? Sure. I'll say a couple of things. First, most, if not all broadcasters have internal rules as to how many spots for an industry and advertiser can enter next to each other or within a stop set, which is a set of commercials or within an hour or a period of time. And I would hazard to guess that most of our broadcasters would continue to follow their internal rules so that you don't have an MGM, DraftKings and a Fandall spot running back to back. And that leads me to my second point. We do that because our broadcasters are beholden to their listeners and viewers. And to annoy a viewer or a listener to the point where they change the channel is exactly the opposite of what our broadcasters want to do. So it's a balancing act that they each go through, but it's an important one because changing the channel or changing the station is not the goal of broadcasters for sure. Very helpful. Tom? Yeah, and just like Jordan was saying, I'll take it one step further and also is what on the backside of what Sean was saying. But yeah, it's especially on high profile sports broadcast that we have as an affiliation with Fox or CBS, NBC. We're kind of not only we do self-impose and we also are very aware of what we're hearing in games, but we're kind of the bottom of the funnel because the network obviously has their regulations on that which comes down as well as the league. So we only have really a few of Vales that we can in game and then very few of Vales we've been regulated to only do X amount of in game and then pre and post. So you won't see an oversaturation in high profile sports events on local broadcasters. Thank you. I'm happy to share a few thoughts as well, Madam Chair. I think probably one thing I've heard from a number of other folks that I think is a key point is that idea of balance. And so for Major League Baseball's perspective, it is all about trying to strike a balance to increase the opportunity for fan engagement for our fans who are of betting age and are interested in doing so responsibly. And then also making sure that there isn't so much saturation of sports betting advertising or exposure to it that it turns off those fans who are not interested in betting. Well, we walk completely the family friendly environment and don't wanna be inundated with ads. And so to achieve that goal and to make sure we're striking that balance, we've talked a bit about the restrictions we put in place in terms of the advertising that we permit. So just highlighting some of it. We have what we call our game window which includes pre game, the game and post game. And so it's limited to 10 spots total across that. The pre and post can only be four. And then as you've heard from other folks on the round table, during the actual game, there can be no more than six ads. We don't permit more than one 30 second spot per ad break. But we do permit to kind of use the carrot approach to additional 30 second spots if they are responsible gaming messaging. And so very much so, and this has been, we've had a great collaborative effort with our partners at the AGA. We want to as much as we can for our fans who are interested in sports betting and we can use it as an opportunity to increase fan engagement with them. We wanna keep them in the part of the sports betting funnel that is responsible game, right? And so those are some of the ways that we put those restrictions in place but I do wanna echo again what we've heard from a few other folks on the round table, two thoughts. One, I do think that the sports betting operators and I guess I shouldn't say I think I know because I've had conversations with high level folks in some of the leading operators. They've heard the concern from not just regulators in Massachusetts but across and other jurisdictions. And so they responded accordingly. And that also is in the mind of the leagues when we set our kind of year to year benchmarks and we talk about these things in our off season. The second thing that I would highlight again is or perhaps hasn't been highlighted today is, some of the balance that we're trying to strike in particular as Major League Baseball is. Obviously we want to make sure we're giving our commercial partners fair benefit of the economic exchange that we're engaged in. But more importantly in the way that we think about it is the goal here with legalizing sports betting and putting it into a regulatory space and what flows from that is all this transparency that we cannot get in the illegal market is. We have to permit enough advertising so that the legalized regulated sports books can draw customers away from that illegal market. And to put like an extra fine point on that, I did not share this at the outset, but not only do I oversee state government relations with regard to all topics with sports betting in particular for the commissioner's office and our internal integrity policies, I also am the person responsible for leading our investigations anytime there's an allegation of wrongdoing by baseball personnel. And I can tell you without limitation that the illegal offshore sites like Povada and the others, they're not responding to my email when I try to get information to conduct our investigations and put us in position to levy punishment or to make sure that people are being compliant with our rules. We only get that from the legalized license sports book partners. And so we have tried again to strike that balance to make sure that those entities and companies have as much of an opportunity to draw customers away from that illegal market. So Mary, can I ask a follow up question? Yes. When