 Testing on sound testing on sound we all set I don't think you can even hear me I'll set can you hear me okay yeah he can't hear me good morning good thank you very much good morning everyone if we could take our seats look to get started and we're going to be probably adjusting microphones as we go along so bear with me if I get louder or I'm too soft I welcome any feedback on that all right so thank you for all being here today gathering in person so that we can learn from key stakeholders through a manageable and meaningful process before we begin I wish to remind all that this meeting will be streamed on our website I wish to call this meeting to order it is September 22nd is it the first day of fall commissioner it is the first day of fall we are starting public meeting number 395 a little bit later around 910 and I have just a few opening remarks and some housekeeping tips so if you'll allow me once again on behalf of my fellow commissioners I wish to thank the legislature for its confidence in the MGC to stand up this new sports wagering industry here in the Commonwealth in designating the MGC as regulator the legislature likely saw an agency familiar with legalizing wagering familiar with many players that would likely be interested in expanding the business or entering the Massachusetts gambling market by taking sports bets as I have said in earlier public meetings any new statute can reveal complexities as you begin to dig into its implementation and its practical consequences as we analyze the new law we knew that we needed to understand the scope of interest in this new marketplace most of the represented entities today responded to our request for notices of intent but they do not reflect nearly the entire pool of respondents the Commonwealth should be extremely proud of the level of interest online sports wagering operators have signaled Massachusetts is an exciting sports market our inquiry was critical because the law contemplates a competitive process for awarding category three licenses permitting the gaming Commission to award up to seven full online sports wagering operator licenses this legislative limit allows for the MGC to evaluate each application equitably while offering the market reasonable and manageable number of new licenses and new licensees and still providing for excellent consumer choice the temporary license provision in the law however does not set a limit on the number of licenses that can be awarded upon a payment of a million dollars and satisfaction of the commission's eligibility requirements including industry standard technical and suitability expectations the temporary licensing process under the statute could ultimately require an early dismantling process of ongoing betting operations even those that are superior that could lead to significant destabilization of this new industry that all wish to see launched with excellence and integrity and in a timely manner to learn more about this issue that could have unforeseen impacts on businesses and consumers we have today invited representatives of the companies that expressed their interest in a category three or online or as the statute references a mobile digital platform license here today to take part in this meeting we appreciate their attendance and look forward to their input as to housekeeping while this meeting is open to the public it is not a public hearing we will be calling the invited representatives up alphabetically by company to speak to specific questions related to consumer protection and launch sequence we ask that each representative keep their remarks to five minutes and we will have an attending timekeeper executive director Wells given the number of companies in attendance commissioners will keep any follow-up questions to specific clarifying questions for specific presenters general questions that may come up will be addressed by the commission through a request for responses at a later date please note that the gardener auditorium has been reached recently refurbished and they are asking that we keep food and beverages out water is acceptable and I understand the restrooms are just outside the room in the lobby so at this time I'd like to introduce my fellow commissioners and thank them for their commitment to this important issue we also have a lot of work that's not related to sports wagering that we continue to address and for that I appreciate all of your support and I know that we are truly a team first I'm going to introduce commissioner Eileen O'Brien who is attending virtually today because of health considerations good morning and next to me is commissioner Brad Hill and then next to commissioner Hill is commissioner Nikisha Skinner and then next to me is commissioner Jordan Maynard who was officially appointed on August 1st the day that sports wagering was legalized in Massachusetts and I've asked him if he could remind all of us of the two questions presented today thank you madam chair and good morning the first question set forth on the agenda reads assuming any commission implementation of temporary licensure for untethered category three operators would necessarily include technical testing suitability internal controls and other industry standard requirements and given the logistical complexities and consumer protection concerns outlined at the commission meeting on September 15th 2022 would you have an interest in a temporary license and if so do you have any suggestions on how to address consumer protection concerns in the event that a large number of licensees may be required to dismantle their operations within a short period of time the second question set forth on the agenda reads what is your position on a staggered launch versus a simultaneous launch of the different categories of sports wagering operators retail versus mobile tethered mobile versus untethered mobile any experience from other jurisdictions and reasoning behind your position should be included in your answer thank you commissioner O'Brien are you all set you can hear everything just fine yep I can hear it just fine thank you okay so we'll get started as I noted I'll be asking the companies to come up alphabetically so if the representative from Bailey's interactive could come to the podium and state your name please and your title and thank you welcome I think you may need to just press the button it will be read apologies good morning Commission this is Justin Smith legal counsel for Bally's interactive North America in response to the Commission's first question Bally's does not recommend the implement implementation of a temporary license scheme for all operator applicants only to have some shut down post launch from an operator's perspective this will be difficult to manage where one customers have already placed wagers on future games which are usually placed months in advance and to where operators will have to manage payments and account balance withdrawals if they are deemed in fact required to shut down further this approach may reduce the operators opportunity to invest in marketing and product development if there is a risk that the operation will subsequently need to be shut down and reducing the potential for taxable revenue in the Commonwealth Bally's recommends completing the due diligence of each applicants ability to launch operations to the citizens of Massachusetts with the comfort that all operators and vendors have undergone and completed the the state investigations and are authorized and certified to launch their operations in response to the Commission second question speaking specifically to mobile licenses operators once certified and authorized to launch should be able to launch their operations when they're in the appropriate position to do so after a designated date set by the Commission this will allow operators to introduce the product they want rather than a minimized version due to timing restraints requiring all operators to start at the same date will add stress to the Massachusetts Gaming Commission with regard to completing all the required due diligence and the authorizations of operators platforms and suppliers with a hard deadline if the deadline is missed and not all operators have completed the process there will be pressure on authorized operators and platforms to launch by the Massachusetts Gaming Commission in some jurisdictions we've seen regulatory bodies state that the market will be live from a designated date which has allowed us and other operators to complete key development work prior to launching the platform in that state which has led to success Bally's recommends implementing a specific launch date and which will place the onus on the operator to meet that the required launch date and that's all I have for balance. Thank you. Thank you very much. Mr. Smith. Thank you. Next up please is a barber time media if the representative could come to the podium please. Okay. If that individual arrives later we'll bring him into we'll bring him at the end of the presentations. Okay. Next up bet Fred. Good morning. And if you could just state your name please in your title. Thank you. My name is Cynthia Hayes and I'm the vice president of compliance for bet Fred USA sports. So that is all our operations here in the United States. Good morning and thanks for allowing us to have this opportunity. I'd like to echo very much what Mr. Smith said. You know the other thing that will happen if you have everybody in the universe going out there with the product it also promotes bonus abuse. So what's going to happen is all of the customers are going to go online. They're going to sign up for everybody they can. They're going to take advantage of the sign up offers. And in most cases depending on how long the temporary licensees are allowed to remain operating they're not going to be able to recoup that money. And just the setup and the effort and the time that goes into getting a system out into the field as well as the expense. It's very prohibitive and we don't recommend that temporary license process either. The other thing is a universal start date. We like that approach for online. We think that both untethered and tethered so anybody mobile should be able to get a universal start date that they can they can go ahead and do. We don't personally have an issue with the with the retail books operating but we don't think anybody should have an advantage when it comes to online. Everybody should have the same date that they're given you know a date that's far enough out that allows us to do the work that we need. But also a date that then puts the onus on us to get the work done. So that's it. You're welcome. Commissioner Hill is just wondering again if we hold our questions. We are going to hold our questions to the end. But and if we have specific questions, we'll just invite folks to come back so we do hope you'll stay in the room. So next I bet our thank you. Good morning. Is this on? You have to. Yeah, thank you. Madam Chair, members of the Madam Chair, members of the Commission. Thank you for giving us this opportunity to speak before you. My name is Ashwin Krishnan. I'm head of legal at better. We'd like to start first by explaining a little bit about our company and then we'll dive right into the questions. Better is the first direct to consumer sports betting company to focus predominantly on micro betting, a new form of betting that enhances the sports betting user experience by enabling the moments that drive us sports consumption, such as pitches and at bats of baseball games, plays and drives of football games to become discrete betting opportunities will be a differentiator in Massachusetts by bringing forth a unique product not currently offered by existing licensees and applicants in Massachusetts and will therefore introduce a distinct concept that will provide choice to consumers in the Commonwealth. We're also building a media company that is bringing sports betting to a more mainstream audience by emphasizing the sports betting is for entertainment value and a way for consumers to enhance their consumption of sporting events in a fun and responsible manner. Founded in 2022 by Joey Levy and Jake Paul, better setting out to disrupt legacy gambling and legacy media. Levy is the co founder of SimpleBet, the B2B technology company that has pioneered micro betting on US sports by building the machine learning and automation infrastructure to enable this new form of betting to exist at scale. In fact, SimpleBet licenses technologies to companies like DraftKings. We released our app in August initially as a free to play experience with state by state role out of our license real money betting plan to follow later this year. Better is unbundling micro betting by building an entire company around it and delivering the experience in a simple intuitive user experience. We believe the micro betting will ultimately emerge as the predominant way consumers bet on US sports, given the start and stop cadence of US sports, lending itself perfectly to the style of wagering. Similarly to how daily fantasy sports innovated on top of season long fantasy sports, micro betting introduces an enhancement to the current sports betting user experience. To date, we've raised more than 50 million in funding from renowned institutional and strategic investors and some of the most influential athletes, celebrities and sports