I read through the comments and responses issued on September 30 regarding I-gaming regulations in NJ.

The NJ DGE stated it is clear that any entity that wants to enter into a "commission based" marketing agreement with an NJ operator will be required to obtain an ancillary license:

"COMMENT: Pokertrip suggests that entities providing services relating to marketing activities using commission-based business models obtain an ancillary casino service industry enterprise license under N.J.A.C. 13:69J-1.2(d).
RESPONSE: The Division has amended N.J.A.C. 13:69J-1.2(d) to make clear that these entities will be considered ancillary casino service industry enterprises."

I've searched this doc and no 13:69J-1.2(d) is listed in it.

http://www.nj.gov/lps/ge/docs/Regula...CHAPTER69J.doc

I'm guessing it did not exist the last time that page was updated.

Any thoughts on what this means? I would guess that this means that there is no back door for affiliates in NJ. Anyone and everyone that wants a part of the action is going to have to get licensed like software and location services as opposed to being just a vendor piggybacking on a room. Is that a fair assumption?

It is hard to make too educated of a guess when that reg is not described anywhere.

Could it maybe be a typo? This section seems to cover the situation closely, unless maybe affiliates will have their own subsection.

"13:69J-1.2C - Licensing of vendors doing non-gaming business"

Also, do you assume commission based marketing includes CPA?

By the way, thank you for all of your help on this topic over the past few years.

http://www.nj.gov/oag/ge/docs/Propos...rnetgaming.pdf

I found the law in question there under proposed rules but before the affiliate language was added. It currently reads: