BILL ANALYSIS Ķ
AB 431
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Date of Hearing: April 27, 2015
ASSEMBLY COMMITTEE ON GOVERNMENTAL ORGANIZATION
Adam Gray, Chair
AB 431
(Gray) - As Introduced February 19, 2015
SUBJECT: Gambling: Internet poker
SUMMARY: Would authorize the operation of an Internet poker
Web site within the borders of the state. The bill would
require the California Gambling Control Commission (CGCC), in
consultation with the California Department of Justice's Bureau
of Gambling Control (Bureau), to promulgate regulations for
intrastate Internet poker. Specifically, this bill:
1) Provides an Internet poker Web site authorized pursuant to
this bill may be operated within the borders of the state in
accordance with all applicable laws and regulations, including,
but not limited to, the Unlawful Internet Gambling Enforcement
Act of 2006.
2) Provides for purposes of this bill, the following
definitions apply:
(a) "Commission" means the California Gambling Control
Commission.
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(b) "Department" means the Department of Justice.
3) Provides the CGCC, in consultation with the Bureau, shall
promulgate regulations for intrastate Internet poker. These
regulations shall include, but not be limited to, both of the
following:
(a) A licensing process for an individual or entity to become
an operator of an Internet poker Web site.
(b) Rules for the operation of an Internet poker Web site.
4) Makes legislative findings and declarations.
EXISTING LAW:
1) In 2000, Californians approved Proposition 1A which amended
Article IV, Section 19 of the State Constitution to allow slot
machines, lottery games, and banking card games on Indian tribal
lands if: (1) the Governor and an Indian tribe reach agreement
on a compact; (2) the Legislature approves the compact; and (3)
the federal government approves the compact. Proposition 1A was
a follow-up to a court's determination that a 1998 statutory
initiative authorizing tribal casinos (Proposition 5) was
unconstitutional. The State of California has signed and
ratified Tribal-State Gaming Compacts with 72 Tribes and there
are Secretarial Procedures in effect with one Tribe. There are
currently 60 casinos operated by 58 Tribes.
2) Existing federal law, the Federal Indian Gaming Regulatory
Act (IGRA) of 1988, established the jurisdictional framework
that presently governs Indian gaming. Under IGRA, before a tribe
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may lawfully conduct class III gaming (games commonly played at
casinos, such as slot machines and black jack), the following
conditions must be met: (1) The particular form of class III
gaming must be permitted in the state; (2) The tribe and the
state must have negotiated a compact that has been approved by
the Secretary of the Interior; and (3) The tribe must have
adopted a tribal gaming ordinance that has been approved by the
chairman of the National Indian Gaming Commission.
3) In 1984, California voters passed Proposition 37, an
exception to the State Constitution prohibition against
lotteries. Proposition 37 included the California Lottery Act
and created the California State Lottery.
4) In 1933, California voters passed Proposition 5, an
exception to the State Constitution, legalizing pari-mutuel
wagering on horse racing. Regulation of horse racing is the
responsibility of the California Horse Racing Board, which was
established by the Legislature in 1933.
6) Authorizes and defines "Advance Deposit Wagering" as a form
of pari-mutuel horse wagering in which a person "establishes an
account with a board-approved betting system or wagering hub
where the account owner provides 'wagering instructions'
authorizing the entity holding the account to place wagers on
the owner's behalf via the phone or Internet.
5) Provides an exception to the California Constitution to
allow the Legislature to authorize cities and counties to
provide for charitable bingo games. (Cal. Const. art. IV, §§
19(b), 19(c).)
7) The Gambling Control Act of 1997 established the CGCC to
regulate legal gaming in California and the Bureau of Gambling
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Control within the Department of Justice (DOJ) to investigate
and enforce controlled gambling activities in California. It
prohibits gambling in a city or county that does not have an
ordinance governing certain aspects of the operation of gambling
establishments, including the "hours of operation" of gambling
establishments. The Act granted the CGCC licensing jurisdiction
over the operation of card clubs and of all persons having an
interest in the ownership or operation of card clubs.
8) Provides that, until January 1, 2020, if a local
jurisdiction had not authorized legal gaming within its
boundaries prior to January 1, 1996, then it is prohibited from
authorizing legal gaming. Furthermore, until January 1, 2020,
the California Gambling Commission is prohibited from issuing a
gambling license for a gambling establishment that was not
licensed to operate on December 31, 1999, unless an application
to operate that establishment was on file with the division
prior to September 1, 2000.