team owners. Better is poised to become the consumer company, product and brand associated with simple and intuitive sports betting user experiences, which we believe will ultimately make better the category defining company. We've already submitted applications for licensing in the states of Ohio and Indiana and we anticipate filing applications several other states in the near term in order to facilitate execution of our business plans. Turning to the first question asked by the commission. Yes, better would greatly appreciate the commission's consideration for a temporary license if that is the scheme put forward. We believe that our platform is different than the existing operators and that our user experience will significantly differentiate us amongst potential competitors. We are in favor of consumer choice in terms of providing consumers with a variety of platforms and allowing users to pick the best experience across their choices. We believe that our product also offers low learning curve and makes betting simple, intuitive and combined with all of our responsible play efforts. We believe that our offering will resonate well within the marketplace. We are simply looking for equal footing amongst operators in terms of having the opportunity to put forward our product to consumers in Massachusetts. In terms of consumer protection, we aspire to be a nationwide operator of real money betting, fantasy games and free to play games. So we are investing to make sure that we meet all of the technical standards, internal controls, identity verification, geolocation and responsible play standards. We will be announcing several market access deals across other states in the coming months and have had and will continue to have responsible play focus conversations with regulators in each of those states. In particular, we appreciate that Massachusetts is not accepting credit cards for online sports betting as this is part of our nationwide strategy on responsible play and one of our core principles. We will also feature deposit limits for those consumers under the age of 25, as well as comprehensive affordability checks which allow for wager limits and or deposit limits based on consumer financial profile. Responsible play is a core pillar of better values and will be infused throughout all of our product offerings and media campaigns. With respect to the second question, we believe that a simultaneous launch across sports wagering operators is the right approach as long as operators have adequate time to prepare for such a universal launch date. Based on our experience in other states, we believe that Massachusetts should carefully evaluate and put forward a reasonable timeline for compliance with technical standards and internal controls such that operators have had adequate lead time to prepare for such an initial launch date. Further, once those timelines and procedures are set, barring unforeseen circumstances, Massachusetts should endeavor to stick to those established timelines and procedures rather than shift the goalposts, which can force operators to scramble and have to reprioritize various components of their offering to meet the new protocols. If Massachusetts wants to ensure that there's a level playing field amongst operators and that consumer choice will truly dictate which platforms prevail in this market, then operators, both existing and new, should be given a fair and reasonable timeline in terms of technical and compliance standards in order to go live by day one in Massachusetts. We firmly believe that our product have given an equal opportunity to compete with existing and potential operators will prevail in the marketplace because we have made sports betting simple intuitive while continuing to maintain high standards of responsible play. We would welcome the opportunity to speak with each of you to tell you more about our company, our vision and our products and also provide any insights that we have as the sports wagering landscape across the country, which may help inform how Massachusetts creates its regulatory framework in this area. Thank you. Thank you very much. Caesar's Sportsbook. Good morning, Chair. Good morning, commissioners. And thank you for the opportunity to appear on behalf of Caesar's Sportsbook. I'll be very brief. Excuse me, Mark, if you could introduce yourself. I'm sorry. Mark Hickar of Greenberg Troward on behalf of Caesar's Sportsbook. And again, thank you for the opportunity to appear. I'll be very brief. We seek only that the process regarding the launch timeline be clear and transparent. We appreciate the views of others who are seeking untethered category three licenses. And we look forward to hearing their opinions, but none from us at this time. So thank you. Thank you very much. Moving on to DraftKings, please. Just a reminder to introduce yourself and, oh, you know what? Thank you, Commissioner Skinner. There's just a different order. Thank you. DraftKings and if you could state your name and title, please. Thank you. Good morning, Madam Chair, members of the Commission. My name is Chris Sopola, and I'm the Senior Director of Legal and Government Affairs at DraftKings. DraftKings is a digital sports entertainment company founded right here in Massachusetts. And to this day, we continue to be a founder led company with our corporate headquarters on Boylston Street right here in Boston, which is home to more than 1000 DraftKings employees. We currently operate our DraftKings sportsbook in 20 states and are very excited to be here today to discuss sports wagering coming to the Commonwealth. As a leading sports wagering operator in the United States, we look forward to hopefully having the opportunity to provide our DraftKings sportsbook right here in our home to the residents of the Commonwealth. To answer your questions, before I answer the questions specifically from a DraftKings perspective, we believe it's very important overall and it applies to both questions in our opinion that all operators, whether category one, category two, category three, untethered mobile or tethered mobile are given the opportunity to launch on day one. Everybody given that fair shake, whether it be retail mobile. We found that in other jurisdictions that has worked and made sense and it ensures that nobody obtains a competitive advantage, an unfair competitive advantage when a new market opens. Temporary license licenses help facilitate that to ensure that everybody is given a fair shake. So as to your first question, the temporary licensing process has been used effectively and safely in other jurisdictions and one of the benefits to being in 2022 while the residents of the Commonwealth obviously want sports wagering to be operating now, the Commonwealth and you as a commission do have the benefit of four plus years post the Supreme Court decision striking down PASPA to look to other jurisdictions where operators are safely operating and responsibly operating their products to help determine who should be entitled to a temporary license. So we do feel that the temporary licensing process and making those available is important to maintain that parity across all categories. I kind of hinted our answer to a question to when it comes to staggered versus a simultaneous launch. We do feel that what's of utmost importance is giving everybody a fair shot to launch. Retail mobile untethered tethered. By doing that, setting a date that operators can work towards and clearly working with operators to understand what is reasonable as far as a launch timeline, setting that expectation and allowing operators to work towards that. We found that that's been the most efficient way to launch a market. If there are operators that choose not to go live on day one, which we've seen in other jurisdictions or operators that are not able to launch on day one where you have other operators that are able to launch in a safe manner, we think that's the fairest and best approach to new markets. So I do again, I think the Commission for the time and I'm happy to answer any questions you may have. Thank you. Thank you. Moving on to fanatics, betting and gaming. Good morning. If you could state your name and good morning. My name is Alex Smith. I'm the Vice President of Regulatory Affairs at Fanatics, betting and gaming. Madam Chair, members of the Commission, thank you for having us here today and for the opportunity to speak in front of you. I'll keep my remarks fairly brief. To your first question, I think it is true that across the country we have seen temporary licenses issued and used in a safe manner in other jurisdictions. However, I would caution that allowing more operators to launch than the market can bear on a full license basis does introduce consumer protection concerns that I think are difficult to address. I assume you will hear from many of my colleagues concerns around bet settlements, promotions, concerns. And I think those are all valid concerns that will exist if are valid concerns that will be difficult to address if more operators are allowed to launch than the market can bear. With regard to the universal start date, we do support a universal start date. We've seen that work well in other jurisdictions. It adds certainty to the market and makes the process smoother both for you as a regulator and for all of us here as operators. We thank you for your time and look forward to working with you in the days to come. Thank you very much. Fandall. Good morning. If you could state your name and your title, please. Thank you. Good morning. My name is Corey Fox. I'm vice president for product and new market compliance at Fandall. Fandall is currently licensed and operates 27 Brook and Mortar sportsbooks in 15 states and NDC, as well as online sports wager and 16 states as well as Ontario and Canada. Fandall's success is based on our best in class platform, innovative wagering offering offerings, a culture of strong compliance and overall customer experience, including a strong commitment to responsible gaming. With regard to the first question around temporary licenses for untethered category three operators, a successful launch of sports wagering requires a significant investment of time and resources by the operator to make sure that they are creating a customized product for the specific state where they're launching, as well as by the commission to make sure that the product that's being launched is appropriate and meets the regulatory guidelines for that state. We don't think it's an effective use of resources by operators or by the Commonwealth to offer more temporary licenses than there can be final licenses, given the significant investments by both the operator and the commission. We view the ability for the commission to issue temporary licenses as a way to expedite the launch of the operators who have already been selected through a competitive process. The temporary licenses allow the commission to launch sports wagering while the commission is finalizing its suitability review of the operator in preparation for issuing a full license. In mobile sports wagering, this has been successfully implemented in numerous jurisdictions throughout the U.S., expediting the launch of many mobile sports wagering markets while allowing regulators to take the time necessary to complete their due diligence on operators prior to issuing a full license. On the second question regarding a staggered launch, we urge the commission to select a universal start date. At a minimum, all mobile sports wagering operators regardless of category should have a universal start date. In states which did not have a universal start date, operators who have launched first have enjoyed significant sustained advantage in market share versus operators who have launched only a few days or weeks later. Our experiences from 2019 in Pennsylvania and Indiana highlight this. In Pennsylvania, FanDuel launched mobile sports wagering approximately three months prior to DraftKings, whereas in Indiana, DraftKings launched mobile sports wagering approximately three weeks before FanDuel. Based on publicly available data, FanDuel has maintained our position as market leader in Pennsylvania ever since, and similarly based on publicly available data, DraftKings has continued to benefit from their early launch as well. Use of a universal start date ensures fairness for all operators to compete on the quality of their product offering. Use of a universal start date also removes undue pressure on the commission staff to make decisions and issue approvals. If there's a specific date, if there's no specific date, the operators will race to get licensure and will put significant pressure on the commission to ensure that they are first to market because of the competitive on us to make sure that we're first to market on the Commonwealth. We think that this has been, the universal start date has been really successful in states such as Arizona, Colorado, Kansas, Michigan and New York and it will be utilized in Ohio on January 1, 2023 as well. I'm happy to take any questions the commission has. Thank you very much. Next up, fan logic. Good morning. Nice to be shot. If you could state your name and Walter Sullivan for fan logic. Good morning Madam Chair and members of the commission. The commission asked two questions of the applicants relative to temporary licensing and staggering. First, the