US v. Internet Gambling: A Losing Bet
Sunday, July 02, 2006
The following is a paper that earned me a C+ in Internet Law at law school, circa 2003-2004. The grade is at least partially indicative of the fact that I prefered the gambling aspect to the law aspect, and tended to play low stakes during lectures (god bless wireless Internet). One last warning. This may not have been my final paper, but it's the only copy I can find. Enjoy:
United States v. Internet Gambling: A Losing Bet
Introduction
In 1997, Senator Jon Kyl of Arizona stated, “Gambling across State lines is illegal, but the advent of the Internet has created the opportunity to gamble in a manner that is not specifically covered by our laws…”.[1] Six years later, after multiple attempts to pass legislation by Senator Kyl and other Congressmen,[2] Internet casinos continue to thrive.[3] United States citizens contribute more than fifty percent of the Internet gambling industry’s revenue.[4] However, the United States government has failed to find a way to handle the new reality of a globalized, technologically advanced gambling industry. In order to prevent billions of dollars in revenue and taxes from leaving the United States, Congress will have to find some way to either eliminate or regulate Internet gambling. While their efforts are focused on the former, the latter may be the only realistic resolution to the uncontrolled spread of Internet gambling throughout the U.S.
This paper addresses the practicality of Internet gambling legislation. Part I of provides a brief background of the Internet gambling industry, from a novel concept in 1995 to a multi-billion dollar industry in 2003. It also discusses the primary concerns of the United States government. Part II examines the current U.S. laws as they apply to Internet gambling. Primarily, this involves the Wire Act,[5] the only current federal criminal law applied to Internet casinos.[6] Part III analyzes the structure and practicality of proposed legislation in the United States, with emphasis on the goals of said legislation. Part IV proposes a solution to the United State’s dilemma. Perhaps, given the globalized nature of the Internet and constantly evolving technology, the United States government would benefit from embracing Internet gambling rather than prohibiting it.
I. Background
In August 1995, Interactive Casinos, Inc. opened the first online casino.[7] The site hosted eighteen different games, sports betting and online access to the National Indian Lottery.[8] The entrepreneurial opportunities presented by the Internet corresponded with the opportunistic nature of gamblers.[9] In the following years, Internet gambling grew exponentially.[10] From 1997 to 1998 alone, the number of Internet gamblers increased from 6.9 million to 14.5 million. [11] Revenues soared from estimates of $300 million to $651 million. Other studies found the revenues to be at about $919.1 million.[12] Estimates for 2003 are currently between $4.2 and 6 billion, and account for approximately 4.3 percent of business-to-consumer e-commerce.[13] Over half of that revenue is attributable to U.S. citizens.[14]
Meanwhile, the United States Congress has seen a multitude of proposed legislation regarding Internet gambling.[15] The U.S. government’s major concerns are fourfold.[16] First, Internet gambling can provide an outlet for underage gamblers.[17] Second, pathological gamblers, also known as problem gamblers, will be hurt by the immediate availability and lack of controls afforded by Internet casinos.[18] Third, Internet casinos could be rigged or otherwise unfair to consumers.[19] Fourth, Internet casinos may be a tool for money laundering or other criminal abuse.[20] These issues inherent in the Internet casino industry are problematic. A solution is needed that will protect American consumers and provide the United States government with some control over the worldwide phenomenon. However, Congress’s legislation prohibiting Internet gambling, while noble, may be unrealistic, given the borderless nature of the Internet and the constantly evolving technology involved.[21] Rather, regulation through licensing may impart control over the quality and policies of Internet casinos while providing tax dollars to the U.S. government.
II. Current Legislation
Traditionally, gambling in the United States is legislated by both state and federal law.[22] While states generally determine whether its citizens can gamble within their borders, the federal government has supplemented state law with laws that prevent interstate or international gambling.[23] Therefore, Congress is the foremost arena to address Internet gambling.
A. Federal Legislation
The United States government could prohibit or prevent Internet gambling in two ways.[24] First, existing laws could be applied to Internet casinos.[25] Second, new laws could be enacted to address Internet gambling directly.[26] Given the current legal framework in regards to gambling, the latter is preferable. Even so, it is crucial to examine the current laws to determine their defects as applied to Internet casinos.
While there are three laws that could conceivably be applicable to Internet gambling, the Wire Act[27] has been the only law applied in federal prosecutions.[28] The Wire Act provides criminal fines and incarceration for entities engaged in a gambling business that use a “wire communication facility” for the transmission of bets “on any sporting event or contest.”[29] While some courts have held that the Wire Act applies to Internet gambling,[30] other courts have questioned its applicability.[31] Those who oppose the application of the Wire Act have looked to three major points: (1) the Wire Act implies that it is applicable only to sports betting, (2) the use of the Internet may not be considered a “wire transaction” as traditionally contemplated, and (3) future technology may entirely eliminate the use of wires when connecting to the Internet.[32] Practically speaking, the Wire Act and other anti-gambling laws have an additional failing. Since such laws apply only to gambling businesses, they cannot effectively deter U.S. citizens from using Internet casinos.[33] Rather than stemming Internet gambling, the current law merely encourages the use of Internet casinos owned and operated by foreign companies and subsidiaries.[34] Clearly, such an effect is not ideal if the U.S.’s primary concern is the welfare of its citizens.
B. State Legislation
States have tackled Internet gambling in a variety of ways. Most states have no laws specific to Internet gambling, and will therefore likely seek to apply existing laws to the industry.[35] However, a select few have enacted legislation particularly tailored to address Internet gambling.[36] An exemplary contrast is evident between the legislation enacted in Nevada[37] and the application of existing law in New York.[38]
In 2001, the Nevada legislature passed Nevada Statute 483.750.[39] The law provided the Nevada Gaming Commission with the power to license online casinos and manufacturers of online casino technology.[40] Acknowledging the still-developing nature of the industry, Nevada lawmakers required that such licensing only occur after meeting three requisite conditions: (1) that Internet casinos comply with all applicable gambling laws, (2) that the sites be secure and reliable and would reasonably assure that users are of legal age and are in a jurisdiction in which gambling is legal, and (3) that the Internet casinos foster the stability and success of gaming.[41]
While the Nevada law is effectively inconsequential until Internet gaming meets the aforementioned prerequisites, it is an example of how a local or national government could use Internet gambling to its and its citizens’ benefit. Under the Nevada law, all Internet casinos would pay the licensing fees paid by traditional Nevada casinos.[42] This includes a fee of three and one-half and six and three-quarter percent of all revenues for online casinos paid monthly, in addition to general licensing fees.[43] The statute goes further by requiring licenses for the manufacture of Internet gaming hardware, software and equipment.[44] Such measures can ensure that consumers are receiving “fair odds” and are using reliable software when playing at Internet casinos.
On the other side of the spectrum, New York has applied its current laws in an effort to ban Internet gambling entirely.[45] In a landmark case, People v. World Interactive Gaming Corp., a New York court applied existing local and federal law against an Internet casino located in Antigua.[46] The New York court determined that it had the authority to enjoin and request restitution from the Delaware corporation that wholly owned the Antiguan subsidiary.[47] While the case is a success for Internet gaming opponents, it is a minor one at best. The New York court successfully applied existing anti-gambling laws to an Internet casino.[48] However, had the casino been operated wholly by the subsidiary or a foreign corporation, the casino’s assets would be free from the court’s reaches.[49] Therefore, the decision only encourages U.S. companies seeking entry into the Internet gambling industry to set up foreign subsidiaries or corporations that exist apart from their U.S. counterparts.
III. Proposed Legislation
According to legislation proposed over the past six years, the government’s main goal has been to curb the ills associated with Internet gambling by prohibiting Internet gambling in the United States.[50] The proposed legislation has sought to do this through two major avenues: by limiting U.S. citizens’ ability to use bank instruments to participate in Internet gambling,[51] and by creating laws that unequivocally prohibit Internet gambling.[52] In recent years, a third possibility has emerged: the creation of a commission to study the possibility of licensing and regulating Internet gambling.[53] While the bill received little to no attention from Congress,[54] it may be the only way for the U.S. to have any significant impact on the Internet gambling industry.