9) Provides "Gambling operation" means exposing for play one or
more controlled games that are dealt, operated, carried on,
conducted, or maintained for commercial gain.
10) Authorizes a licensed gambling establishment to contract
with a third party for the purpose of providing proposition
player services.
11) Provides that a "banking game" or "banked game" does not
include a controlled game if the published rules of the game
feature a player-dealer position and provides that this position
must be continuously and systematically rotated amongst each of
the participants during the play of the game.
12) Existing federal law, the Unlawful Internet Gaming
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Enforcement Act of 2006 (UIGEA), prevents U.S. financial
institutions from processing payments to online gambling
businesses. The UIGEA does exempt three categories of
transactions: intra-tribal, intrastate, and interstate horse
racing. The UIGEA defines intrastate transactions are bets or
wagers that are made exclusively within a single state, whose
state laws or regulations contain certain safeguards regarding
such transactions, expressly authorize the bet or wager and the
method by which the bet or wager is made, and do not violate any
provisions of applicable federal gaming statues.
FISCAL EFFECT: Unknown
COMMENTS:
Purpose of the bill : For over a century, gambling in California
was confined to horse racing tracks and card rooms. Then, the
California Lottery was authorized in 1984 and, through a series
of federal court cases, changes in federal law, and Proposition
5 and 1A-casino gambling on Native American tribal lands emerged
in the last decade of the 20th century. Now it appears that the
Internet might be the next phase of gambling expansion in
California.
The author states, in addition, to countless meetings held among
the various stakeholders and interested parties, both supporting
and opposing the concept of Internet gaming, the Legislature has
held numerous hearings and taken hours of testimony over the
past 7+ years on the issues and challenges surrounding the
authorization of intrastate Internet gaming in California. On
April 23, 2014, the Assembly Governmental Organization Committee
held a lengthy informational hearing titled "The Future Public
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Policy and Fiscal Implications of Authorizing iPoker Gaming in
California." These hearings have helped to identify problems
and solutions that have narrowed the differences among various
stakeholders, but, to date, no vote has ever been recorded on
this issue in a legislative committee.
The author emphasizes that although various stakeholders and
interested parties have different views relating to the
legalization of iPoker in California, those entities have worked
together in good faith toward the possible development of a
regulatory framework.
It has been reported that well over a million Californians are
playing Internet poker on Web sites run by offshore companies
that are not regulated or licensed by any U.S. government entity
- these poker players are at the mercy of unscrupulous operators
who may cheat them out of their money with absolutely no
recourse. As a result, Californians who play poker on these
websites have no way of protecting sensitive personal
information when they use their credit card or provide other
financial information to such a site. In addition, hundreds of
millions of dollars are leaving the California economy, money
(and tax revenues) that could stay in the state if intrastate
iPoker was legalized in California.
The author states, the intent of this bill is to assist the
California Legislature to further consider a legislative
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framework to authorize qualified entities, which are to be
determined, to operate intrastate Internet Poker.
The framework shall extend consumer protections to Californians
who play online poker, ensure that the revenues from online
poker are realized in California, and protect the public
interest by ensuring that the various aspects of online poker
are sanctioned and regulated by the state. The framework shall
take into consideration the negative impacts of gambling, and
spur a new industry in California which will provide economic
inducements to California's economy, including job creation.
Furthermore, the framework shall include strict standards to
ensure that the online poker games are fair, played by persons
of legal age who are located in California, and using advanced
technologies to identify and restrict access by minors.
The author states that any iPoker legislative proposal must
include a strong regulatory framework that protects Californians
and cracks down on illegal online gaming, replacing it with
safeguards against compulsive gambling, money laundering, fraud,
and identity theft. In addition, the framework should also
consider licensing, enforcement, regulatory authority, and
taxation.
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The author concludes that the goal of this measure is to further
explore how a well-regulated iPoker framework can be developed
in California that will be used as a national model for creating
jobs and revenue for the state while providing a safe,
regulated, and responsible entertainment option for its
residents.
General Background : The global legal framework for Internet
gambling is a complicated mix of laws and regulations. In the
United States, both federal and state statutes apply. Gambling
is generally regulated at the state level, with federal law
supporting state laws and regulations to ensure that interstate
and foreign commerce do not circumvent them.
