The Casino Control Commission (“Commission”) should deny the AGA’s petition toavoid setting a dangerous precedent that would eviscerate all requirements forparticipation in the context of the Commission’s consideration of licensing applications,and would empower the AGA’s thinly veiled anti-competitive campaign against the entryof a competitor into the market.
The AGA lacks a “significant interest in the outcome” of theseproceedings.
The AGA’s petition should be rejected because it lacks a “significant interest inthe outcome” of these licensing proceedings. The AGA explains that it is engaged ingeneral gaming advocacy, including spearheading campaigns relating to responsiblegaming and corporate philanthropy, hosting a global trade show, and lobbying
Brief in Support of Petition (“Pet. Br.”) 2-4; Patterson Cert. ¶¶ 5-10. However, it neverexplains how those activities give the AGA a significant interest specifically in Rational’spetition for a license. The AGA’s claimed interest in preserving “suitability-based licensing of gamingoperations,” Pet. Br. 1, 4, 10, is irrelevant, because the integrity of the process by whichthe Division of Gaming Enforcement (“Division”) and the Commission conductsuitability-based licensing is not in doubt, or even at issue, in these proceedings. To thecontrary, Rational recognizes that New Jersey’s licensing statutes and regulations set thehighest standards in the industry and are models for other jurisdictions. This case is onlyabout fairly applying these rules to Rational’s petition. And the Division and the