A. The Unlawful Internet Gambling Funding Prohibition Act
The Unlawful Internet Gambling Funding Prohibition Act[55] seeks to prevent U.S. citizens from using Internet casinos by prohibiting gambling businesses from knowingly accepting bank instruments, including checks, credit cards, and electronic fund transfers, for illegal Internet gambling.[56] Paradoxically, while the bill has yet to become law, most financial institutions have already blocked funding to Internet casinos.[57] Their voluntary prohibition is likely caused by fear.[58] Some online gamblers seeking to escape debt have sued the banking institutions for their involvement in supplying access to Internet casinos.[59] While few claims have brought and even fewer won, their impact on the banking industry is clear.[60] Perhaps the biggest reason for the fear is the types of claims brought.[61] Rather than an innocuous claim of breach of contract, claimants have raised the stakes in online gambling funding by claiming that banking institutions involved in Internet gambling funding are in violation of the RICO Act.[62]
The banking industry’s voluntary ban on funding Internet gambling has effectively mirrored the Unlawful Internet Gambling Funding Prohibition Act. The United States even suggests that the pressure placed on the institutions has had a positive effect on the war on Internet gambling.[63] According to gaming analysts, the industry growth has slowed from estimated revenue of $5 billion in 2003 to only $4.2 billion.[64] Meanwhile, opponents of the legislation believe that prohibiting the use of bank instruments will merely move users to find alternative access to funding.[65] The concerns are legitimate, given the alternatives already developed, including personal payment account services, online money transfer services, virtual debit cards, and even telephone billing services.[66]
B. The Comprehensive Gaming Prohibition Act
The Comprehensive Internet Gaming Prohibition Act of 2002 (hereinafter, the “CIGPA”)[67] exemplifies the second prong of attack initiated by Congress. The CIGPA directly declares Internet gambling illegal by amending provisions of the Wire Act to address the emerging technology.[68] References to wire communication would be amended to apply to any interstate or international communication. This would avoid any claims that the Internet does not constitute a traditional wire communication. It would also eliminate concerns that new wireless Internet technology would be beyond the Wire Act’s scope. The CIPGA also expands the Wire Act to include all games of chance.[69] Therefore, as amended, the Wire Act would apply to casino games as well as its traditional application to sporting events.[70]
Opponents believe that prohibiting Internet gambling in the United States will only drive the industry underground. Congressman John Conyers, a proponent of regulation and licensing of the industry, likened the current proposed laws to the 1920’s prohibition era.[71] According to Conyers, the prohibition of Internet gambling in order to fight crime and protect children and problem gamblers will have the opposite effect.[72] Underground casino operators will emerge in locations outside of the reach of U.S. officials.[73] By forfeiting the industry to the unscrupulous, criminals will thrive and problem gamblers and children will have no protection at all.[74]
C. House of Representatives Bill 5760
Conyers’ analysis of the Internet gambling problem led him to introduce House bill 5760.[75] The bill as proposed would create a commission to study the Internet gambling industry and create alternatives to prohibition, namely licensing and regulation.[76] If enacted, Conyers’ bill would mark a shift from the prohibitionist position that Congress has taken since the mid-1990s. This would be a crucial change if the U.S. government wants to control Internet gambling. Additionally, it would bring U.S. policy in line with its citizens.[77] According to a study released by the Interactive Gaming Council[78] and conducted by First International Resources, 55% of Americans would welcome government efforts to legalize online casinos.[79] 68% would prefer legalization or the status quo to an absolute prohibition.[80] 60% feel that prohibition would lead to further restrictions of the Internet.[81]
Legislation aimed at licensing and regulation would also bring U.S. policy in line with much of the world.[82] While some nations like Australia have actively prohibited Internet gambling, over fifty nations and foreign jurisdictions have passed legislation legalizing the industry.[83] International dissent has even led Antigua and Barbuda to file a complaint with the World Trade Organization that states that the United States is in violation of international trade accords.[84] According to Antigua and Barbuda, the United States permits gambling by domestic entities within its borders, but is seeking to prevent foreign entities from providing similar services.[85] The United States has replied that online gambling services are not within their trade commitments and are a haven for money laundering and terrorist funding.[86] Several nations, including Taiwan, Mexico, Canada and the EU states, have reserved their right to join the dispute on the side of Antigua and Barbuda.[87]
IV. A Practical Solution to the Internet Gambling Problem
Unfortunately, Congressman Conyers’ legislation has been given little consideration by the House of Representative’s leadership.[88] Regardless, Congress’s current efforts will likely be ineffective once realized.[89] Legalization, licensing, and regulation would provide an alternative that would provide tax revenue for the government, fairness to U.S. citizens and protection for vulnerable parties.[90] Regulation would address all of the U.S. government’s four major concerns, underage gamblers, problem gamblers, unfair practices, and money laundering.[91]