In October 2006, the United States Congress passed the Unlawful
Internet Gambling Enforcement Act (UIGEA), 31 U.S.C. 5361 et
seq., which generally prohibits the use of banking instruments,
including credit cards, checks, and fund transfers, for
interstate Internet gambling, essentially prohibiting online
gambling by United States citizens, but which includes
exceptions that permit individual states to create a regulatory
framework to enable intrastate Internet gambling, provided that
the bets or wagers are made exclusively within a single state
under specified circumstances.
In summary, federal law prohibits online gambling by U.S.
citizens but includes specific provisions that allow individual
states to offer intrastate Internet gaming, provided that state
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laws permitting and regulating that activity could impose
reasonable protections against participation by underage persons
or by persons located outside the boundaries of the states.
Some gaming experts say that gambling over the Internet is not
just inevitable but mainstream and readily available to anyone
desiring to partake in this activity. Recent reports state that
Americans spent approximately $2.6 billion gambling online in
2012, despite being illegal under UIGEA. Most of that money
still goes to offshore gambling websites, meaning the websites
are operated in other countries where online gambling is
regulated or non-existent. These gaming sites are out of the
reach of U.S. courts and regulators, exposing online players to
significant risks without effective legal recourse.
Many gaming experts believe that legalizing intrastate Internet
gaming could have a significant positive impact on state
revenues by redirecting gaming revenues into a domestic, legal
operation that otherwise currently go abroad. However, others
have stated this is not easy because it would take time to
establish operations, approve contracts, games, hubs, and
convince existing players to redirect their gambling to legal,
domestic sites.
In March 2015, Morgan Stanley revised its forecast for the
nationwide online betting market at $2.7 billion by 2020, down
from the $5 billion it predicted in late September 2014. The
firm cited several reasons for the reevaluation, from payment
processing and geolocation problems, to a lack of effective
marketing and the continued strength of the offshore market.
Three states - Nevada, New Jersey and Delaware - have legalized
Internet gambling, but online betting is off to a slow start.
It took in $135 million last year; Morgan Stanley initially
forecast $678 million. The firm forecasts the 2017 online
market will be $410 million, down from an initial estimate of
$1.3 billion. It predicts 15 states will legalize online
gambling by 2020, with legalization in larger states prompting
smaller ones to follow suit.
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Gambling opponents, consumer advocates and addiction researchers
warn of potentially dire consequences. They say the gaming
industry will use techniques perfected in online advertising and
marketing to target vulnerable consumers, leading to a spike in
problem gambling and, more broadly, a rise in income inequality.
As mentioned above, under federal law, states can authorize
online gambling only for residents of their states within their
state lines. So far, only three U.S. states allow licensed
online casinos and poker sites. These states are Nevada,
Delaware, and New Jersey. In all three states, a significant
portion of the established gaming interests in the states bought
into the idea that online gambling could help - not harm - their
business models. It is thought by some analysts that California
would be a key U.S. state in the legalization process.
California's Involvement in iGaming Legislation : At stated
above, under the terms of the federal Unlawful Internet Gaming
Enforcement Act, states may authorize intrastate internet poker.
California, however, currently has no such law. As such, it is
legal to play poker in Native American tribal casinos and
state-approved card clubs inside California, but not legal to
play online poker on a site that allows players from California,
other states, and other countries to wager against each other.
The effect of the federal law prohibiting interstate internet
gambling and California's lack of a law authorizing intrastate
internet gambling has been to channel players in California to
offshore sites.
Since 2008, eleven legislative proposals have been introduced in
California in an attempt to change the nature of Internet
gambling. Each bill was referred to the respective Governmental
Organization Committee in each house but no testimony or vote
was ever taken on the issue.
On-line Poker Revenue Projections for California : Gaming
experts state that if iPoker was legalized in California, the
state would benefit financially in three main ways: taxes paid
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on operator revenues and profits, income taxes from player
winnings, and taxes paid by suppliers and employees of gaming
sites. The largest revenue source would be from site operators
who would pay fees based on Gross Gaming Revenues (GGR). GGR
consists of total wagers made by customers less the winnings
paid back to its customers, and a tax rate is applied on the
base.
A forecast by Morgan Stanley stated that given California's
population of 38 million people (vs. NJ's 8 million), "we expect
the market to reach $1.1B by 2017." Morgan Stanley estimates
that the online poker market in California will be approximately
$435 million in Year 1, growing to $1.1 billion by Year 3.
