September 8, 2020
Amy Dilworth
General Counsel
Virginia Lottery Board
600 E. Main Street
Richmond, VA 23219
Re: NFL Comments on Proposed Regulations for Online Sports Betting
Dear Ms. Dilworth:
On behalf of the National Football League (“NFL”) and its member clubs, we appreciate the opportunity to provide feedback on the Lottery’s proposed regulations for online sports betting. We want to thank the Virginia Lottery Board for your willingness to engage with our organization to work on the future of sports betting in Virginia. As a key stakeholder and partner in the process, we appreciate your help in ensuring the integrity of our games is protected.
This letter sets forth certain suggested amendments to the proposed regulations pursuant to Virginia 2020 Session Chapters 1218 and 1256. These recommendations are intended to help further the Act’s fundamental objectives, while focusing in particular on the regulations in 11VAC5-70-190 (Use of Official League Data); 11VAC5-70-170 (Permissible Wagers); and 11VAC5-70-180 (Requests from Sports Governing Bodies), which we believe are essential to consumer protection.
Our suggestions are set forth below (in sequential order of the corresponding regulations):
Thank you again for providing us an opportunity to submit our comments. We believe the proposed regulations do a great job of addressing some of our issues and hope that you will take our suggestions into consideration to properly capture those remaining concerns. We welcome the opportunity to meet with you to discuss our concerns in greater detail. Please contact Jonathan Nabavi (Jonathan.Nabavi@nfl.com) or Marvin Yates (Marvin.Yates@nfl.com) with any questions.
[1] Tennessee Sports Gaming Rules and Regulations, Tennessee Education Lottery Corporation, https://www.tnlottery.com/sites/default/files/2020-04/TN_Rules_%26_Regulations_-_FINAL_04-15-20_0.pdf, August 21, 2020
[2] Iowa Approved Sports Wager, Iowa Racing and Gaming Commission, https://irgc.iowa.gov/sites/default/files/documents/2020/08/approved_wager_listing_080420.pdf, August 4, 2020