The government should protect underage gamblers through already established identity-verification methods.[92] Congress has previously acknowledged, when passing the Children’s Online Protection Act, that credit cards can protect minors from the Internet.[93] Therefore, credit cards should be mandatory, rather than banned under the Unlawful Internet Gambling Funding Prohibition Act.[94] Alternatively, Internet casinos should be required to identify players’ identities through crosschecking multiple forms of identification, such as a driver’s license, a credit card, and a utility bill.[95] Companies like eBay have required users to verify the amount and dates of their first two deposits in their account in order to prevent unauthorized users.[96] Finally, the U.S. could mimic the Australian e-lottery, which requires that online gamblers purchase access codes in person, thereby providing an opportunity to check the user’s identification.[97]
Problem gamblers may prove to be a more difficult problem. The Australian online gaming industry has kept a list of problem gamblers that effectively blacklists those parties.[98] While the procedure prevents problem gamblers access, in the United States such a list would cause privacy concerns.[99] Alternatively, Congress could pass financial limits to an individual’s gambling.[100] If all U.S.-licensed sites shared such financial information, problem gamblers could be identified and referred to appropriate organizations.[101]
Congress can tackle the issue of unfair Internet casinos through legislation that mimics Nevada’s Internet gambling legislation.[102] According to Nevada’s law, all software and hardware manufacturers will be subject to licensing. Provisions in the U.S. version could detail the auditing of software to ensure set odds. In turn, the licensed websites would drive out unfair competitors.[103]
Congress’s concern regarding money laundering would also be served by legitimizing Internet casinos. Law enforcement officials have attributed the low number of prosecutions to the lack of industry regulations and oversight.[104] If Congress decides to pass the Unlawful Internet Gambling Funding Prohibition Act, gamblers will be encouraged to pay through offshore accounts and cash.[105] These anonymous forms of payment will only add to the potential for money laundering. Rather, the United States should follow Nevada’s Internet gambling legislation. Strict State oversight and open bookkeeping would serve as an effective deterrent to illegal activity.[106]
The failure of Congress’s current prohibitionist policy, the amorphous nature of the Internet, and the continual spread of Internet gambling, particularly in the United States, requires a new course of action. If the United States government is to have any significant effect on the Internet gambling industry, legislation must be passed that establishes a framework for the legalization, licensing, and regulation of Internet casinos. The U.S. government, in return, would be able to tax the earnings attributable to U.S. citizens. Player identity verification methods should be mandatory, as it can serve to identify U.S. customers, underage players, and problem gamblers. The legislation should also provide for some form of additional auditing powers. This would effectively allow the government to identify and eliminate money laundering and other computer-related crimes. Through a licensing program that includes manufacturers and maintenance of gambling software and hardware, the U.S. government could ensure that Internet casinos were giving fair odds to customers. While some sites owned and operated by unscrupulous parties may offer Internet gambling to U.S. customers without a license, legitimate Internet casinos seeking U.S. customers would benefit greatly from the legislation. The license would serve as a seal of approval by the U.S. government, which would signal to customers that the website offered secure transactions and fair odds.
Internet gambling is inevitable. The nature of the Internet combined with the entrepreneurial spirit common to the gambling industry has led to the growth of the Internet gambling industry from one casino in 1995 to an industry made up of over 1700 casinos.[107] The industry is expected to make between $4.2 and 6 billion in revenue in 2003.[108] Given the reality of the industry, the United States government must protect its citizens by the only practical means, licensing and regulation.
[1] The Internet Gambling Act of 1997: Hearing on S. 474 Before the Subcomm. on Technology, Terrorism, and Government Information on the Judiciary, 105th Cong. 1 (1997).
[2] See Internet Gambling Prohibition Act of 1997, S. 474, 105th Cong. (1997); Internet Gambling Prohibition Act of 1997, H.R. 2380, 105th Cong. (1997); Internet Gambling Prohibition Act of 1999, S. 692, 106th Cong. (1999); Internet Gambling Prohibition Act of 1999, H.R. 3125, 106th Cong. (1999); Unlawful Internet Gambling Funding Prohibition Act, H.R. 556, 107th Cong. (2002); Comprehensive Internet Gambling Prohibition Act S. 3006, 107th Cong. (2002); H.R. 5760, 107th Cong. (2002).
[3] See United States General Accounting Office, Internet Gambling: An Overview of the Issues, GAO-03-89, 1 (December 2, 2002).
[4] Id. at 6.
[5] 18 U.S.C. 1084.
[6] United States General Accounting Office, supra note 3, at 12.
[7] R. Scott Girdwood, Place Your Bets…On the Keyboard: Are Internet Casinos Legal?, 25 Campbell L. Rev. 135, 135 (2002).
[8] Id.