commission cannot move forward with licensing process until the regulatory framework, excuse me, until the regulatory framework is in place and regulations in place for applying for licenses. Regulations need to be in place to protect the public from granting any license, including a temporary license. In awarding a temporary license the commission should look at the process of the Massachusetts Commission against, excuse me, the Massachusetts Cannabis Control Commission. An applicant submits an application for licensure. The commission conducts a full and fair investigation. The commission then issues a provisional license. The applicant then goes through the process of permitting and building the facility out and obtaining a final license from the commission. The commission should only grant a temporary license like the CCC's provisional license after complete and thorough investigation is done to ensure that the applicant meets the statutory and regulatory requirements for licensure. Granting a license at this time is more probable than not that the applicant will be granted a final license. Further, the commission should not grant temporary licenses more than the maximum numbers of licenses allowed. The chairman was correct when she said, quote, the idea of, excuse me, the idea of having to give notice to honorably operating businesses that did not take, did not make the cut is unattainable to me. Further, Executive Director Karen Wells memo to the commission relating to the impact of temporary licenses more than adequately state the reasons why the commission should not take approach of granting more than the number of licenses allowed. The second question asked by the commission, for the applicants to answer, relates to staggered launch versus simultaneously launch of granting licenses. Again, the commission should follow the CCC's, what the CCC did relative to licensure, which has been replicated in many states that have legalized cannabis. The CCC gave priority for licensure to existing medical marijuana treatment centers, economic empowerment applicants, social equity applicants, women, minority owned businesses, and other businesses that prove that they helped benefit those groups. To many industries, including the gaming industry, including the gaming industry, have not considered equity in their planning. This is one reason why the commission, including in the gaming license application, is sectioned on how to deal with affirmative action and inclusion for the applicants. In moving forward with sports wagering, the commission should give more consideration to applicants that promote equity when they are granted licenses. Sports wagering does not have the same in-depth requirement for licensure that the expanded gaming act did. The commission should include such in-depth requirements, including social equity requirement, on the license application, and take a staggered launch approach to licensure, given priority applicants that meet the requirements in a ranked and mannered fashion. In other words, the first phase would be giving licenses to one Category 1, one Category 2, and one Category 3 that ranks the highest second phase, one Category 1, one Category 2, one Category 3 that ranked the second, and so forth, until all the licenses are given out, or the commission decides that the amount of licenses they want to see out there are out there. Thank you. Thank you. I'm sorry. Sir, could you please repeat your name, your title, and your affiliation? Oh, I apologize. My name is Walter Sullivan. I'm a lawyer representing the client. Oh, Finn Logic, sorry. Thank you, Mr. Sullivan. OK. Then moving on to FSST Interactive. Thank you. And just a reminder to state your name and title. Thank you. Hi, everybody. Thank you for allowing me to speak today and excited about what you guys are doing and to be part of the process. My name is Brian Hall. I'm the Director of Regulatory Affairs for FSST Interactive. FSST Interactive is a tribal operated business operated by the Flandro Santi Su Tribe of South Dakota. As to the two questions that the Commission has asked and posed to us today, in terms of the temporary license, I don't think it's ideal, again, echoing some of my colleagues' remarks, mostly because of the significant investment that is required to enter a new market. And it just naturally increases the risk of that investment. However, if if the Commission does decide that a temporary license is the way forward, there are obviously benefits to getting to the market. And as a kind of a trial period, I think the only caveat that we would suggest would be that the process needs to be very clear on the pathway to a permanent license and what the requirements might be. And I say this because that will allow operators to really assess the risk of the investment that I've spoke of earlier. In terms of a staggered launch, I'd probably echo and we'd echo some of what's been said already, a universal, I guess, launch date would be ideal because it allows for a level playing field. And I think those are our two comments as regards to the questions. Thank you very much. Thank you. Hard Rock Digital. Good morning. Good morning, Madam Chair, Commission members. My name is Danielle Boyd. I'm the Vice President of Regulatory and Compliance for Hard Rock Digital. Thank you for having us here today. On a personal note, I just wanted to mention that I truly appreciate and respect the endeavor that you all are undertaking as a two-time regulator in my former life in West Virginia and Tennessee. I was involved in the sports betting launches there. So thank you for giving us all the opportunity to speak to you today. As it relates to the first question, I'll echo the sentiments of a lot of my operator counterparts. Hard Rock Digital would not recommend the issuance of a temporary license to all potential untethered category three operators, given the time, resources, and expenses required to launch and operate a mobile sports betting business. That being said, we certainly deferred to the Commission to determine the best approach for the Commonwealth and just urge that if temporary licenses are offered, there's a vetting of all applicants, all key personnel, and operational documentation and testing certifications issued in advance. As the second question, we support a simultaneous launch for all sports betting products in which all operators who have diligently worked to become licensed and received all necessary operational approvals launched to the public simultaneously on one prescribed universal start date. We believe this approach enhances the value of the Massachusetts market by fostering greater competition, which will be a credit to the revenue generator for the Commonwealth, as well as allowing operators to launch on an equal playing field, which further increases competition and enhances the experience for consumers. More specifically, a staggered approach could devalue the licenses issued to operators who are not first to market and could ultimately result in less license fees for the Commonwealth as well as revenue. I know a lot of my operator counterparts have spoken about their experience in jurisdictions launching from a corporate perspective, but I can also speak to my personal experience having launched West Virginia as a regulator and a staggered approach in Tennessee with one simultaneous launch date. And while I hesitate to really compare the two markets, given their differences, and given the unique factors that were involved in making those decisions in each state, I will say that objectively the success of the Tennessee launch lends itself to support a simultaneous launch date as well. So thank you very much for your time today. Thank you. Novabet, Max and Bet. Good morning. So thank you, Madam Chair, commissioners and staff. My name is Joe Cusole, and I'm a consultant to Novabet and Max and Bet. Dealing with the companies in alphabetical order, I'll make a statement on behalf of Max and Bet first. So Massachusetts presents the potential of a unique situation for many sports wagering operators being permitted to take wagers under a temporary permit for up to a year, and then potentially being forced to shut down their operations, if not granted, one of the available permanent license by the commission. Operators face the unfortunate scenario of getting all the operational and technical elements prepared to launch in the state, entering the market, and then being forced to shut down shortly thereafter. Nonetheless, Carousel Group, which does business as Max and Bet in the US, would be interested and would suggest temporary licensing as a potential for untethered category three operators. In the face of such an operational environment, it is yet most important that customers feel confident in the safety and security of their funds. To mitigate the disruption from the closure of a sports book, operators that do not receive a permit license should be required to do the following. Clearly communicate to customers across multiple mediums about the discontinuation of operations. Stop accepting new wagers, new accounts, and deposits well before the required closure date. All active vets should be avoided and returned to the customer's wallet app prior to the shutdown. And lastly, operators should refund all account balances for all current players and keep the active for a period of time to allow for easy withdrawals as necessary. During the commission meeting on September 15th, it was mentioned that temporary licenses may only be valid for a short period of time, even well under a year. If Massachusetts is planning to proceed down a path where a host of operators are granted temporary licenses, the timeline for their operation should be abundantly clear from the start. From an operator standpoint, requiring companies to do everything required to launch in the state only to have to have their license revoked before even a year feels overly draconian. More importantly, such short and unknown time frame prevents clear messaging to the consumer about when an app may no longer be available and will only result in additional confusion, uncertainty, and potential distrust of the sports wagering market. As to the second question, staggering launch dates for different categories of operators creates a pronounced advantage for those who have the benefit of launching first. In particular, allowing some operators offering sports wagering through a mobile application or digital platform to make their products available to the public before others only serves to significantly distort the market where it matters the most. When operators are prevented from launching from the same starting line, the evidence is extremely clear that it creates stark competitive advantages for those that are permitted to launch before their peers. In Virginia, the three largest current U.S. operators, so let me start that over. In Virginia, the three largest current operators readily admit that Vandals' three-day head start on DraftKings and one-week head start on BetMGM had a material impact on market share in that state. As has been repeated in multiple markets, first mover advantage is a massive leg up for operators and inhibits competitive advantage to the detriment of consumers. For this reason, several U.S. jurisdictions have made a concerted effort to put all prospective operators on the same initial footing. In June, the Ohio Casino Control Commission announced a universal start date in Ohio for both retail and online sports betting, which is January 1st of this upcoming year. Therefore, all sports gaming operators can only begin accepting wagers from eligible patrons on that same day. Ultimately, this will result in a vibrant and competitive sports gaming market from the go live date. Operators recognize the public yearning to get sports wagering markets live in Massachusetts as quickly as possible. If the gaming commission is determined to expediently launch some form of gaming, staggering the launch state of retail versus mobile market will be far more equitable solution than staggering the go live date between tethered and untethered mobile operators. Like in most other states, of the total addressable sports wagering market, over 90% of the overall market amounts wagered by patrons in Massachusetts will ultimately come via online mobile channel. And so that's time if you can move on. Thank you. I know you have another client. Yep. Thank you. And that was my concluding remarks anyway. Thank you very much. So that was for five minutes for Max and Beth. Yep. Thank you. And we appreciate our timekeeper. Thank you, director. Thank you so much. OK. So now on behalf of Novabet, with regards to the first question, under different circumstances, the issuance of a temporary license would be a win for all parties because operators and the state receive gaming revenue sooner while upholding consumer protection through approved internal controls and abbreviated compliance review. However, in this case, the cost of setting up operations prior to knowing whether one company will be chosen for a permanent license as one of the seven, it puts a significant disadvantage to larger established companies that already have independent testing lab certifications and also who can quickly scale their operations to include Massachusetts. While it is certainly possible for Novabet to launch and