Dear Members of the Board:

I wanted to bring to your attention that one of the incorporated documents in this regulation is Robert's Rules of Poker (see 11VAC15-50-80, etc.) In Section 2 - House Policies of Robert's Rules of Poker, procedure number 28 prohibits "speaking a foreign language during a deal...." I believe this provision should not be incorporated into state regulation, whereby operators are required to enforce this rule. Enforcement of this rule would ostracize the sizeable non-native English speaking population in Virginia who would like to play Texas Hold 'Em, and may have constitutional implications. I believe this rule of "etiquette" is a holdover from a more jingoistic era from the gold rush frontier expansion era when anti-immigrant sentiment was high, and it should not be perpetuated by the Board with this incorporated rule.

What, for example, about American Sign Language for players who are hard of hearing/deaf? This raises significant issues under the ADA. What about a charitable poker game held at a community center or church serving what this rule would deem a "foreign" community? Some sources indicate that poker was actually derivative of a Persian game called "As Nas" and then popularized in the Western world and brought to America sometime in the mid-19th Century. Some sources suggest the very word "poker" is an English ization of the German game called "Pochen" or the French game "Poque."

The rules do not require that players whispering to each other in English speak loud enough that they can be heard -- but they would forbid two deaf players from signing to each other while cards are being dealt.

These regulations should not give the archaic, antiquated, and wrong-mided rule require operators to implement procedure 28, barring "foreign languages" during a deal, the force of law.

Thank you for your service to the Commonwealth,

Alex W. West, Newport News