[9] See Joel Michael Schwartz, The Internet Gambling Fallacy Craps Out, 14 Berkeley Tech. L.J. 1021, 1070 (1999).
[10] Girwood, supra note 7, at 135-36.
[11] Edward M. Yures, Gambling on the Internet: The States Risk Playing Economic Roulette as the Internet Gambling Industry Soars Onward, 28 Rutgers Computer & Tech L.J. 193, 196 (2002).
[12] Id.
[13] See United States General Accounting Office, supra note 3, at 4, 6.
[14] Id. at 6.
[15] See Unlawful Internet Gambling Funding Prohibition Act, H.R. 556, 107th Cong. (2002); Comprehensive Internet Gambling Prohibition Act S. 3006, 107th Cong. (2002); H.R. 5760, 107th Cong. (2002).
[16] See United States General Accounting Office, supra note 3, at 2.
[17] Id.
[18] Id.
[19] Id.
[20] Id.
[21] See id. at 3.
[22] Id. at 11.
[23] Id.
[24] Fridolin M.R. Walther, Internet Gambling Related Regulatory Questions and Enforcement Problems: A Comparative U.S.-Swiss Perspective, 2000 Stan. Tech. L. Rev. 3, I (2000).
[25] Id.
[26] Id.
[27] Wire Act, 18 U.S.C. § 1084 (1994).
[28] United States General Accounting Office, supra note 3, at 12. The other two applicable laws are the Travel Act, 18 U.S.C. § 1952 (2002), and the Illegal Gambling Business Act, 18 U.S.C. § 1955 (2002).
[29] Wire Act, 18 U.S.C. § 1084(a).
[30] See People v. World Interactive Gaming Corp., 185 Misc. 2d 852, 714 N.Y.S.2d 844 (1999).
[31] United States General Accounting Office, supra note 3, at 12.
[32] Id.
[33] See Yures, supra note 11, at 211-12.
[34] Id.
[35] See People v. World Interactive Gaming Corp., 185 Misc. 2d 852, 714 N.Y.S.2d 844 (1999); see United States General Accounting Office, supra note 3, at 16.
[36] See United States General Accounting Office, supra note 3, at 16. Only five states have laws specific to Internet gambling: Illinois, Louisiana, Nevada, Oregon, and South Dakota. Id.
[37] Nev. Rev. Stat. 463.750 (2001).
[38] See People v. World Interactive Gaming Corp., 185 Misc. 2d 852, 714 N.Y.S.2d 844 (1999).
[39] Nev. Rev. Stat. 463.750 (2001).
[40] Id. 463.750(1).
[41] Id. 463.750(2)(a-c).
[42] Id. 463.750(2)(d).
[43] Nev. Rev. Stat. 463.370(1)-(2) (2003), amended by 2003 Nev. Laws 20th Spec. Sess. Ch. 5.
[44] Nev. Rev. Stat. 463.750(3)(b)(1-2) (2001).
[45] People v. World Interactive Gaming Corp., 185 Misc. 2d 852, 714 N.Y.S.2d 844 (1999).
[46] Id.
[47] Id. at 863, 854.
[48] Id. at 860, 851.
[49] See id. at 859, 850 (stating that the Delaware entity completely dominates the Antiguan subsidiary, which permits New York to ignore the corporate form and hold the Delaware corporation liable).
[50] See Internet Gambling Prohibition Act of 1997, S. 474, 105th Cong. (1997); Internet Gambling Prohibition Act of 1997, H.R. 2380, 105th Cong. (1997); Internet Gambling Prohibition Act of 1999, S. 692, 106th Cong. (1999); Internet Gambling Prohibition Act of 1999, H.R. 3125, 106th Cong. (1999); Unlawful Internet Gambling Funding Prohibition Act, H.R. 556, 107th Cong. (2002); Comprehensive Internet Gambling Prohibition Act S. 3006, 107th Cong. (2002); H.R. 5760, 107th Cong. (2002).
[51] See Unlawful Internet Gambling Funding Prohibition Act, H.R. 556, 107th Cong. (2002) (prohibiting any person engaged in a gambling business from accepting bank instruments).
[52] See Comprehensive Internet Gambling Prohibition Act, S. 3006, 107th Cong. (2002) (amending the Wire Act to include the use of all communication facilities and all gambling activities).
[53] H.R. 5760, 107th Cong. (2002).
[54] Americans Oppose Ban to Internet Gambling, PRNewswire, April 29, 2003 available at www.onlinecasinonews.com
[55] Unlawful Internet Gambling Funding Prohibition Act, H.R. 556, 107th Cong. (2002).
