Nevada Parimutuel Event Wagering

July 1, 2010

VIA FACSIMILE AND U.S. MAIL

Dennis K. Neilander, Chairman Nevada State Gaming Control Board

555 East Washington Avenue, Suite 2600

Las Vegas, Nevada 89101

Re: Application Letter for Approval of Wagering on Certain Events Pursuant to NGC Reg. 22.120(1)(e) and A.B. 218 (Enacted) Our File Number: 100370-001

Dear Chairman Neilander:

As you may recall, we represent Harry B. Platis (“Mr. Platis”), a well-respected Washington attorney and gaming visionary. Specifically, for the last few years, Mr. Platis has been diligently pursuing his dream of making parimutuel wagering possible on various regulated and competitive events (specifically, poker, blackjack, baccarat, roulette, craps, and slot tournaments) held in Nevada and elsewhere by casinos and their affiliates. In the past, Nevada race and sports books have, of course, limited their wagering activity to horse races and athletic sporting events, pursuant to NGC Reg. 22.120(1)(e).   At the same time, with regard to poker and many of the other events referenced above, it is not an exaggeration to say that many of these events and tournaments are so popular they are virtually on fire.1

By proposing wagering on these new types of tournaments at Nevada sports books, Mr. Platis hopes to harness their popularity for the benefit of the Nevada gaming industry and the State of Nevada. For example, under Mr. Platis’s proposal, a person at a Nevada sports book could now wager on Chris Moneymaker winning the World Series of PokerTournament.

In Regulation 22, the Commission has already defined a “sports pool” as “a business that accepts wagers on sporting events and other events.” NGC Reg. 22.010.20 (2008) (emphasis added).

In continuing discussions that Jeff Silver has had with Member Sayre, we have been anticipating a change in the law that would provide the regulation with appropriate statutory support to permit wagering on other activities. With the enactment of A.B. 218 on June 3, 2009, the Nevada Legislature has expressly endorsed that Commission definition, as well as provided a specific mandate. See A.B. 218 (Section 3). In particular, with the enactment of A.B. 218, the Nevada Legislature has expressly clarified that permissible games, events, and tournaments on which wagers might be accepted at Nevada sports books could include those “other events” that are currently proposed by Mr. Platis and not just strictly athletic “sporting events.” See id.

Specifically, we believe that A.B. 218 now allows the gaming industry and the Board to be as innovative in the sports book area as they can be on the casino floor. See e.g., http://www.washingtonpost.com/wp-dyn/articles/A64457-2004Sep5.html For example, when a new type or style of wagering device is introduced by a licensed manufacturer for the casino floor, it merely requires technical approval. In sharp contrast, the sports book regulations, without the additional permission for wagering on “other events” (as now expressly set forth in A.B. 218), have been less susceptible to timely innovation for wagering on new types of events and tournaments.

This is a shortcoming that has now been remedied with the enactment of A.B. 218.   In particular, pursuant to A.B. 218, the gaming industry can now be as innovative in the sports book area as they have been on the casino floor. This opportunity for new innovation will undoubtedly come at a time when it is desperately needed by our state. Accordingly, pursuant to NGC 22.120(1)(e) and A.B. 218, we respectfully seek a “waiver” or “determination” that poker, blackjack, baccarat, roulette, craps, and slot tournaments are all “other events” on which wagering can now be readily accepted at Nevada sports books.

Thank you for your kind consideration.

Very truly yours,

GORDON SILVER LOUIS V. CSOKA, ESQ. LVC/

cji cc: Randall E. Sayre, Member

Mark A. Lipparelli, Member