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2004 Connecticut Attorney General Reports and Opinions 1 (2004)

handle is hein.sag/sagct0023 and id is 1 raw text is: Attorney General's Opinion Attorney General, Richard Blumenthal January 2, 2004 Susan G. Townsley Executive Director Division of Special Revenue 555 Russell Road Newington, CT 06111 Dear Ms. Townsley: This is in response to your request for a reconsideration of a previous informal opinion, and request for a formal opinion, on whether you can give permission to Autotote Enterprises, Inc. (AEI) to install Color Tiny TIMs (CTTs) and Hand Held Personal Account Terminals (PATs) at the Mohegan Sun Race Book under the terms of the Mohegan Tribe - State of Connecticut Gaming Compact. The informal opinion held that the devices violated the moratorium on telephone betting under Sec. 15(d) of the Compact and lacked necessary standards required by Sec. 8(a) of the Compact. See Informal Opinion, Attachment A. For the following reasons, we conclude that the use of the devices within the race book do not violate the provisions of the Compact, but the devices cannot be allowed until standards are promulgated for their use under Sec. 8(a) of the Compact. The facts are as follows: Autotote Enterprises, Inc. (AEI) is the provider to the Mohegan Sun Race Book of off-track pari-mutuel wagering services through its hub at Sports Haven in New Haven. Autotote Systems, Inc. (ASI) provides totalizator computer service to Autotote Enterprises. Both AEI and ASI are wholly owned subsidiaries of Scientific Games Corporation (SGC) and both are licensees of the Division of Special Revenue. Under AEI's present agreement with the Tribe, AEI would like to install CTTs and PATs for use at the Mohegan Sun Race Book. Holders of one-day accounts at the race book would use the CTTs and PATs to enter wagers. Currently, the race book has devices called Tiny Tims (as opposed to Color Tiny TIMs), which are installed at carrels and hard-wired into the tote system. Tiny Tims are self-service machines that are used by customers who have opened a one-day account at a teller window. They allow the patron to wager from the privacy of a carrel without returning to a teller window. Like the Tiny Tims, CTTs and PATs are self-service machines. Unlike them, CTTs and PATs are wireless devices. CTTs are 2.5 x 9 x 6.5 and weight 3 pounds. According to the specs, they have a maximum range of approximately 100 feet, although both ASI and Mohegan Sun Race Book personnel believe that the range is closer to 1,000 feet. The batteries allow CTTs to be used for up to six hours on a single charge. PATs are 1 x 3-5/8 x 7 and weigh 11.8 oz. They use the Palm Operating System. They have a maximum range, in open space, of approximately 1,000 feet. This range diminishes when the signal must pass through walls. ASI tested the range of the PATs at Mohegan Sun and discovered that, with the exception of spaces around certain doors and windows, the signal is not strong enough to connect to the tote system through walls. Even in the spaces around windows and doors, the signal diminished after only a few paces. The batteries allow PATs

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