unwind operations, smaller companies may be obligated to hire and train staff and go through testing process with only a hope of having a favorable outcome. The general assumption would be that they are obligated to do this to be considered one of, for one of the seven permanent licenses. Regardless, Novabet does have an interest in seeking temporary licensure. Novabet is confident that its operations guided by internal controls will provide the necessary protections should it be required to dismantle its operations in a short time. These controls will address issues such as notice to customers and employees maintaining cash reserves, guidelines for the cancellation of open wagers, procedures for closing accounts, distribution of patron funds, record retention, insurity bond requirements and procedures for resolving customer complaints for a period of time after the shutdown. With regards to the second question, Novabet prefers the availability of a simultaneous launch by a category with retail operations launching first followed by mobile operations. In this scenario, the commission would establish a go live date. Those operators that meet all the regulatory requirements for go live will be able to launch on that date with others launching once approved. The availability of simultaneous launch would put all operators on equal footing in that first mover advantage is taken away from those who meet the established deadline. Additionally, since there is certainty about who qualifies for a retail license, we respectfully request the commission to consider an approach that would permit the launch of retail operations while they simultaneously review the untethered mobile submissions. This would allow the commission in stakeholders time to become familiar with sports betting operations, collect revenue and deliberate on the qualification of prospective mobile applicants. It would also provide certainty to provide certainty to the seven selected mobile operators without requiring them to begin operations only to have them shut down. Thank you for your time. Thank you. Commissioner O'Brien, do you need a break? I'm fine. Thanks. OK. We're all set to continue then. Barbara. No one from Barbara time? No, not quite. I just before we move on to the next speaker, I just want to confirm that we have not had anyone from Barbara time media arrive. All right. Then we're going to move on to Commonwealth Equine and Agricultural Center. Good morning. And if you're wondering why it's a different alphabetical order, this isn't to challenge us on our ABCs, but it is in reference to the fact that the next group that will be presenting could are or could become licensees for category one or category two licensees. And you fit into that category. Good morning. Thank you. Good morning, Madam Chair, members of the commission and staff of the commission. My name is Patrick Hanley. I represent Commonwealth Equine and Agricultural Center. And as you indicated, I don't fit neatly into the order here. And I think that'll be reflected that my response is really to your second question and not to the first. And I think that will make sense. As I indicated, I represent a group that intends to apply for a license under Chapter 128A with the support of the thoroughbred horsemen in Massachusetts to conduct thoroughbred racing at Great Meadowbrook Farm in Hardwick, Massachusetts. And it's our expectation to race subject to licensure next September. Assuming that's not the case. Although I love the emphasis. It's actually kind of fitting. Thanks. OK. That was great. Assuming that the commission grants the thoroughbred horse racing license, we are planned to apply for a sports wagering license as well. And as the commission considers the timelines for issuing licenses, I ask that you consider the fact that eligibility for a potential licensee through Chapter 128A for a client like mine, Commonwealth Equine, may develop later in the process by virtue of the 128A timelines. And I'd suggest that under the law, any delay in the eligibility should not be a barrier to seeking a sports wagering license. As the commission knows, thoroughbred racing has been an unintended casualty of expanded gaming in Massachusetts. And I believe the legislature was mindful of that when it was crafting the sports wagering act. I say that because the legislature was intentional in creating opportunity for sports wagering for thoroughbred racing in the legislation. And I ask that the commission set up its regulatory framework, including its timeline, in such a way to account for the particular timeline set forth in 128A. I have no doubt that you'll do that, but I just wanted to praise it before you today. Thank you very much for your time. Thank you very much. Next up, Bette MGM. Lady Chair, fellow commissioners, Daniel Miller, director of compliance at MGM Springfield. As you mentioned, we as an operating casino in the state would be looking for a category one license in the realm of sports wagering, but giving our tethered nature with our partner, Bette MGM. I'm gonna yield the floor to my partner here, Josh Wiseman, working as Bette MGM to explain our joint position on the two questions that the commissioners has posed. Thank you, Mr. Miller. Good morning. Good morning. My name is Josh Wiseman, and I'm the senior manager of licensing at Bette MGM. So before I begin, Madam Chair and commissioners, I'd just like to thank you very much for the opportunity to be here today and to weigh in on some of these issues. So for the first question about the appetite for a temporary license, this question doesn't directly pertain to Bette MGM as will be applying for both a temporary and permanent category three license, but that license would be tethered to MGM Springfield. Nevertheless, Bette MGM's position is that the number of untethered permanent licenses should be equal to the number of untethered temporary licenses. The concept of issuing more temporary licenses than permanent and then having operators dismantle their operations is problematic for several reasons and would be unprecedented. So we would caution against that. The second question that MGM's position is that there should be a universal or simultaneous launch date across the industry. So that would include retail, tethered mobile and untethered mobile operations. This is an approach that's been adopted in several other jurisdictions with success, Arizona and Colorado are a couple of examples and then Ohio is doing something similar right now. One critical element of this simultaneous launch date is a transparent timeline, which has already been mentioned today. So Bette MGM's suggestion would be that a set launch date would be communicated to the public and then a timeline made available of all of the critical milestones that operators would have to meet that wish to launch in that first wave. So that would include things like license application, submission deadlines and the submission of other regulatory documentation. We believe that this combination of a universal start date along with a objective and transparent timeline is the most effective way to launch sports betting in a new jurisdiction. It affords the best experience for customers who on the first day of legal sports wagering in Massachusetts are welcomed to a full suite of operators and all of their products and let the market sort of speak for itself. And also from the equity standpoint, it's the most fair way in our opinion to launch the new market and ensure that no operator has an unfair competitive advantage when we begin. And that concludes my statement. Thank you very much. Thank you. MGM Springfield, so Mr. Miller, you're all set. Thank you. Okay. Cambridge Park Casino, Mr. North. Good morning. A couple of introductions to start off. Please. If you could state your name and title, please. Yes. Good morning, Madam Chair and commissioners. We appreciate the time taken today. My name's Samantha Haggerty and I am Deputy Chief Compliance Officer and Regulatory Affairs Council for Penn Entertainment, formerly known as Penn National Gaming. And we are the parent company of both Penn Sports Interactive and Plain Edge Park Casino. So North will be speaking on our behalf today. Good morning, Madam Chair. Good morning, commissioners. My name is Josh Pearl, Senior Director of New Markets and Strategic Initiatives of Penn Sports Interactive. As additional background, Penn Sports Interactive plans to apply as a category three tethered to Plain Ridge Park's category one. As a whole, Penn Entertainment currently offers 25 sports books, retail sports books and 11 jurisdictions. We also offer online sports wagering and 13 jurisdictions. Thank you so much. And again, good morning, Madam Chair. Good morning, commissioners. It's a pleasure to be speaking in front of you this morning. Again, for the record, my name is North Grounds on the General Manager at Plain Ridge Park Casino. Both Penn Entertainment and Wynn Encore will be submitting a joint written comment on the two questions outlined. That being said, this morning I will be speaking for Penn Entertainment and Wynn will speak on their own behalf. While our joint statement is complete, we wanted to add a few additional brief points to our written comments. With regards to the first question, the commission rightly notes that the primary question on temporary licensure falls to those entities that are not tethered to an existing licensee. We further acknowledge the logistical and regulatory issues that would result from the temporary licensure of a number of licensees that exceeds the maximum allowable under the law. Further, being granted a temporary license without being granted a permanent license could negatively impact an operator's ability to obtain licenses in other jurisdictions. As the commission is aware, jurisdictions tend to look unfavorably upon applicants who have withdrawn or failed to complete their license in another jurisdiction. As such, we would advocate for a competitive selection process for the up to seven untethered mobile licensees to ensure those applicants are qualified under section two of 23K before the temporary licensing process for those untethered mobile operators begin. With regards to the second question, Penn Entertainment advocates for separate launch phases comprising retail, tethered mobile, and untethered mobile in that order. Within each phase, qualified entities should have the opportunity to launch on the same day if all commission requirements are met. This approach would provide the public and operators clarity and certainty around the launch process. Additionally, it gives the commission ample time to complete the qualification and competitive selection process for the up to seven untethered mobile licensees. See, that concludes our comments this morning. We're able to answer any questions commission may have when it comes to that point. Thank you very much. Thank you all. Rainham Park, good morning. Good morning, Madam Chairman and members of the committee. My name's Daniel Bryan. I'm the CPA for Rainham Park and I'm here representing them today. On the first question of the temporary licensure for the untethered category three operators, although it may not directly affect us, we do have a couple of comments. The commission has raised numerous valid concerns regarding the practical implications of granting temporary licenses to the untethered category three licensees only to have them possibly revoke some of them later on. Unless some of these issues can be satisfactory resolved in advance of the process, the risk to the commonwealth and the public perception risk may make the process a no-win situation. Also, a temporary license process could divert a portion of the commission's limited resources away from the permitting licensing process and with the result that all licenses would be issued at a much later time. On the second question, from Rainham's perspective, we believe that it makes sense that the category one, the category two and the tethered category three licensees be permitted to launch their sports wagering operations prior to the untethered category three licensees. This seems logical in that the identities of the category one and category two licensees were determined by statute and are known operators to the commission. Consequently, the suitability vetting process should be more efficient. In addition, most of the licensees have committed and continue to commit significant capital resources to their brick and mortar facilities necessary to operate a retail location. Rainham Park has committed substantial resources to build a new building for their sports gaming operation in the hope of opening as soon as possible. Finally, giving the sheer number of untethered category three notices of intent, the vetting and license process would undoubtedly take a much greater period of time for the commonwealth to narrow down the field and decide which of the applicants should be granted the seven unfettered licenses. It would not seem to be in the best interest of the commonwealth to delay all licenses until the unfettered category three licensees were issued. The final decision should be based primarily upon what is in the best interest of the commonwealth and what is the most likely result, what is most likely to result in the most successful launch of the sports wagering experience in Massachusetts. Thank