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9/2/20  11:37 am
Commenter: Penn National Gaming, Inc., and Penn Interactive

PIV Comments/Suggested Edits - 11 VAC 5-70-10 - Definitions (A-L)

“Affiliate” means a person that, directly or indirectly, through 1 or more intermediaries, controls or is controlled by an internet gaming operator.[1]

[1] We respectfully recommend defining “Affiliate” to provide clarity on what entities or persons are included in the definition as it relates to Permit Applications.


“Affiliate Marketer” means entities and individuals involved in promoting, marketing, and directing business to online gaming sites, on their own behalf, and who have an agreement to be compensated by a permit holder based on: the number of successful registrations, the number of successful registrations to make a deposit, or a sharing in adjusted gross revenue.[1]

[1] For clarity of permit holders, we respectfully recommend defining “Affiliate Marketer” in the rules as provided. We have provided a suggested definition, that is consistent with industry standard.


“Annual permit application period” means the period occurring annually when the Department will accept sports betting permit applications. The renewal annual permit application period shall begin May 15 and end May 31 at 11:59:59 PM.[1]

[1] As permits are issued for three (3) year periods, we respectfully recommend providing clarity around renewal, which would be every three (3) years rather than an annual permit, which would be every one (1) year.

CommentID: 84366