you talked about sort of the no more than six and more than 130 within an ad break, but that there's sort of an unless that goes with that in terms of when they roll in a responsible gaming message. Could you be a little more specific about what qualifies as the responsible gaming message that would then get them the additional time? Is it just putting a phone number up, a tagline at the end? Like how much do they have to put in that extra space? Yeah, so we don't have hard parameters written out at this time that, you know, it was like, look, this is what it is because this is a carrot and an exception. And it is to be clear, it would not permit them to go more than 130 second spot during an ad break. Those two additional would be, okay, in this game window, you can get two more if they're responsible gaming messages. But we are still at the point and I don't know that this will ever change. We're still at the point in this process because it is still very new that we at the league level are very hands on in this. And so for broadcast partners or clubs working with their own broadcast partners who wanna take advantage of those two additional, we are likely taking a look at those responsible gaming messages. So I think you can feel rest assured that nobody's getting by easy and saying, well, we put in small print in the lower right hand corner a number for responsible gaming. So that's gonna give us two more opportunities. And how is that vetted? Just out of curiosity, if I come in and I have two more I wanna put in, how would that be reviewed by you guys? Yeah, so it flows up to the league office and I think there's myself and four other folks who span across. So I'm in sports betting kind of compliance integrity side. They're sports betting business side folks who deal with it. And then also folks on our legal team who not only review these matters but everything in the gambit of deals in the sports betting space. We are very much keeping our hands tight on the reins in the space because we appreciate the opportunity for the sort of concerns we've been discussing today. Thank you. I see. Thank you, Chair. I think it's important that, you know, one, I'm glad that I don't even need to be here because we've got quest on message. It's really indicative of how closely we are all working together to ensure that this gets done the right way. And so I joke, but it is critically important to ensuring that consumers are getting the right kind of protections that only exist in the legal market that we're all working together to the commissioner's question just now about responsible gaming content every ad that comes out from an operator in the United States should include a responsible gaming message and does include access to helpline resources or problem gambling resources. And so there are kind of two factors there that are really important and are ubiquitous across all industry marketing and advertising content related to activations on sports betting. And we've been very close on our research to understanding consumer trends and sentiment about these things and more than 90% of last year sports betters are familiar with RG tools. 51% saw more RG content over the last year than the year before. And so advertising is playing a really important role in getting that content into better's hands so that they can be more informed if they choose to, you know, enhance their entertainment experience the way that we've been talking about. Excellent, thank you. Michelle Hill, you took your hand down. I wasn't forgetting you, but you had, how can I help? I still wanna make sure that we're hearing from our professionals before I ask my question. Okay. It looks like right now everyone wants to hear your question. So I'm pleasantly surprised from what I'm hearing in regards to this issue. And it was a big issue. We laugh about it a year later, but it was during the World Series. It was during the NFL games that we just kept seeing these ads coming up over and over and over. And they were not only commercials but you're looking down on the floor of a basketball game and seeing a particular company with their ads going across of the floor. And now I've noticed the NHL going around the rink. They now have little commercials that in game you can see them flying around. I always think it's a puck, but it's not. It's an ad that they're trying to put in. But I'm pleasantly surprised. I believe if I'm hearing this correctly certainly from our local companies, Boston 25 and Nessun in the case of Boston 25, you only have so many ads you can actually put in locally anyways. I think I heard you say that. And then in Nessun, you actually control the amount of locals and you wouldn't see three companies right in a row. The concern that I have and here's the question or comment is we could potentially have up to 15 companies doing business here in Massachusetts. And I would think they would all want to do some form of advertising, not only in TV but in radio and things of that sort. But I think I'm hearing that one, you would never do three in a row, four in a row. But more importantly, you may not even have the space to do that if given the opportunity. Is that an accurate statement? Can I see Sean has his hand up? Maybe you wanna respond to commissioner Hill's question as well or hold Sean? Sure, I'd be happy to jump in. It's a great question. And I think again, we defer back to a couple of things legal certainly, and then our audience secondly. So right now we've made an active decision to only offer inventory to four different gaming operators inside our pro