This legal opinion was requested and drafted in early 2008 during the final negotiations with United States Futures Exchange that closed the deal in the summer.
Here is the link:
http://thenewsportseconomy.com/wp-content/uploads/2011/01/Simulated-Trading-January-17-2008.pdf
Here is my position on this but I would like to hear from anyone else who may have comments and especially so if you are an attorney with experience in this field of practice.
This is something we really need to think about carefully. Putting up
a retail SRI simulator will be a significant driver of the educational platform.
Keep in mind that this memo was written under the Bush II regime. I think this memo is extremely conservative written during a conservative administration. Things have changed and will continue to change. New Jersey is in the process of approving an Internet gambling law aimed at residents inside the State. The climate is easing.
First, I think we can not take any money into the system. Further I think that it would be risky to award prizes based on trading outcomes. Finally, if this is to be done, we use mock team names and carefully outline the purpose of the simulator. Basically we make no indication this is to rouse the public in an effort to ram through the regulatory approval.
I disagree that we should categorically abandon a retail simulator. I think that if we position it as a demonstration tool to assist in understanding and OUR OWN development, along with using fake team names, taking no money and awarding no prizes, we will be fine. In my opinion, this is far too valuable a piece of the puzzle to abandon.
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