A study published by Academicon and PokerScout in December 2013
stated, if California were to legalize and regulate online
poker, the market could generate revenue between $217 million
and $263 million in its first year of operation and up to $384
million in year ten.
California's population is larger than every country in Europe
but eight and is viewed by many as possessing the needed online
poker liquidity to maintain the player base that is crucial to
ensure that such a system is successful from a monetary
standpoint.
States that have legalized Internet Gaming :
Nevada : An Internet gaming bill, AB466, was enacted in June
2001. It authorized certain commercial casinos to offer
so-called "interactive gaming." Interactive gaming, currently
limited to intrastate Internet poker, went live in April 2013
pursuant to final regulations that were promulgated in December
2011.
New Jersey : An Internet gaming bill, A2578, was enacted in
February 2013. It authorized commercial casinos to offer
so-called "Internet gaming." Internet gaming, currently limited
to intrastate Internet poker, table games and slots, went live
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in November 2013 pursuant to final regulations that were
promulgated in September 2013.
Delaware : An Internet gaming bill, HB 333, was enacted in 2012.
It authorized games, such as slots, roulette, poker and
blackjack, which are to be played on each Delaware casino's
website and controlled centrally by the Delaware Lottery.
2014 Legislative Action by States : In 2014, eight states
considered but did not enact legislation that would authorize
Internet gambling or amend existing Internet gambling statutes.
Some states, including California and New York, considered
legislation that would authorize Internet poker, only, while
others, including Pennsylvania, considered legislation that
would authorize some combination of Internet poker, table games
and slot games. The states were as follows: California,
Hawaii, Iowa, Massachusetts, Mississippi, New York, New Jersey,
and Pennsylvania.
It should be noted that California, New York and Pennsylvania,
account for roughly 22 percent of the U.S. population.
What about Federal Legislation to Regulate iGaming ? On the
federal level, proposals have been introduced to establish a
federal regulatory system for Internet gaming. Congressmen
Barney Frank (2010), Senator Harry Reid (2012), Congressman
Peter King (2013), and Congressman Joe Barton (2011 & 2013)
introduced bills which would have instituted federal regulation
of a legalized system of Internet gaming. However, all of the
bills stalled in their respective house of origin. It has been
stated that Federal regulation would provide a single,
comprehensive mechanism for consistent licensing, operation and
enforcement of U.S. Internet gambling laws.
2015 Federal Action on iGaming - The Restoration of America's
Wire Act : U.S. Representative Jason Chaffetz (R-Utah)
reintroduced a bill (HR 707) called the Restoration of America's
Wire Act (RAWA) for the 2015 Congressional session. The bill
awaits action by the House Judiciary Committee. In March 2015,
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the House Judiciary Subcommittee on Crime, Terrorism, Homeland
Security and Investigations held a hearing on RAWA. The bill is
pending before the House Judiciary Committee. The Department of
Justice's current position on the Wire Act as it applies to
online gambling is that the Wire Act only applies to "online
sports betting."
RAWA would amend provisions of the federal criminal code,
commonly known as the Federal Wire Act of 1961, to provide that
the prohibition against transmission of wagering information
shall apply to any bet or wager, or information assisting in the
placing of any bet or wager (thus making such prohibition
applicable to all types of gambling activities, including
Internet gambling. The bill is a reintroduction of previous
bills introduced by U.S. Senator Lindsey Graham (R-South
Carolina) and Congressman Jason Chaffetz (R-Utah) in March of
2014 on the same subject matter. The bills were not taken up by
either chamber before Congress adjourned.
In Support : Writing in support, the Morongo Band of Mission
Indians, San Manuel Band of Mission Indians, Commerce Casino,
Hawaiian Gardens Casino and Bicycle Casino and Amaya Inc.
states, "We strongly support authorizing online poker in
California and commit to what we understand will be a
deliberative process to develop, and ultimately approve, a bill
in 2015 to authorize iPoker and establish a safe California
market. We know that finalizing the policy that will ultimately
regulate California's online poker marketplace will not be
quick, nor will it be easy. The stagnation of the last six
years has made that obvious. But so far, 2015 has been
different. Hard lines and tough talk have morphed into open
minds and dialogue. Authorizing online poker will be good for
millions of consumers and poker players who will benefit from a
safe, regulated, commercial gaming environment where they are
protected. Every year that California fails to act not only
puts consumers at risk while playing online games from offshore
localities that provide few protections and regulations, but our
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state also loses out on collecting hundreds of millions of
dollars that can be used for essential programs like public
schools, public safety, healthcare and social services. We are
committed to putting in the hours and the time necessary to
establish a vibrant, competitive marketplace, one that provides
superior consumer protections, requires strict oversight and
regulation of licensees, and service providers, and ensures that
the state receives a reasonable return."