broadcast. We've done that again very proactively without finding other reasons to do it. So, and we're obviously breaking it up into different commercial pods so that we're not creating overload on any one piece of inventory or any one break in the game. Of course, in high stakes games, everyone would love to be in the top of the ninth or middle of the ninth. We don't break it up that way. We're doing it evenly throughout the broadcast. And I think one other point, I mentioned it earlier on. We've already run over 4,000 responsible gaming spots in our Connecticut feed this year. And unless we're completely sold out, we're making a point of running a responsible gaming spot inside every one of our pro broadcasts both NHL and MLB in collegiate. So we've been very proactive, I think on this front, well in front of the legislation. You'll also find on our digital sites, again, educational videos, you'll find responsible gaming videos and you'll also find videos about if you need help to a vulnerable audience, how to get that help. So I think it's in everyone's best interest to make sure that this goes well at every point in the chain from the league level all the way down to the local broadcasters. And I think all of them have taken this very seriously. I would just add, I would applaud Nelson. I've seen those commercials and I've seen those videos. I actually reached out to the chair one night and said, take a look, I actually videoed it because I was very impressed with what you folks have been doing and I believe I'm not mistaken. That was in partnership with the AGA Casey. And I know you would, Casey had spoken to us or your group had about a month or two ago that this was happening and to see it happen locally was kind of cool actually. So I applaud you because it's being done very, very well. Thank you. Sorry, I would just like to add one thing as the salesperson on the call, we would never take all 15 and as Sean said, like we're limiting it right now to four, but even if you take it a step further, our inventory wouldn't even allow us to take, we don't even have that much available inventory at this point in time, like we're a hundred percent sold out right now in the burn today. So like we don't even have that type of inventory to offer to these sports operators. So I think that's a really important point. We are like the number one programming most nights on crime times. So like we already have a massive amount of inventory that we're trying to manage without even gaming being live. Also, Mr. Hill too, as a local broadcaster, I know what we'll be doing and I can't speak for all broadcasters, but I know once that the gaming is online, we'll be certainly doing news stories around responsible gaming besides running commercials like Sean was talking about. So that's just one other component that we'll be doing on the local broadcasters. And I know probably Jordan will probably recommend that as well to other constituents. Yeah, music to mark the end of the years. Yes. Yeah, I'll just jump in quickly and piggyback on what Todd said. I reached out to our television broadcasters specifically at the end of last week and put together a quick overview of the amount of news that our local TV stations are doing each week. And that it's just short of 500 hours worth of news. So there's going to be plenty of opportunity, I think, to have that responsible gaming message in those newscasts. It's going to be something that's top of mind, I think for a lot of viewers. And I think that Todd's sentiments are not are going to align with most of our television broadcasters, if not all of them when it comes to news coverage. Excellent. Thank you, Jordan. Dr. DeQuest and then Casey. Thank you, Madam Chair. And I just wanted to be responsive to Commissioner Hill's concerns, which I appreciate or probably shared by a number of commissioners. I want to state that at the outset, because I appreciate you're watching your local sports teams and you're seeing kind of what new and creative ways for sports book operators to be able to advertise. I want to reiterate the point that I made earlier, which is I think, and I obviously can't speak for NHL, but I know from the government relations work where I interact with my counterparts at other leagues, we all have in mind this idea of trying to shift as many consumers and our fans and your constituents away from the illegal market. I do also just want to layer on top of that though. I talked before about the restrictions we have in place, and those are with regard to broadcast and radio. But even when you do see in venue or you're watching the broadcast and you see something in a baseball stadium that is advertising, I want you all to know that that is not haphazard. We also have in venue restrictions in place. So we are very clear about where our local, our clubs are able to permit that advertising in venue and there are restrictions in those spaces as well. And it's all been an effort to be thoughtful about what fans are going to get exposure to, what you can see in stadium when you're watching the broadcast, even what our players are going to be able to see and not putting excess pressure or stress on them. And so that's really the point I want to make is that we have tried as best we can, starting just from our internal perspective to be as thoughtful as we can and try to preempt any sort of issues. And we've layered on top of that then going outside of MLB and collaborative with organizations like AGA, NCPG, and at least at a high level in terms of talking about the policy concerns, talking with our other league counterparts