you. Thank you very much. And then, Wynn Batt, Encore Boston Harbor. Good morning. Good morning, Madam Chair and Commissioners. My name is Jackie Crum and I'm the Senior Vice President and General Counsel for Encore Boston Harbor. It's nice to be back in person. Commissioner O'Brien, we wish you were with us too. As North mentioned, we will be submitting written comments, so I will be brief. In an effort to balance the desire to provide legalized sports betting in a timely manner, and to do so in a manner that is consistent with the MGC's demonstrated commitment to the integrity of the licensing and competitive process, we suggest that there should be three separate launch phases for retail tethered and untethered mobile, in that order. And within each phase, there should be a designated universal start date for licensees that have met the MGC's requirements. With respect to retail, category one and category two licensees have already been found suitable by the MGC, and much of the infrastructure is already in place to support in-person sports wagering. This will provide a legalized sports wagering option in the Commonwealth in a timely manner while the MGC works through the competitive and licensing process for mobile. We appreciate the opportunity to present these comments to you today. Thank you. Thank you very much. I think that I understand that we have someone from Suffolk here to move forward. Good morning. Good morning, thank you. Good morning, Madam Chair and commissioners. My name is Bruce Barnett. I'm from the law firm of DLI Piper, and we represent strong Suffolk race course LLC. Chip Tuttle, Chief Operating Officer of the company, very much wanted to be here today. He's been hung up. We sort of expected to be coming up a little bit later in the hour, and he's still on his way, so. Our apologies. No, certainly nothing to apologize for. I'm just explaining, he'd be here if he could. Briefly with respect to question one, as some others have said, obviously not directly related to us. To the extent the commissioners, commissioners gathering information, yes, we do plan to either apply for or support a tethered category one mobile application. We definitely appreciate the challenge before the commission. Balancing the temporary license provision against the cap on the tethered license is for full time licenses. Unfortunately, we don't have helpful answers to your second question to offer. How do you handle that situation before you might have a number of tethered licensee, untethered licensee shutting down? We don't have anything to add to what has already been said today. With respect to the staggered versus unstaggered start date, I think we are in the same alignment as Wynn and Plain Ridge Park in terms of supporting three start dates for the following reasons. We think that the general approach should be that sports wagering should launch for a category as soon as the operators in that category and the commission are ready to make that happen. And we think that doing so fulfills the purposes of the statute to bring sports wagering to the people of the Commonwealth and most importantly, perhaps to bring it out of the shadows and under regulation for those who either knowingly or unknowingly have been wagering essentially illegally up until this point. As category one and category two licensees will probably be more or better positioned to quickly launch their retail operations, we think that those should be able to open first. Our understanding of the evolving regulatory structure also is that there are additional regulations that need to be put in place and vetted thoroughly for the mobile side that may not entirely apply to the retail side. So to the extent that timing is such that they can open first, there shouldn't be a delay in that. But we also think beyond that there should be a staggered opening of the mobile licenses between the tethered and the untethered assuming that the technical standards for mobile operation can be in place before the commission is able to complete the competitive process to window the untethered's down to seven. Even if the retail sports books are already open and sports wagering is live in Massachusetts, the problem of, as I think the chair in particular but the commission has recognized, there's a risk going on as we stand here today that because the statute has been passed and the governor has signed it, there's confusion in the marketplace and among the people as to whether or not sports wagering is legal. And that's gonna continue as nefarious operators, take advantage of people who may not realize that while the law has been signed, it's still not approved by the commission and legal out there. Once retail sports wagering becomes open, that concern for mobile operators who are trying to pull people in would only become worse. And so of continuing out the period for any mobile until both tethered and untethered are ready to go will extend the period of time when those risks are being experienced. We recognize that that would result in a differing treatment among the tethered and the untethered licensees but we submit that it's the legislature in passing the law that created that difference in treatment by putting a cap on the untethered and we think that would be the best way to proceed. Thank you. Thank you very much. Is there any other organization entity that has not been heard today that wishes to be heard? Okay, before I turn to my fellow commissioners for questions, we do have written comments that were invited at our September 15 meeting and Executive Director Wells will read them into the record and they'll be beneficial for all of you I assume as well. Thank you. Thank you, Madam Chair. So the first written response we have from the CEO of G3 Esports LLC and as to question number one, their written response is as follows. G3 Esports LLC is interested in obtaining a temporary untethered license and welcomes any technical and compliance oversight required to be approved, obtained, and sustained a license. Regarding the question about consumer concerns related to quote, a large number of licenses, quote, unquote, being required to dismantle their operations within a short period of time, please consider the following. A, a significant amount of time and financial expense is required to establish operations in any state, including instituting state and regulatory compliant KYC, AML, KBA, and a secured user PII database. Approved money in and out systems, responsible gaming protocols, and in my company's case, biometric user identification. Additionally, companies need to commit to hiring and training a substantial amount of new employees to run Massachusetts-based operations and the time to launch marketing efforts that introduce their brand and products to consumers. There will be, there will likely be substantial market and consumer confusion if a large number of temporary licenses begin operations, but subsequently have their licenses revoked after only a year or less of operation. Because ceasing operations will add considerable costs, the methods by which revoked operators handle PII storage, employee terminations, and outstanding player balances may not meet the expected standards of the Massachusetts Gaming Commission and act to erode consumer trust in the system. The possibility that potentially disenfranchised revoked operators will use player data in non-desired ways may be heightened. The process of what to do with PII data in the event of business closure needs to be clearly defined by regulators. C, the ability to expand existing operations in Massachusetts is relatively simple. For larger, established operators but has a material and significant impact on smaller operators, this impact will act as a substantial barrier to product and service innovation for consumers. Smaller, independent operators that strive to introduce new ideas will have to determine if it is worth the risk and cost to obtain a temporary license with the looming possibility of revocation. This risk will effectively preclude minority-owned companies from being able to enter the state in any significant manner. D, the Massachusetts Gaming Commission should clearly establish the requirements for permanent licensure so that temporary license applicants can recognize their significant expensive time and money as a solid investment in obtaining a permanent license. Other concepts for consideration should include, one, temporary licenses should allow for a period of operation of at least three years, or if one year it should be auto-renewed for up to three years subject to operational compliance, i.e. a final determination on its operator license application is not made for at least three to four years. Two, the criteria for revocation or failure to renew a temporary license should be indicated clearly at the beginning of the licensing process. And three, temporary operators not in compliance should be provided a minimal period of time to comply depending on the severity of the issue and whether or not it existed or was known during their launch period. E, the concept should also be established that obtaining a temporary or provisional license is the standard process by which the Massachusetts Gaming Commission enables independent operators to obtain full licensure. As part of this process, companies should be required to submit their product offerings as well as their responsible gaming, regulatory, and internal control plans during a pre-screening period. And F, in order to ensure fairness, companies that apply but are not selected should have their $1 million fee refunded or the fee should not be payable into the seven temporary licenses are selected. And as to question number two, the response is market confusion is often the result of introducing too many concepts, projects, categories, features, et cetera, simultaneously creating information overload in the mind of consumers. This is especially the case with products that are similar in nature or with differences that are not apparent. Consumers were often conflate one message with another, resulting in frustration and a loss of trust in the system that has oversight responsibility. Staggering launches for new market categories will allow for better early consumer adoption and for operators to educate users about new market categories while allowing regulators to monitor safe marketing practices. A staggered launch related to retail versus mobile is highly preferable to provide each category operator adequate time to establish itself apart from other operators, as well as differing classifications of wagering. This includes efforts related to category introduction, operator brand introduction, marketing initiatives, and consumer education efforts. Additionally, this would include staggering the launch of sports books, traditionally sports betting, apart from the new video game and eSports wagering category. To assure responsible behavior from both operators' consumers, each category of wagering needs to be clearly and separately introduced, along with the best practice operator requirements to establish trust with consumers. And it says, thank you for considering my response. It's part of your process, sign Louis Anthony Goud. So that's the first one. I'm actually going to ask Mr. Grossman to read the next one. We can alternate just for my voices. I'm keeping out a little bit. This is from, good morning, everybody. This is from Gary Erlich, from Digital Gaming Corporation, USA. It says, I am the corporate compliance officer of Digital Gaming Corporation, USA, one of the companies that filed a notice of intent regarding a license for sports wagering in Massachusetts. I write on behalf of DGC in anticipation of the Massachusetts Gaming Commission's meeting for prospective mobile sports wagering licensees scheduled for Thursday, September 9, 2022. Although I will not be able to attend the meeting in person, your email of September 15 indicated that the commission would welcome written comments on the questions posed in that email. DGC's responses are set forth below. Number one, assuming any commission implementation of temporary licensure for untethered category three operators would necessarily include technical testing, suitability, internal controls, and other industry standard requirements. And given the logistical complexities and consumer protection concerns outlined at the commission meeting on September 15, 2022, would you have an interest in a temporary license? And if so, do you have any suggestions on how to address consumer protection concerns in the event that a large number of licensees may be required to dismantle their operations within a short period of time? So that was the question. Here's his answer. As an operator currently offering live sports wagering in multiple states with applications pending in several more, DGC can categorically state that in our experience, we have never encountered the issue of temporary licensure proposed as it is in the questions and comments of the commission. DGC has encountered and obtained temporary licensure in only two situations. The first situation arises in states which offer an unlimited number of sports wagering licenses. Here, once a preliminary investigation indicates that the applicant is probably qualified, the applicant may be permitted to go live under a temporary license pending completion of the full