The California Thoroughbred Breeders Association, Thoroughbred
Owners of California and Del Mar Thoroughbred Club states, "the
Thoroughbred racing industry has enjoyed a storied and historic
history in California featuring some of the world's greatest
horses, jockeys, trainers and more than a few colorful owners
throughout the years. Thoroughbred racing generates more than
$2.5 billion dollars to the State's economy and directly or
indirectly provides more than 50,000 jobs in the Golden State.
It goes without saying that Internet poker is the most
significant legislation facing horse racing in more than a
decade. Currently, racing benefits from the exclusivity of
providing the only form of legal gambling on the Internet.
Racing views Internet Poker as a new form of gaming, which will
increase racing revenue and provide a marketing tool to create
interest in a youthful demographic, which will continue the
history of this beautiful sport. We believe passage of an
Internet poker bill which allows racing associations, card rooms
and Tribal Governments to compete equally in California will
benefit state revenues, protect consumers and underage gamblers,
protect consumer's privacy and create new job opportunities. The
Legislature must act now in order to establish a regulatory and
enforcement frame work and put a stop to illegal offshore
sites."
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The California Teamsters Public Affairs Council writes, "It is
crucial to the horse racing industry to be included, along with
Indian tribes and card clubs to be allowed to participate fully
as licensees in this emerging on-line on-line gaming market.
Our industry is currently the only industry that accepts on-line
wagers and the program, which has been in effect for five years
has proved to be critical source of revenue for our industry and
operated without any issues related to corruption or
illegality."
The horse racing industry employs thousands of workers both at
the track and in agriculture. There are many Teamsters employed
in the industry. While the horseracing industry has weathered
the storm of the growth in competition with other areas of
gaming, basic fairness demands that it be a participant in any
gaming market expansion. Horse racing deserves equal treatment
with other sectors of the gaming industry.
In opposition . Writing in opposition, the Agua Caliente Band of
Cahuilla Indians states this measure would broadly authorize
intrastate iPoker in California and require CGCC, in
consultation with the Bureau, to promulgate regulations to
enable play. Our Tribal Council supports thoughtful legislation
that does not amount to an expansion of gaming in California.
The voters have already said "no" to that. A credible bill in
our view would include substantive protections for the consumer,
including ensuring that only credible and suitable operators are
permitted to conduct iPoker in the state, and only those
entities currently allowed to offer poker in this state would be
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considered licensees.
The Barona Band of Mission Indians states, "It was our
understanding that the topic of iPoker would be pursued in a
thoughtful and deliberate manner this year - including thorough
informational hearings during which key issues and stakeholder
perspectives will be discussed. Given the complexity of the
issue and the landscape of the stakeholder interests, we believe
completion of this key step is vital to a debate that should not
be rushed."
The Pechanga Band of Luiseņo Indians writes, "Online poker
legislation is a significant public policy issue with long-term
implications for the State of California, its citizens and our
tribal governments. Although stakeholders have made a lot of
progress in building consensus on language, important issues
remain outstanding including bad actor provisions and
eligibility for licensure. Just last year, our Tribe and twelve
others support comprehensive legislation that abides by the
longstanding public policy principle of limited gaming, protects
children and the vulnerable, creates jobs for Californians,
provides additional revenues for State services and protects
both consumers and the high suitability standards of the gaming
industry from organizations that do not respect the law."
The California Coalition Against Gambling Expansion opposes this
bill stating, "This measure seeks to legalize a massive
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expansion in legal gambling in California. This bill would have
the state sanction the conversion of every smartphone into a
mobile casino, hugely impacting underage gamblers, college
students, and those with problem or pathological gambling
inclinations. The cots to California families and taxpayers
could be immense, far outweighing any possible revenues to the
state." CAGE would prefer that state officials clamp down on
illegal online gambling which is happening already before
opening up the floodgates to state-sanctioned Internet poker.