about ways in which we can be thoughtful in this space. Thank you, Chris. Casey? Again, I'll just echo my friend Quest's comments. I think we need to not lose sight of the fact that the illegal market has had a multi-decade long head start in attracting consumers into a marketplace where there are no consumer protections, there are no responsible gaming provisions, there's no focus on consumer education, there's none of the collaborative work that we're all doing to ensure that our content is being focused entirely on people of age and not particularly vulnerable populations. And so I think we need to make sure that there's a critical role for regulators at all at the state level and the federal level to make sure that we don't allow this illegal market to continue their unfettered access to betters in Massachusetts and advertising and marketing plays an important role in helping to educate those consumers, not just of where they can bet legally, but also how to do that responsibly. And that's what we've been doing collaboratively with our partners, everyone on this call, and 30 more partners across the ecosystem with our Habit Game Plan Bet Responsibly campaign, which Commissioner Hill saw. So I'm enthusiastic about where we're headed and we built that campaign intentionally so that we'd all be kind of rowing the boat in the same direction to ensure that we have an informed consumer base should they choose to engage in this sort of activity. And so we're seeing real traction there. Okay, so that's such an important point. We do, and we try to remind those who want to bet in Massachusetts that we're standing up the industry and we're doing so thoughtfully and as swiftly as we can do so thoughtfully that if they're placing bets right now, they don't have those protections. So, and that's why we're working hard to get those protections in place. So thank you. Other comments on this line of questioning. A&K, I'm going to not ask you affirmatively, but I know you'll weigh in if you wish at any point in time. We really have started to address the RG, integration of RG tools into your work. I know that we were lucky enough to have a very, very productive conversation with responsible gaming experts that Mark Vanderman and help us lead. And we had representation from AGA there, as well as the National Council on Problem Gambling and others, it was very informative. But we knew that this piece was missing in terms of how the media market and the leagues work on responsible gaming. Are there innovations that you have seen on our leagues? For instance, we have major league baseball. Do you work with the other leagues and think about collaborations where you can use consistent tools or approaches? Is that anything in the works? And then I'll ask my fellow commissioners to also ask their questions that are drilling down a little bit more on the general conversation that you've had about responsible gaming so far. I'll turn to Quest. Thank you, Madam Chair. I think two things I want to share up front is, as you've probably heard from me responding to a few other comments or questions, we are always making an effort to try to step ahead of problems and to try to see around the corner. And so we want to be very thoughtful in this space in what we do in terms of partnerships with particular sports betting companies, what sort of advertising we permit during our broadcast in stadium. And then I want to repeat again, because I don't think I can say it enough or you guys can hear it enough from a sports league because I know this perspective is shared from other sports leagues. That when we think about sports betting as a tool to increase fan engagement across the different sports, everybody, everybody has interest. I think everybody sitting on this round table, I know from all of the sports leagues, this is a space where I feel comfortable speaking for everyone. We want to keep everyone at the part of the funnel where they are responsibly gaming. So if they choose to do so, if they have the interest, stay in the responsible gaming space and we're going to do everything we can to keep them there. With that said, we appreciate that there are going to be folks who run into trouble. And so MLB was actually the first major sports league to join NCPG as a partner. At this point, we are not only a Platinum member of NCPG, but we've joined their leadership circle. We also just announced in September that we have partnered with AGA on their have a game plan that responsibly. And to put a little more meat on that bone, what that means is we're not only collaborating with the AGA to find ways for us as MLB to push that responsible gaming message to our fans. We're also going to figure out how to funnel those resources to our clubs who have their own individual partnerships with sports books or working with their own broadcast partners. So we're in constant conversation to figure that out. To kind of go to the direct call of your question, Madam Chair. Yes, there are conversations that are happening amongst the sports leagues. It has been probably for the better part of more than a year where myself included in other folks who not just, you know, on my team who focus on and deal with the integrity investigative issues that center around sports betting. I think it's really important to note that it's also folks from our business side, right? Who have a built in invested interest in making sure that responsible gaming remains the way that we are pushing up for our fans to do gaming. And so we've had several conversations with different leagues. I think part of the