investigation. The expectation is that if the full investigation does not disclose any previously unknown disqualifying information, the applicant will receive plenary licensure. This model allows for speed to market while still maintaining full integrity checks without unreasonably frustrating the applicant's business plans and expectations. The second situation occurs in states which offer only a limited number of sports wagering licenses awarded in some type of competitive evaluation process. DGC has been authorized to go live on a temporary basis in such a state but only after, not before, it has received notice of its preliminary selection, contingent only on satisfactory completion of its plenary investigation. While this question assumes commission implementation of temporary licensure for untethered three, category three operators, DGC does not believe such a procedure would truly serve the interests either of Massachusetts or its prospective mobile sports wagering applicants. Specifically, it appears that what is contemplated is allowing more than seven applicants for the untethered sports wagering licenses to go live under temporary licensure with those applicants which are not subsequently awarded one of the seven available licenses having to shut down their Massachusetts operations within a short period of time. Such a process would only serve a speed to market goal if enough applicants participated. However, the plan constitutes a huge disincentive for businesses which might otherwise be interested in Massachusetts but which cannot reasonably assume the unusually high risk that its large expenditure of funds to go live could rapidly become a sunk cost. As outlined, the proposed temporary licensure plan seems more akin to a high stakes lottery which most companies could not afford to enter. Then he addresses the second question as follows. Recognizing that Massachusetts may have differing even conflicting goals regarding this issue, DGC can nevertheless point the commission to Ohio which has designated a universal start date for all sports gaming in that state. The rationale for proceeding in this manner is set forth on the website of the Ohio Casino Control Commission which states, the universal start date is January 1st, 2023. This date was chosen to give all stakeholders time to start offering sports gaming on the same date including businesses looking to offer online and brick and mortar sports gaming as well as kiosks and bars and taverns across Ohio. Leading up to the universal start date, prospective licensees will be completing buildings, distributing kiosks, hiring and training employees, obtaining partners and making all other necessary arrangements to begin operating sports gaming from the same starting line. The commission is aware that some stakeholders, specifically many online operators, have fewer preparations to make leading up to launch and could start sooner. However, pursuant to HB29, all forms of sports gaming must have the opportunity to launch on the exact same date. End quote. In essence, a universal start date ensures fairness by affording all sports wagering operators the chance to begin on equal footing. We thank you for your consideration and it is signed by Gary Ehrlich. The next one, Madam Chair, is from Victory Games Challenge, Inc. The response to question one is, we are interested in the temporary license. Our suggestion is to leverage the mobile slash online technology to bring the TPPPS, third party providers of propositional players concept in retail gambling from California to the online mobile sports wagering. The idea of TPPPS in California is the collaboration between the casino establishments with sports books and the TPPPS without sports books to improve experiences for betters as well as the business of casino establishments without losing protection of end consumers. The sports book closing issues of the temporary licenses in Massachusetts could be solved with similar type of collaboration between potential CAT3 licensees under the guidance of the EMGC. There could be many ways to achieve collaboration in the spirit of TPPPS. In the following, we will elaborate on one type and how to achieve that in stages. You actually, can you tell me? Stage one, agreement stage. Potential CAT3 operators agree that the final regular licenses will accept transferred wagers from these temporary licensees who will stop their sports book because they do not make it into the regular license list. Note that these temporary licenses will stop their sports books but will continue running by simply forwarding wagers to regular licensees if consumers want to use their platforms like TPPPS. Also note that Know Your Customer KYC is already validated on the temporary licensees based on regulation. Regular licensees will agree that temporary licensees will do KYC if customers choose to do so. It is a requirement on the mobile online platform that the wagers could be transferred to another licensed platform under the choice of sports better. There are incentives for both sides for such agreements for regular licensees. They will accept transferred wagers of customers from those non-sports book temporary licensees with predetermined compensations for each transfer. For non-sports book temporary licensees, the predetermined compensations could make up the initial investment and their performance with end consumers could help their applications for future regular license during renewal slash update time. Stage two, temporary license stage, CAT3 operators have the temporary licenses and start to accept customers and wagers. Their platform should have the capability of transferring wagers. In the stage three, the temporary license sports book closing stage when regular licenses are issued, temporary licensees will stop running sports book and transfer consumer wagers to the regular licenses of consumers choice, based on the agreement and pre-built in platform capability as described in stage one. As mentioned before, the temporary licenses online mobile platform could still be running, but all wagers will be forward to regular licensees of consumers choice. It is the end consumers to decide whether they would like to switch to the regular licensees platform or continue to use the existing one with forwarded wagers to fully protect consumers right slash choice. On stage four, license renewal and update stage during the regular license renewal update time, the performance and consumer inputs on these temporary licensees platform without sports book and just wager forwarding could be considered as a criterion in the competitive process by the MGC. It is also just suggested that the MGC adds a special type of license to regulate such non sports book and wager forwarding providers, which is like TPPS license in California. So I think that's time. I do note a question to response. They start that they support the simultaneous sports launching. And I'm gonna, okay. We have one more and I'll have or do that afterwards. Just one more. It is short. So we'll hear the last written statement and then we'll take a brief 10 minute break. And then I believe that the commissioners will have some questions for some of you who have presented. So thank you. Thank you manager. Okay. So the final submission comes from Steven Brody assistant general counsel for regulatory and government affairs. In response to the first question, Fubo, by the way, this is for Fubo gaming. Fubo would be interested in the opportunity to obtain a temporary license and believes operations under such licensure in the Commonwealth can be performed in a manner that addresses the consumer protection concerns outlined at the commission meeting on September 15th, 2022. Specifically, there can be on platform messaging that notifies consumers of special considerations during the period of temporary licensure, limits on future wagers that extend beyond a certain date or number of days, and an additional acknowledgement by consumers regarding the method of returning any balances in their accounts. And to the second question, they respond. We believe that a simultaneous launch of different categories of sports wagering operators will create the best environment possible for consumers in the Commonwealth. A staggered launch will create an unintended benefit for the first category of licensees by providing limited competition, unintentionally enhanced brand awareness and default brand loyalty. One of the strengths of the legislation in Massachusetts is the variety of opportunities it makes available to consumers to wager among competing businesses and staggered launches will erode that benefit. Further, staggered launches and other jurisdictions have created confusion in the marketplace because consumers have believed the first available method of wagering remained the only form of wagering even after operators launched under other categories of licenses. And that's it. Thank you to Mr. Grossman, Director Wells and Ms. Bocheman for reading those into the record. And if it is now 1040, if we could reconvene at 1050, does that sound okay? Is that all right? All right, we'll reconvene and we look forward to just a few questions for you. Thank you for your patience. Okay, if everyone could take their seats, our break extended, but it seemed as though it was a great opportunity to see each other in person. Again, thank you for all being here today and thank you for your presentations. Thank you for your mindfulness around our timekeeping. You know, we could have asked a lot of questions of you for today's meeting, but we focused on a particular issue. The opportunity to ask questions in the future, we reserve the right to perhaps it may be in a virtual format. Perhaps it will be through written increase, but we really do appreciate your input on all a host of issues. We look forward to continued discourse. But for today, again, if we could focus on the presentations that made before us, I'm going to turn to normally and that have gotten so used to the virtual that I look to see who leans in first for their question, but I'm gonna turn to my right. Well, first I'm gonna turn to Commissioner O'Brien as I would. Commissioner O'Brien, do you have a question? I do, thank you Madam Chair and thank you to everyone who spoke this morning. I have two areas. One I think is probably better left to follow questions by my fellow commissioners. The first one however was, and I flag Cynthia, he's from Beth Fred because she was the first one to say it, but there's been references to sort of start dates and the fact that obviously companies need time to ramp up. So the hypothetical I had out there, particularly to Cynthia, just to keep it not for a free-for-all would be if we were to say today, anybody can come in and you have the ability to launch a mobile untethered. How long internally either an average or a minimum to maximum timeframe do you guys need as a lead time to actually launch or start taking a bet? And that's for, I say it to send a position out there. Commissioner O'Brien, if the individual for Beth Fred could come and I think it was Cynthia Hayes. Hayes. Could you come to the podium please? And my apologies, but we will ask that you come to the podium so that we can hear. Take your time, there is no hurry and I just wanna make sure if you need any clarification on the question, Commissioner O'Brien is happy to repeat it. Thank you. So it really depends because it's gonna depend on the regulations and if there's development work that needs to be done, but if there's minimal to no development work that needs to be done, it's probably, if you're talking internal controls and all of that, it's probably close to a nine month process. Thank you. Like I said, it just depends. Right. Thank you. And did you have a follow up question for her or? No, I had a different question. We heard a lot of comment about staggered versus non-staggered retail versus the sort of the three options. And the question that I have, the follow up and in particular for Danielle Boyd, the former regulator, which is what if any consumer protection impacts did you see in a staggered launch that was retail first and then mobile? Thank you for your question, Commissioner. So just to give some context to West Virginia versus Tennessee, when we did launch the staggered launch in West Virginia, it was with the West Virginia Lottery, we did start with retail first. That was done. It was a different time. It was right after Paspa was overturned. I think Paspa was overturned in May of 2018. We launched the first sports book at Charlestown. It was actually a Penn National Casino Labor Day weekend of 2018. And so with that kind of the factors that went into play there were that some of the casinos were still kind of looking for new partners, had different plans for deployment. And the first particular casino had everything in order. Everything was ready. And so we made sure that we reviewed all of the operational controls, internal controls. They were going with a reputable vendor who was known from Nevada. And those were the kinds of things that we looked at. And then mobile launched slightly later, still a staggered approach. In Tennessee, obviously, being one of the first states to launch in West Virginia, I had the benefit of the experience over the last couple of years when the mobile launch and open license untethered market, that's