[56] Id. at § 3(a)(1-4)
[57] United States General Accounting Office, supra note 3, at 24.
[58] I. Nelson Rose, Why Visa is Dropping Online Gambling, Online Casino News, October 21, 2003 at www.onlinecasinonews.com.
[59] In re Mastercard Int’l Inc., 313 F.3d 257 (5th Cir. 2002); I. Nelson Rose, supra note 58.
[60] See id.
[61] I. Nelson Rose, supra note 58.
[62] See In re Mastercard Int’l Inc., 313 F.3d 257; I. Nelson Rose, supra note 58. RICO stands for the Racketeer Influenced Corrupt Organizations Act. 18 U.S.C. §§ 1961-1968 (2000).
[63] United States General Accounting Office, supra note 3, at 4.
[64] Id.
[65] See Title Introduction of Internet Gambling Licensing and Regulation Commission Act, 108th Cong., Vol. 149, No. 40 (March 12, 2003); United States General Accounting Office, supra note 3, at 33-34.
[66] Peak Online Casino Group Announces New Payment Options, Online Casino News, December 17, 2002 at www.onlinecasinonews.com.
[67] Comprehensive Internet Gambling Prohibition Act of 2002, S. 3006, 107th Cong. (2002).
[68] Id.
[69] Id.
[70] Id.
[71] Title Introduction of Internet Gambling Licensing and Regulation Commission Act, supra note 65.
[72] Id.
[73] Id.
[74] Id.
[75] See id.
[76] H.R. 5760, 107th Cong. (2002).
[77] See Press Release, Interactive Gaming Council, Passed: Unlawful Internet Gambling Funding Act (June 12, 2003), available at www.onlinecasinonews.com (citing a national poll that stated that 68% of American adults preferred either the status quo or licensing and regulation to an absolute prohibition on Internet gambling).
[78] The Interactive Gaming Council is the leading trade association for the international interactive gambling industry. Id.
[79] Americans Oppose Ban to Internet Gambling, supra note 54.
[80] Id.
[81] Id.
[82] United States General Accounting Office, supra note 3, at 17 (stating that over 50 countries and foreign jurisdictions have legalized Internet gambling).
[83] United States General Accounting Office, supra note 3, at 17-18.
[84] Lawrence G. Walters, The Caribbean Presses On, Online Casino News, September 16, 2003 at www.onlinecasinonews.com. Antigua and Barbuda rely on income and jobs generated from online casinos as a means to reduce their dependence on the volatile tourism industry. U.S. Internet Gambling Crackdown Sparks WTO Complaint, Online Casino News, July 23, 2003 at www.onlinecasinonews.com.
[85] Walters, supra note 84.
[86] U.S. Internet Gambling Crackdown Sparks WTO Complaint, supra note 84.
[87] Id.
[88] Press Release, Interactive Gaming Council, supra note 76.
[89] See Title Introduction of Internet Gambling Licensing and Regulation Commission Act, supra note 65; Yures, supra note 11, at 226;; R. Scott Girdwood, supra note 7, at 150.
[90] Title Introduction of Internet Gambling Licensing and Regulation Commission Act, supra note 65.
[91] Id.
[92] Kevin Ferguson, Privacy Concerns Arise in Internet Gambling Review, Las Vegas Sun, August 1, 2001.
[93] Title Introduction of Internet Gambling Licensing and Regulation Commission Act, supra note 65.
[94] See Unlawful Internet Gambling Funding Prohibition Act, H.R. 556, 107th Cong. (2002); Title Introduction of Internet Gambling Licensing and Regulation Commission Act, supra note 65.
[95] Kevin Ferguson, supra note 92.
[96] Id.
[97] Id.
[98] Id.
[99] Id.
[100] Title Introduction of Internet Gambling Licensing and Regulation Commission Act, supra note 65.
[101] Id.
[102] See Nev. Rev. Stat. 463.750 (2001).
[103] Title Introduction of Internet Gambling Licensing and Regulation Commission Act, supra note 65.
[104] See United States General Accounting Office, supra note 3, at 35.
[105] See Title Introduction of Internet Gambling Licensing and Regulation Commission Act, supra note 65.
[106] See id.
[107] R. Scott Girdwood, supra note 7, at 135; United States General Accounting Office, supra note 3, at 51.
[108] United States General Accounting Office, supra note 3, at 4, 6.
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