difficulty is we're trying to find, we're trying to find a way that we can operate in this space and be collaborative and maybe figure out something across the board that doesn't run afoul of legal limitations on us in the commercial space in terms of what we can and can't do overlapping. But also just candidly having to appreciate that the game window for a baseball game is a different size than the game window for an NBA game. And so it can't be one size fits all, but I think what we can agree that is a central focus point for all of us is what I started with is that we wanna make sure that our fans that are interested in gaming do so responsibly. So yes, we are having those conversations and we're trying to figure out a way that we can hone in and be consistent. And I think one way that we've done that is that we've all kind of taken that focal point of we really want it to be in the space of responsible gaming if our fans choose to do so. Others wishing to respond to any responsible gaming tool that you haven't mentioned today that's maybe more nuanced that you'd love to share with us. How are you leaning in? I can't tell. No? Okay. All right. Casey, I know that your organization has been and it's clear today that has been an impetus or so much of the progress here. And for that, we thank the American Gaming Association. Is there anything that you can share with us that's new and different that's happening and other jurisdictions that we should be considering as we think about our responsible gaming regulations in this context? I appreciate your kind words. And really it's our members who are such strong advocates for their customers and for this marketplace that and really a testament to the work that they're doing every day to make sure that they're building lasting and meaningful relationships with customers in a way that they would want to be engaged. And so it's an important and great job to have to be their advocate on this issue. I think there isn't always a technological solution to some of you. There isn't a widget that we might be able to turn on and turn off that would just solve for some of the concerns. But I do think that we've hit on a lot of the themes today. One is collaboration. Looking at everyone who's involved in this ecosystem as equal partners and ensuring that the consumers are well protected and well informed. We have that opportunity with our partnerships with the leagues and the broadcasters and our operators administering to our own standards which we set very, it's a high standard and a foundational effort for not just sports betting but for gaming in the United States for decades. And so we're really applying standards that sets the American gambling industry apart from our global counterparts and credit to Mark and Long. His team have been really great partners in thinking through this and helping to advance these core priorities. So it's been really interesting for us to think about advertising and marketing particularly because as an asset for advancing responsible gaming it's not just about customer acquisition but it's an important opportunity for us to get the message to core audiences. And so looking at advertising not just as a monetary or commercial opportunity but as an opportunity to advance RG is really critical. I don't think advertising and responsible gaming are mutually exclusive. I think they're actually really beneficial. And so the opportunity to work together with the commission with other partners across the ecosystem to advance core issues that we all understand and appreciate has been a real important opportunity to get this message and to get the legal market into the right people's hands. Excellent. Commissioners, questions before we turn to what I know is a topic that all of us share. It's been touched on by, I wanna make sure we've asked our nuanced questions around minors. Commissioner Bryan, you might have a more nuanced question you wanna ask around minors and I know Commissioner Maynard you've asked an important one already but in any of the other question around RG generally looks like we're all set. So Commissioner Bryan, do you want to address any particular question around the issue around advertising and minors that we haven't touched on yet? I guess the only area that I'm curious about but I'm not so sure that the members today I'm probably not putting them on the spot if I ask them this question but I think a lot of the advertising particularly mine we're gonna be seeing is gonna be online and it's gonna be popping up that way as opposed to sort of the traditional broadcasting of a sporting event and the controls that are in place there which I'm glad to hear about. I didn't know the detail of it and I'm glad to hear how proactive the leaks are being but if anybody can speak to trends, mechanisms, RG in that forum where you might have people under the age of 21 getting bombarded with things online and on mobile as opposed to traditional TV radio. Does anybody want to speak to the digital of the online marketing? You have experience in that, Sean? No, okay, Casey? Chair, I'm happy to weigh in a little bit but I appreciate the caution, Commissioner Bryan. I think what's important to realize is that the gaming operators hold themselves accountable to all media so it's not just where they're focused they're marketing and advertising spend on broadcast or print or other places like that but digital media is certainly a core component to everybody's advertising and marketing mix. The benefits of digital advertising of course is that you can be pretty deliberate about who's receiving