only mobile in Tennessee. We had the experience of kind of the last two and a half years to look at. And we had not only licenses in place, operational controls reviewed, but it was essentially everyone who had diligently worked to go live by that November 1st, 2020, I think it was 2020 or 2020, get my ears confused here. It was a couple of years ago. But we ensured that they could all launch at the same time. And because of that, I think objectively, looking at what at the time was considered to be probably one of the most successful first days and first weekends that any state had had. I think that obviously in hindsight, the simultaneous launch date for everyone who's worked diligently, also making sure that promos, any promos are reviewed or approved that are being offered if the commission determines that that's a process they wanna go about. And also operational controls, testing certifications, everything is in place. Spreading that out, the competitive advantage. I do think that competition and diligence makes all operators perform better. And therefore, I think that by virtue of that, there are ways to ensure whatever approach you take is 100% safe for consumers and the processes are in place to ensure if there are any issues that both the commission and the operators go through certain dispute processes, complaint processes and can protect consumers. Thank you. All set, commissioner. Thank you, Ms. Floyd. Commissioner Hill. Thank you, Madam Chair. And I'm gonna follow up with what my fellow commissioner just asked about the staggered launches. I'm not surprised at the testimony or the comments that I heard regarding the implementation of our temporary licenses for untethered category three operators. I'm not surprised at all at what I heard today. But I think I heard, and I don't care who answers the question or follows up with what I'm about to say, but I think I heard everybody say, and it started, Cynthia, we're not picking on you, but you started the conversation in this regard and I heard it from Mr. Cusull and I heard it from the letter in Mr. Gold's comments. So why don't we ask for those two to respond? Yes, thank you. Did I hear you correct that you would be okay with the commission setting up a process where we would allow the retail operations to start up first and then we would look at tethered and untethered launches separately. I don't think I heard anybody say that they would be against that. So I wanna be very clear that's what I heard today because the testimony, I'm calling a testimony, this isn't a hearing. The comments that I heard are telling me that everybody is okay if we were to do something like that. Am I correct? That Fred is fine with that. We just don't want an opportunity for somebody to offer mobile ahead of anybody else. So we're fine with retail if they are ready and they go first, but we don't want anybody to have an advantage in online so that everybody can start online at the same time. I'd also like to say in response to my last answer, it's probably nine to 12 months and nine months would probably be pretty quick. Okay. And again, it'll depend on what's in the regulations. And is Joe still here? Yeah. Yes, Joe, certainly. And there probably was some presenters who did would dispute that. Thank you for your question, commissioner. And yes, both Novabet and Max and Bet or a carousel group would support or would be in favor of a staggered start or separate universal dates, one for retail and the other for mobile, although neither would support or view favorably different start dates for tethered and untethered mobile, but would be in favor of phases for retail and phases for mobile. Okay. Thank you. Thank you, Madam Chair. There, I know that I heard that there was opposition to that proposal that you just had forth. And I will ask the representative from DraftKings who's jumping out of his seat to come. Thank you, Madam Chair. And I do agree with my colleagues that have spoken before that, putting mobile operators on the same playing field tethered or untethered is about most important. We also do feel that retail should be viewed the same as mobile. The overwhelming majority of wagering activity when you look at other states is on the mobile platforms. Many states have successfully launched both at the same time. Our most recent launch was in Kansas, operators could go live with retail and mobile. We think that there are roadmaps in place that would allow for both verticals to go live at the same time. And we do think that's the most equitable approach to a new market launch. And if I may, just one comment to Commissioner O'Brien's question on launch timeline, is that okay, Madam Chair? You know what, I'm going to actually insert my rules if you'll allow me because that would give you an opportunity that many others wouldn't have. I invited you up because I did remember that you had offered a different proposal that you may have missed, Commissioner. There may have been another, but I think what we do here is that it is not necessarily universal, right, on the stack, unstaggered. Okay. Thank you. Thank you. Do you have another question? No. Commissioner Skinner, do you have a question? I do, Madam Chair. Thank you. First, I want to express my gratitude for each of you, the commenters today. It was a very helpful process and we appreciate your participation. There has been a couple of you who have, can you hear me okay? Yeah. A couple of you have mentioned other jurisdictions who have used the temporary license structure. And I guess I'll direct this to the Draft King's rep, in particular, but have any of those jurisdictions required operators to shut down where they were not extended an opportunity to operate permanently in that jurisdiction? Thank you, Commissioner Skinner. To my knowledge, no. Typically the process when there was a competitive selection process in place in other jurisdictions, Virginia comes to mind, that competitive selection process would take place and then I don't recall if the temporary license was utilized in Virginia, but in that instance, they went through a competitive process. The legislation was signed into law and within eight months from legislation being signed into law, they went through a competitive selection process for up to 12 mobile operators. They had significantly more interest in those licenses, selected the operators and the first operators were taking waders within eight months. So from a sequencing perspective, we have not seen temporary licenses be awarded and then definitive selections made. That said, again, from a Draft King's perspective, what's of utmost importance to our company is parity in the market and everybody being on an equal footing so that there aren't competitive advantages. So if that were how the commission felt that that was the only way to provide equity, Draft King's being part of the first group to go live is of utmost importance to us. Are you aware of any mobile operator who was required to shut down operations for any reason? In other United States jurisdictions, permanently? Yes. I would have to get back to you. I believe there may have been one-off instances where temporarily operators shut down, but I don't wanna misspeak and be happy to follow up with that information after the hearing. I'd appreciate that, thank you. Yes. Madam Chair, another question. This one's directed to Mr. Brian Hall, FST. I'm sorry, you did speak on behalf of FST. Yes, okay, great. So I think you talked about the risk of investment for mobile operators. Could you elaborate on exactly what those are, particularly in the technology component of the risk? Yeah, I mean, I think that, and this is in reference to the risk associated with the temporary license, right? Yes. As we were talking about, yeah. Yes. I think in most cases, I don't think it's a technological risk. I think most of the risk money is actually in acquisition or customer acquisition. So, you know, the technology, most operators that have been in the business kind of have that sorted out. There will be a risk and investment to align it with some of the compliance requirements that may be different, that require development, and those will depend on the rules, but generally speaking, you know, when it comes to testing and facilitating, most products have been through that in other jurisdictions. The product that we will be using and partnered with has been through some of those testing and facilitating. So the development costs really will depend on what the rules and regulations are and whether or not that's very different from other jurisdictions, I think. But the big investment risk that we'd have to assess really is the customer acquisition cost because, you know, the capex of a business like this is very front heavy, right? So, you know, the operators won't see returns, you know, until maybe years down the line when they spend a lot of money. Acquiring players onto the platform. So I think that presents the biggest financial risk, in my opinion. Thank you. Yep, thank you. And commissioners, I'll swing back to you if something comes up. Commissioner Maynard, do you have a question? Madam Chair, if you'll give me one second to put my thoughts together. If I could have someone, maybe Jackie, address the staggered launch, the retail, the untethered and the tethered. I really just want to know if there are other jurisdictions that have operated in that capacity and moved in that way where there's been a separation in what's tied to the retail versus what's not tied to the retail. And North, either one of you, Jackie North. You know, they're delivering a joint statement anyway. Yeah, I know you're delivering a joint statement. Perfect. Commissioner Maynard, Josh Pearl, and Samantha Haggerty will answer on our behalf. Appreciate the opportunity again this morning. I would say that Massachusetts is almost unique in the legislation that was passed in terms of the retail, the tethered and the untethered. The closest thing to it is Illinois, with the Illinois Sports Wadring Act. It does allow for tethered access to each of the casinos and racetracks. It also allows for up to three untethered online only operator licenses. I will say in Illinois, it did provide the board up to 540 days since the first license was issued. We would certainly not recommend that in fairness to all of our colleagues here. However, it is the state that is closest in terms of mirroring Massachusetts legislation. And just a note there, retail did go live about three months before online did, before the first tethered operator. And I believe every online operator there, with the exception of one, still operates under a provisional license. Thank you. You're welcome. Commissioner Maynard, I'm sorry. Do you have another question right now? Because I want to do a follow up for Commissioner Hill. I'm all set. So a follow up to Commissioner Hill's question. I noted DraftKings, because I had noted the response earlier, but I also watched that he was eager to speak. I don't want to be remiss and not give another organization entity the opportunity to respond to Commissioner Hill's question. He had, as you noted, a general sense that staggered retail versus mobile or online might be acceptable to the majority. Is there someone else who wants to state the opposition again at this time? Is that a fair way of saying, okay, good. All right, good. If we haven't missed anyone, I feel better. I do have a couple of questions. And I'm going to turn to, yeah, I'm going to turn to DraftKings. Mr. Spohl, if you want to come up again, please. So, and also, eventually, Bruce from Suffolk, as we consider this is again on the staggered approach, it's not lost on this commissioner that there was under 23K a requirement of extensive capital investment. And that was noted today by the three current casino facilities. It's also an argument that the product that they would be presenting at a sports book is in the customer that would be seeking that product is distinctly different or at least somewhat different than the customers that the online sports wagering operator might be attracting. With that in mind, I hear you saying that it would be inequitable if there was a stagger between retail going up first and let's make no distinction between tethered and untethered, just the two. How do we address that? Because DraftKings is, you know, a Massachusetts-based company, and we appreciate that. But how do we distinguish the investments that came forward and sort of the ability to launch their product earlier then have to wait for the process that setting aside what we're calling the super temporary licensing issue, how do we address that? Thanks, Madam Chair. And just to clarify my position, I think it's tiered just to be clear about how we're looking at this. We agree with everybody in this room that has said treating the mobile operators differently, tethered versus untethered is completely unequitable. Specifically to the mobile versus retail, we also feel that other states have been able to go live with both products at the same time. And we would submit that we believe that the commonwealth can do the same. And under ideal circumstances, it is most equitable in our opinion to allow all verticals to go live the same. Some I gave the most recent example of Kansas was the most recent state that did that. When it comes to the capital contribution, speaking