Related legislation :
AB 9 (Gatto) of 2015. This bill, which would be known as the
Internet Poker Consumer Protection Act of 2015, would establish
a framework to authorize intrastate Internet poker, as
specified. (Pending in Assembly G.O. Committee - Set for
hearing on July 8, 2015)
AB 167 (Jones-Sawyer) of 2015. This bill, which would be known
as the Internet Poker Consumer Protection Act of 2015, would
establish a framework to authorize intrastate Internet poker, as
specified. (Pending in Assembly G.O. Committee - Set for
hearing on July 8, 2015)
SB 278 (Hall) of 2015. An identical measure to AB 431 (Gray)
would authorize the operation of an Internet poker web site
within the borders of the state. SB 278 requires CGCC, in
consultation with the Bureau, to promulgate regulations for
intrastate Internet poker. SB 278 would require those
regulations to include, but not be limited to, a licensing
process for an individual or entity to become an operator of an
Internet poker Web site and rules for the operation of an
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Internet poker Web site. (Pending in Senate G.O. Committee)
Prior legislation :
AB 2291 (Jones-Sawyer) of 2013/2014 Session. Would have
authorized intrastate Internet poker, as specified. (Never
heard in Committee on Assembly G.O.)
SB 1366 (Correa) of 2013/2014 Session. Would have authorized
intrastate Internet poker, as specified. The bill would
authorize eligible entities to apply for a license to operate an
intrastate Internet poker Web site offering the play of
authorized games to players within California, as specified.
(Never heard in Committee on Senate G.O.)
SB 51 (Wright) of 2013/2014 Session. Would have authorized
intrastate Internet gambling, as specified. The bill would
authorize eligible entities to apply to CGCC for a 10-year
license to operate an intrastate Internet gambling Web site
offering the play of authorized gambling games to registered
players within California. (Never heard in Committee on Senate
G.O.)
SB 678 (Correa) of 2013/2014 Session. Would have authorized
intrastate Internet poker, as specified. The bill would have
authorize eligible entities to apply for a license to operate an
intrastate Internet poker Web site offering the play of
authorized games to players within California, as specified.
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(Never heard in Committee on Senate G.O.)
SB 1463 (Wright) of 2011-12 Session. Would have enacted the
"Internet Gambling Consumer Protection and Public-Private
Partnership Act of 2012" for the stated purpose of authorizing,
intrastate Internet gambling. (Never heard in Committee on
Senate G.O.)
SB 40 (Correa) of 2011-12 Session. Would have authorized
intrastate Internet poker, as specified. The bill required the
CGCC to adopt emergency regulations, in consultation with the
department, providing for the issuance of licenses to operate
intrastate Internet poker Web sites.
SB 45 (Wright) of 2011-12 Session. Would have established a
framework to authorize intrastate
Internet gambling, as specified. The bill would have required
the Bureau to issue a request for proposals to enter into
contracts with up to 3 hub operators, as defined, to provide
lawful Internet
gambling games to registered players in California for a period
of 20 years, as specified. (Never heard in Committee on Senate
G.O.)
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SB 1485 (Wright) of 2009-10 Session. Would have enacted the
"Internet Gambling Consumer Protection and Public-Private
Partnership Act of 2010" for the stated purpose of authorizing,
intrastate Internet gambling. (Never heard in Committee on
Senate G.O.)
AB 2026 (Levine) of 2007-08 Session. Would have authorized the
intrastate play of various Internet poker games to be offered by
licensed gambling establishments registered with CGCC.
(Never heard in Committee on Senate G.O.)
REGISTERED SUPPORT / OPPOSITION:
Support
Amaya Inc.
Bicycle Casino
California Teamsters Public Affairs Council
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California Thoroughbred Breeders Association
Commerce Casino
Del Mar Thoroughbred Club
Hawaiian Gardens Casino
Morongo Band of Mission Indians
Oak Tree Racing Association
Pala Band of Mission Indians
Rincon Band of Luiseņo Indians
San Manuel Band of Mission Indians
The Jockeys' Guild
Thoroughbred Owners of California
United Auburn Indian Community
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Opposition
Agua Caliente Band of Cahuilla Indians
Barona Band of Mission Indians
California Coalition Against Gambling Expansion
Pechanga Band of Luiseņo Indians
Viejas Band of Kumeyaay Indians
Analysis Prepared by:Eric Johnson / G.O. / (916) 319-2531