that content and where it goes and our marketing code restricts and prohibits operators from specifically targeting minors and looks to particularly carbs out places like college-owned media assets and that includes websites. We have age affirmation mechanisms that are required for any go-to-market advertising to bring customers into a particular sports wagering activity and so there are mechanisms in place to help police that within the existing regulations and within our existing self-regulation within the industry and it goes far beyond just the broadcast or terrestrial networks and into the digital marketing space as well. Sean, thank you, Casey. Sean? Yes, I was just going to echo that sentiment. You know, we have a very rigorous process if you're going to sign up online with us to interact with us directly where you have to provide information including your name and your, you know, obviously data for credit card information so we can verify who you are and digitally target and verify your, you know, your parameters. So, and also anything that they be seeing online from us, we adhere to the same type of standards. We're running responsible gaming commercials. We aren't overloading in that space. We're being very judicious in how we work it on a digital platform. Very much analogous to what we're doing on linear television. So I think, again, it's in everyone's best interest. We're here for those guidelines and I think everyone's been very cognizant of that up front as they've designed those regulations and how we've implemented them for the last few years. And just, I wanted to just clarify, Sean, if you could explain this and sort of its percentage of digital and broadcasting. Just what is Nessan so that we understand that you really are in that space? Because that was a very pure question for Commissioner Bryant. Sure. Well, and so we run multiple platforms for it on our linear television networks. We have Nessan and Nessan Plus, which are distributed throughout New England. So, you know, all six to eight, the cable and MVP, the multi-video providers. So it's ubiquitous across all platforms. We also run Nessan.com, which is a general sports website. And we also run Nessan 360, which is a direct-to-consumer site where we directly will sell you Nessan without an intermediary. And it's really, it's the first in the country, fellow linear television service directly to consumers. And we also have an engagement betting site called Nessan Bet. And again, that encourages responsible gaming is providing odds and education, working with the AGA to provide tools to people, and it operates under the same guidelines. Additionally, we don't do any direct betting or we've opted not to engage in anything other than referring to other reference lines and providing information. So we're not actually taking bets or securing bets or moving them through our website. So I think all of those platforms are widely used throughout New England, and we try to adhere to the same guidelines and standards, even if they're not necessarily completely applicable, like the MLB or NHL guidelines are also being applied to not only our digital properties, but other digital efforts that we're having like digital sports and college sports. Thank you, Sean. Best, I keep putting the spotlight on you and I don't mean to be doing that. So I apologize, but can you speak to what the MLB and maybe what some of the other, you know, the NFL or the NBA are doing in regards to national platforms like the Facebooks of the world, Snapchat, you must be dealing with them, I would say as well as the broadcasting world. So speaking for MLB and it's not inconsistent with what you've heard from folks who've already spoken up on this topic. Everything I stated with regard to our restrictions, the requirements as far as what'll be prohibited that is using actors or batteries who are underage, that applies across the board to channels that we control or our clubs control. And so I am again, one of the folks on the small group of folks or the small committee of people in the commissioner's office when we've had this happen where clubs will say, hey, we've got this sports betting partner. You guys have reviewed and approved the contract. You reviewed the assets, which we do as part of our approval of that contract between a club and the sports book operator because they include the proposed assets as an attachment to the contract typically. And they'll say, look, we've agreed to do two social posts on our Instagram account. And here's what we have in mind. We weren't completely sure if it was within the parameters of the guidance you've given. And we've said, yay or nay or you can or can't do this. And so everything I've stated already with regard to broadcast, radio, in some of those specific and venue limitations and the requirements applies regardless of the medium that our clubs, us or our sports book partners are looking to push it out to consumers. Very helpful. Others of our experts? Okay, commissioners, this is a time to ask those questions that you are troubling you as we think about advertising down the road and our obligations as a regulator. Kishore Bryant, are you leaving yet? And again, I'm asking questions that I think maybe the people who are participating today, even if you have suggestions for who to talk to, but it's not obviously just the sporting events that are doing the marketing and the advertising. And so I mentioned this way early on, right? When the statute was passed that I had attended a training with an individual from Michigan commented on the ad inundation that