specifically for DraftKings, obviously the way the legislation was drafted, we don't fall into a category one, category two licensee, but we also have provided significant investment into the commonwealth. We employ over 1,500 employees. This is our home, although we're global company now. We've always stayed true to our roots in Massachusetts and we're walking distance. Our corporate headquarters is walking distance. So we do come at this and look at this from a unique perspective, I believe, compared to some of the other operators that have spoken today. But that is our view, that we believe it is most equitable to treat all verticals on the same playing field, understand the point that you're raising, but that is our position. Can I just clarify, when you said 1,500 employees, is that 1,500 employees in Massachusetts? Nearly 1,500 employees work out of our Boylston office. I believe it's a little higher than that when you factor in total employees in Massachusetts, yes. So again, so how many 1,500? I can get you the exact number I don't wanna misspeak, but it's approximately 1,500, yes. Okay, and then I do have a post script for you as well. I noted your answer about the temporary licensing issue because I think generally the other presenters all understand what we're wrestling with in terms of the complexities of the provisions in the law. Massachusetts legislature is very thoughtful and I do believe that this was an inadvertent decision and an inadvertent development in the legislation and now we're wrestling with how to make sure that when we stand up this industry, it meets the standards that we know the legislature expects of Massachusetts gaming and also of our work. You didn't seem to be wrestling with it in the same way. And I ask that because one of the major concerns for me is because the number might be much larger in the temporary pool, we'd have to reduce by a competitive process up to seven. Some of those companies will be very honorable companies that are competitors across the country that you all compete for the same pool. And we also know that there would have to be very careful regulations and procedures to how to dismantle those operations should they not be selected in our competitive process. I'd like for you to explain what you would do to really protect your customers when you went to them to say that first at the front, you need to be on notice that you may not advance that within six months to a year, we may have to, if we're not selected, we may have to shut down. What would be then on the other end, if you are shut down, how would you protect the interests of your customers in your own organization at that point? Thank you, Madam Chair. And I wasn't, to clarify my previous response, my intention was not to gloss over the framework that was laid out. I think from our perspective, and I cited Virginia earlier, Virginia from our perspective had a similar situation where there was a finite number of licenses, there was a competitive selection process laid out. They received more interest for that initial batch of licenses than were available. They conducted that process and then went into the licensing phase. And they did that within a relatively short period, eight months from the governor signing the law to the first wagers taking place. Under ideal circumstances, I believe that you would select the companies that would be participating and then utilize the temporary licensing to have comfort with who you're selecting and then go through a full suitability. So I'm gonna interject because I think that's where we're starting to use the language of the super temporary licensing process which is in the statute that right now doesn't have the cap. And what I think you're getting at in Virginia and what's common across the country is a more industry standard temporary process where there's provisional licensure on the other end. But again, to my question, because right now the law does allow for a temporary licensing pool where it could be imagined that honorable companies, the best could end up not prevailing in our selection process. And we have real concerns about what that would do to the integrity of the marketplace, the destabilization as I've noted. But what does it do to the operator's interest? What would it do to your customers and how would you protect your customers if you're one of those who's not lucky enough to advance? And I think somebody spoke earlier about, if you were to go that route, safeguards being built in where there's clear direction that this is on a temporary basis, essentially a roadmap to ramping customers off if you chose to go that route so that there's clear communication from the very beginning that everybody that's operating has not been selected through the competitive selection process. I think that you would need to build in those safeguards to make very clear to the public that and to our customers that while these companies are operating, there's no guarantee that these companies will be participating long-term, but there are safeguards in place to ensure that customer funds are safe and by participating in business with the operators that they're operating in a safe way. I think so, there would have to be clear parameters set from the very beginning. From speaking specifically for DraftKings, just the overall, the overarching picture is that we do not believe that operators should be given advantages based on their status in the state or their partnership in the state. It should be an equal playing field. So I understand I'm conflating issues, but we are looking at it as one issue that it all impacts each other. So if the only way for us to participate in the Commonwealth sports betting market on day one is through this process, then that is a business decision we will make because we do understand the importance of being in the group that is first into market. Yes, I'm all set and Commissioner Maynard has a follow-up and I don't know if you have follow-ups, but again, thank you. Thank you, Madam Chair. So I just wanna clarify and really it's a follow-up to your question, Madam Chair. So what you're saying is if a temporary license structure is implemented where there's no cap or no thought on who becomes the permanent category three license, if that's what it takes to get involved, your company would be fine with that. But are you also saying, because I thought I heard, that if the selection process, and I'm gonna quote Mr. Fox from Fandle would cap them at seven, even in the temporary, it seemed like you would be okay with that process too. Thank you, Commissioner Maynard. Yes, I think that that's a process that had other jurisdictions have utilized where you use the competitive process to select, use the number seven, because that's the cap in the legislation, the seven operators that the commission is comfortable with, at least off the initial criteria that's used for the competitive selection, participating in the market. And then in lieu of waiting for a full suitability review, issuing a temporary license to that group, that is more in line with what other jurisdictions have done to date. Is there a preference? Is there a preference? The preference is that, I believe that that has been a tried and true playbook in certain jurisdictions, and they've done it efficiently. I think that that provides the market the most certainty. That said, again, if the commission were to say, the market is going live at X-Date through these, apologies, I forget the phrase that was used, the super temporary permit, then that would be a business decision for us to make at that time. All right, thank you. Thank you. I yield, Madam Chair. Thank you, and if I could just do a followup then with, I think if Mr. Fox is still here for Fanduil, please, thank you so much. Mr. Fox, I think that you did acknowledge the complexity that's raised by having the potential for shutting down operators. If you were faced with having to address your customers, can you just give me a sense of how that would be done and what would be the biggest risk that you would feel, you know, that the customers, the hardest thing that would be addressed is that the future bets, how would you address the shutting down and the consumers' issues? Thank you, so I think with respect to bets that have not yet been settled, we would work with the commission and look for the commission's guidance on how they'd like us to handle those wagers under that scenario. I think for us, the key would be making sure that all of our users were able to access their funds and felt that they had been treated fairly. I don't think, you know, candidly, it would be impossible at all for us to ensure that their wallets were still accessible to them. They could still withdraw their funds or go use their funds in another jurisdiction that has sports wagering or potentially use it for daily fantasy sports as well as sometimes possible for certain funds. So I think there are ways to address each of those issues. I think it would be up to the commission to guide us on whether or not we could settle future bets when they finished off or whether we needed to address them at the point at which the license expired. So you see that as one of the more complicated issues? I think that's a complicated issue. Really candidly for Fandle, and I think I said this in my comments, that investment that we make in a state in year one is designed to pay out over a number of years. So from a business model perspective, it's really challenging for us to invest in a state not knowing if we'll be able to continue to operate there past one year or even shorter. Thank you for that. Thank you, very helpful. Okay, Commissioner Hill, you're all set. Commissioner Skinner. I just, I wanted to kind of piggyback on your questioning. I like where you were going with the questioning, which is why I asked the question that I asked of you, whether you're aware of any jurisdictions where mobile operators were required to dismantle. I think my objective is to try to understand if the answer is yes, which jurisdictions, how they navigated that process. So I open it up to each of the presenters here today. If you are aware of any mobile operators who were required to shut down for any reason, notwithstanding the temporary license process, I invite you to submit that information to the commission for consideration. Thank you, Commissioner Skinner. Okay, another question? You're all set. Commissioner Skinner, are you all set? Back to you, Commissioner O'Brien. Follow-ups, new ones. I don't have anything else other than to say that if anyone wants to submit written responses to the questions that I asked, I'd be more than happy to see it. Excellent. Okay, then this really does conclude our public meeting. As I mentioned, we are likely to follow up with you and we are, as you have been following us, very busy taking lots of steps toward developing a timeline that we hope will inform your industry. This issue has been one that has been analyzed carefully, but it is, as I've used the term too frequently today, it is complex. So we really appreciate your input. I think commissioners, I think it was very helpful. I see Commissioner O'Brien, you're nodding your head and so for that, we're very thankful and appreciative of your time and we really appreciate those who are not local that you came or you sent representatives. It meant a great deal to us, so thank you. Do we have any other business? No other business? Team members, we have Director Lilios, Council Grossman, Executive Director Wells and our multi-faceted Chief Administrative Officer to the Chair and our Special Projects Manager to the Commission, Crystal Bocheman. Very thankful for all your help. Crystal and Tom Mills, you're there. We are very appreciative of your help and Dave Sousa and to Charles River, thank you for your services today. Is there anything else that we're missing? I don't believe so at this time, although I do think Commissioner O'Brien's question about the operator's timeline for how long they would take to get up and running, that may be a helpful question for the Commission to put out for any of the bidders their expectations. My understanding is that this competitive process adds to that timeline. So should the Commission operate under a model where they would do a competitive process before issuing temporary licensure? Should there be either change in the legislation or some other mechanism? Then my understanding is that would be a longer timeline than if there was just giving out the temps to the retail and then what we're calling the super temps. So if the mobile operators in particular could identify how long they need to get ready, that helps us with our timeframe on regulations and things like that. And we were lucky to have Danielle here today because of her past regulatory experience. So thank you very much. We can follow up with that through, again, as I mentioned, we will be issuing requests for written submissions on questions that come up and we may even invite a virtual meeting. So stay tuned on that. Okay. All right. No other business commissioners? Then we need a motion to adjourn. I move to adjourn. Any discussion? Okay. Commissioner O'Brien. Aye. Commissioner Hill. Aye. Commissioner Skinner. Aye. Commissioner Maynard. Aye. And I vote yes, that's five, zero. Thank you, everyone. We appreciate your input and attendance.