7/27/2019 Re: Full Tilt Poker Claims Administration Process
2/3
that term. Some say they merely referred a friend or two and
only received a one-time bonus.Others say they never referred
anyone, nor were paid money for anyone else's play, but weremerely
recorded as affiliates by FTP in order for FTP to reimburse them
for part of their ownrake payments (commonly called a "rakeback"),
which was in effect no more than a type ofdiscount or marketing
tool offered to players by FTP. With this in mind, we hope you
canprovide some additional clarity regarding what might disqualify
someone as an "affiliate ofFTP." The full list of questions
regarding common issues players have raised (includingregarding
affiliate status) is as follows:
1. Are players you determine to have been affiliates of FTP
precluded from receiving
any funds whatsoever, or are they eligible to receive funds that
came from them being a
player (or from a time period in which they merely were a
player) rather than an
affiliate?
2. How is DOJ defining affiliate? FTP had a number of different
relationships with
players. Which, if any, of the following arrangements would
disqualify a player from
receiving remission funds:
a. Receiving referral bonuses for referring players to FTP?
b. Receiving friends and family referral bonuses?
c. Being an FTP Red Pro?
d. Signing up as an affiliate, but not taking any actions to
recruit players or
advertise FTPs services?
e. Signing up as an affiliate but not receiving any revenues
from that status?
f. Earning only de minimis revenues from affiliate activity,
e.g., under $10? $50?
Under $100?
3. Is there currently a list of persons who DOJ or GCG has
deemed to be affiliates? If
so, how can petitioners dispute being categorized as an
affiliate?
4. In FTPs final days, many players requested withdrawals from
FTP which were never
completed. For instance, some players received checks that
bounced. Other players
received nothing, but FullTilt still debited their account. What
information should
players provide to demonstrate they fall into one of these
categories? Would a
descriptive affidavit suffice?
5. FTP provided player incentives with cash value, including FTP
Points, Iron Man
Medals, un-redeemed bonuses purchased with FTP Points,
tournament entries, and
others. If any of these items were not reflected in a
petitioners final FTP balance, can
they claim their cash value for remission?
6. If a player received rakebacks, but never deposited cash with
FullTilt, is that player
eligible for a remission payment? Are rakeback amounts already
included in players
deposit balances?
7/27/2019 Re: Full Tilt Poker Claims Administration Process
3/3
7. Some players have reported making mistakes or uncovering
additional information after
submitting their online petitions. How can these users make
additions or modifications
to that petition? Must all of those modifications, if allowed,
be complete before the
November 16 deadline?
8. If a petitioner submits a petition and you later determine
that part of the amount claimed
is not warranted or accurate, will the warranted part be
approved and remitted, or will
the petitioner need somehow to appeal or resubmit their petition
for the correctedamount?
9. Will GCG resolve all disputed petitions before beginning to
make remission payments,
or will refunds begin for accounts without disputes first?
10. Is the online submission form the only way a claimant can
submit a claim for remission?
11. Once a form is submitted, may claimants make changes prior
to the November 16
deadline? If so, how can they do that?
12. How can claimants verify that GCG has received their
completed petition if they do notreceive an email acknowledging
receipt?
13. Is there any way to submit more than 10 supporting documents
to support a petition?
How should players provide additional documents to GCG?
14. Some petitioners do not have Social Security Numbers or EINs
because they are in a
unique situation where they are living in the U.S., but are not
a U.S. resident. How can
those individuals complete a form which requires entry of an SSN
or EIN?
Please let me know if we can provide further background on these
issues, the questions
members have presented, or any other aspect of these potential
claims. We welcome theopportunity to assist this process in any way
we can.
Sincerely,
John Pappas