came on as soon as sports wagering was legalized in that state and that he said to do it over again, they would put a lot more attention on how to mitigate that. So any direction that you have in terms of that occurring outside the context of sports events and the broadcasting of sports events because there may very likely be advertising that goes above and beyond that. So when you talk about the restrictions on the games, et cetera on the AGA, maybe you can speak to this a little bit is whether or not the expectation is that they continue to conduct themselves that way, regardless of whether they're advertising on a sporting event versus sitcom that might be on that, somebody might be watching or online. Does anyone have a response to that? Sean, you're here this afternoon, I'm not sure if that's a plus or a minus. No, I'm sorry. I didn't mean to derail that, but I do have to step away for a prior engagement. I am going to leave Cosme here with you, who can answer any follow-up questions and I really appreciate the time to participate in this panel and we'll be working with you in the future. So thank you. We don't want you to escape without a very big thank you from us, great contributions and we appreciate the time you've shared with us. Leaving us, we're going to be wrapping up shortly in any case, so thank you so much. We appreciate it. Would you like to address Commissioner Bryan's question? Yeah, I would. I think I can answer this, Commissioner Bryan. Most of us on this call, as far as broadcasters or Nessan, we've always said in previous conversations with this, we're regulated and obviously self-guiding in some of these, right? I think what happens when you see the amount of, I mean, Boston's a big city and then when you see bus boards and outdoor and there's a lot of probably unfettered advertising mediums that beyond sports franchises and broadcast and regional sports networks where you're going to, I mean, they're going to take a lot of this as well too. So I think that we're very good at self-regulating and being very cognizant of messaging and us as a broadcaster, obviously being federally regulated. Easy for me to say, but we have self-imposed guideposts and also guideposts that we really have to watch and I think we're very mindful of that, but other outside media I think is, that's going to be, we're probably going to see the amount of saturation that you're talking about. Do you have any suggestions in terms of other groups to reach out to? You know, I don't know if you've, if you talk to outdoor, you know, I don't know if... Is that the billboard company, I mean? Yeah, yes, yeah, billboard, right. So I mean, again, there's probably now more than ever. I hear 3,000 advertising impressions that somebody goes through on a daily basis and so now more than ever, there's a lot of categories out there in which you can advertise, you know, online, offline, outdoor, broadcast. You know, now you see the big tech companies getting into the content space with Netflix and YouTube TV and other categories. So, you know, you also have that as well too. So I know it's frustrating because sometimes you do want to obviously have some controls around that and regulate some of that messaging, but I think it's getting increasingly more difficult. Can I just follow up with a request, Todd? Sure. You're affiliated with Fox, right? Yes. Is there somebody in the Fox world of New York that we could reach out to that to ask this question? And if so, we don't need an answer right now, but maybe you could find that for us and forward it to us. Like a Fox network representative? Yes. Okay, sure. Thank you. No problem. Okay. Other questions. Trisha Skinner. I want to make sure you had your question spots just. Anything? You're all good. Excellent. Trisha Rainer. I'm good for now. And I appreciate that. Fantastic question, Eileen, because I am thinking about the different ways ads can be targeted, not just through traditional, here's the sports. Here we go. But also through other means. I appreciate it. Do you want to add in your advertising experience on that? No, I mean, I do think that there's a ton of mediums, a ton of different ways that you can touch consumers these days. And, you know, as far as when we look at our, our landscape and whatnot, you know, we're being really, really mindful just given the commitment that we obviously have to this region, being here, being locally, you know, in the association with the team. So I feel like we're doing legit everything we can and every single medium that we touch, whether it be social, digital, you know, true.com, our DTC app to make sure that we're being really mindful of the responsible gaming, the responsible gaming message. But, you know, I would just encourage everybody on this call, you know, think about the next 48 hours and think about all of the different places that you see advertising and all those different touch points. There are a lot of them. So there's a lot to think about for sure. And just a reminder in our statutory language, I know Meena and Kristina are already thinking about this, but the final section with respect to billboards, it's kind of limited, it says advertising on any billboards or where we can regulate advertising on any billboards or any other public signage, which fails to comply with any federal, state or local law. So billboard language is in there, Commissioner O'Brien. I know that outdoor advertising takes care of that. And so I'm wondering if there might be a dialogue we want to have with them on any thoughts that they have about regulating some of the billboards facing content, responsible gaming message, mandates, that sort of thing. And I think we would turn to MassDOT on that. Am I right? MassDOT has that regulatory authority. I raised another question. I think publicly there's some billboards of casinos who advertise who are actually conducting casino gaming in other neighboring states, and they do not include responsible gaming messaging, which we require. So I think that's being addressed right now with MassDOT, I'm hoping. So that is, we could have a follow-up to bring MassDOT into one of our conversations, Commissioner O'Brien. But we didn't get a lot of direction in a statute on that. Any other questions or issues that we want to raise? Participants, is there any closing thoughts that you wish to share as we turn now to our job? I know that this has been extremely helpful for me. I suspect I'm speaking for all of the commissioners. Would you like to close with some thoughts? Class, thank you. Thank you. I'm happy to share a closing thought. First, thank you for the opportunity to participate in this discussion, I think, as much as we talked about collaboration among stakeholders on our side of the table. In my experience and other jurisdictions working with regulators on different issues when investigative concerns have come up, the thing that has made my job the easiest, and I hope that some of my friends at the other regulatory bodies would say made their job a little bit easier, is collaboration amongst the sports leagues and the regulators. So I hope that as the commission continues to grapple with this issue and other issues where you will do rulemaking that you'll continue to consider me and my colleagues at MLB and certainly my colleagues at other sports leagues. So I know some of which wanted to participate today but had conflicts as resources and we can continue to have dialogue on this and many other topics. But the last thing I'll say, again, thank you so much for this opportunity. Thank you, Quest. Others, any closing thoughts? Other than thank you, I appreciate the opportunity to come to the round table and just dialogue and collaborate in this way. And as Quest said, you know, collaboration is understanding where some of the concerns are, how we can be really great partners in that way is really helpful for nothing. So I appreciate you guys taking the time to pull us all together. Thank you so much. And thank you to Ness and Charlie, and also to David Friedman, who is so helpful in bringing Ness into the table today. So thank you. And also, of course, to Sean Grail. Thank you. Thank you. And let me echo my fellow participants in thanking the commission for this thoughtful conversation today and the opportunity to contribute. I think in the, and as Quest talked about collaboration, I think continued collaboration with the commission and operators around what, you know, the practicality of the regulations are going to be and what that will look like. I think this Massachusetts has done a very good job of that to date with the operators for traditional gaming. And I'm sure that will still be true for sports betting as it comes online. And I think it can't, we can't say enough about the opportunity that we all have to help consumers migrate away from the predatory illegal market and into the protections that will be within your regulations and within your authority to help drive the right kind of responsibility messaging, the right kind of consumer protections and the right kind of education to ensure that anyone who wants to get involved in this now has a viable option to do that within the protections of the legal market. So thank you. Thank you so much. And again, to Bill Miller, your president's CEO, thank you to him for sharing you and your colleague at our last roundtable. A very appreciative Jordan. Thank you. I want to thank you again, Madam Chair and the commission for having us here today and discussing and educating about the advertising landscape, not only in Massachusetts, but across the region and across the country. I'll leave you with the thought that broadcasters have been responsible stewards of the public's airwaves for more than 100 years. And while this is new to our broadcasters in Massachusetts, our colleagues in 30 or so other states have been handling advertising of gaming responsibly for some time now and we look forward to the opportunity to continue that stewardship of the airwaves and service to the public as we move forward in Massachusetts, moves forward in this space. So thank you. Very helpful reminder, Jordan. Thank you so much. I'll say Todd, thank you to you and your colleagues at Boston 25 for sharing you today. Yeah, thank you very much. Thank you, Madam Chair and the commission. Appreciate this very, very transparent approach and also very good conversation on this topic. So I know as broadcast will be very mindful of this legislation moving forward. Thank you. Thank you. Commissures are you all set? We can excuse our panelists as they can get back to their day jobs. We feel very, very fortunate to have had all of you participate today and for that I thank you. And I thank my colleagues who have joined today's conversation. Many of them are working hard on their day jobs, but keeping an eye on this important conversation. So thank you. Commissures were all set. If you don't mind, to our guests, I ask for a motion to adjourn. Move to adjourn. Second. Thank you. Any discussion? There never is. Commissioner O'Brien. Hi. Hi. Yes. Thank you. And thank you to the public for joining us today. Appreciate it very much. Thank you. Thank you. The lunch.