Details from the Ongoing Jay Cohen Case

16 October 1998

Jay Cohen of World Sports Exchange was charged by the U.S. government with violating 18 U.S.C. 1084(b), which prohibits interstate usage of wire communication for wagering. IGN has received a copy of the pre-trial motion filed on his behalf.

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA
-against-
JAY COHEN,
Defendant.

Indictment No.
98 CR 434 (TPG)

MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT
JAY COHEN'S PRE-TRIAL MOTIONS
 

Brafman Gilbert & Ross, P.C.
Attorneys for Defendant
JAY COHEN
767 Third Avenue, 26th Floor
New York, New York  10017
(212) 750-7800

Of Counsel:
Benjamin Brafman, Esq.
Melissa M. Beck, Esq.
Table of Contents
 

Preliminary Statement

Statement of Facts

POINT I -
THE INDICTMENT MUST BE DISMISSED BECAUSE THE DEFENDANT'S ACTS FALL SQUARELY WITHIN THE STATUTORY EXCEPTION TO PROSECUTION UNDER 18 U.S.C. § 1084(b).  THUS THE INDICTMENT FAILS TO ALLEGE A CRIME FOR WHICH THE DEFENDANT COULD BE CONVICTED AS A MATTER OF LAW.
 

A. The Defendant's Conduct Falls Squarely Within the Statutory Exception to Prosecution Under 18 U.S.C. § 1084(b) Because it is Legal to Place a bet in New York and Legal to Receive a bet in Antigua
B.  Even Assuming, Arguendo, That 18 U.S.C. § 1084(b) is not Applicable to Placing Bets, the Defendant's
Conduct Remains Squarely Within the Statutory Exception to Prosecution Under 18 U.S.C. 18 U.S.C. 1084(b) Because Information Assisting in the Placement of Bets was Transmitted From one Legal Jurisdiction to Another

POINT II -
THE INDICTMENT MUST BE DISMISSED BECAUSE THE UNITED STATES LACKS JURISDICTION OVER THE DEFENDANT'S ACTS WHICH OCCURRED WITHIN THE SOVEREIGN NATION OF ANTIGUA
 
POINT III-
THE INDICTMENT MUST BE DISMISSED BECAUSE THE DEFENDANT'S ACTS DO NOT VIOLATE 18 U.S.C. § 1084(a) AS A MATTER OF LAW

A. The Indictment Must be Dismissed Because the Defendant Lacked the Requisite Mens Rea to Violate 18 U.S.C. § 1084(a)

i. The Defendant Purposefully Established his Business in Antigua, Where the Antiguan Government has Taken Affirmative Steps to Regulate, License and Legalize On-Line Gambling

ii. The Defendant's Open and Legitimate Business Operation Belies a Finding of Criminal Intent

iii. The Defendant's Use of the Internet Makes it Impossible for him to Know that the Alleged Bets Were Being Placed in Interstate of Foreign Commerce

B. The Indictment Must be Dismissed Because the Defendant's Acts are not Within the Intended Purview of 1084(a)

POINT IV -
THE INDICTMENT MUST BE DISMISSED AS A MATTER OF LAW BECAUSE THE INTERNET IS  NOT A "WIRE COMMUNICATION FACILITY" WITHIN THE MEANING OF 18 U.S.C. § 1084(a)

POINT V -
THE INDICTMENT MUST BE DISMISSED BECAUSE THE PROSECUTION OF THE DEFENDANT THEREUNDER WOULD VIOLATE HIS DUE PROCESS RIGHTS

A. The Internet Gambling Prohibition Act of 1997 Demonstrates That the Defendant had no Notice That His Acts Were Illegal

B. The National Gambling Impact Study Commission Established in 1996 to Determine the Jurisdictional Issues Presented by the Regulation of On-Line Gambling Demonstrates That the Defendant had no Notice That his Acts Were Illegal

C. The Involvement of the United States Government in Assisting Antigua to Establish Their Licensing Procedure for On-Line Gambling Web-sites Demonstrates That the Defendant had no Notice That his Acts Were Illegal

D. The Existence of State Operated On-Line Gambling Web-sites Demonstrates that the Defendant had no Notice That his Acts Were Illegal

CONCLUSION
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,
-against-
JAY COHEN,
Defendant.

Indictment No. 98 CR 294 (TPG)

MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT JAY COHEN'S PRE-TRIAL MOTIONS

PRELIMINARY STATEMENT

This Memorandum of Law is respectfully submitted in support of defendant Jay Cohen's pre-trial motions, as more fully detailed in the accompanying Notice of Motion and Supporting Affidavit of Benjamin Brafman, Esq.
 
STATEMENT OF FACTS

The defendant was indicted, in a seven count indictment, charging him with one count of conspiring to use wire communication facilities to transmit bets and wagers, or information assisting in the placement of bets and wagers, in interstate or foreign commerce (18 U.S.C. §§ 371/1084).  The six remaining counts of the indictment charge the defendant with using wire communication facilities to transmit bets and wagers, or information assisting in the placement of bets and wagers, in interstate or foreign commerce on six separate occasions.

The facts underlying the indictment are set forth in the accompanying affidavit at paragraphs 8 though 12.  In addition, the facts underlying the indictment are referenced within this memorandum of law where needed to illuminate the legal arguments presented therein.

POINT I
THE INDICTMENT MUST BE DISMISSED BECAUSE THE DEFENDANT'S ACTS FALL SQUARELY WITHIN THE STATUTORY EXCEPTION TO PROSECUTION UNDER 18 U.S.C. § 1084(b).  THUS, THE INDICTMENT FAILS TO ALLEGE A CRIME FOR WHICH THE DEFENDANT COULD BE CONVICTED AS A MATTER OF LAW.

It is respectfully submitted that the indictment must be dismissed because the facts alleged therein do not constitute a criminal offense.  Accordingly, the indictment is facially defective.  Specifically, all counts relate to conduct that falls squarely within the statutory exception to prosecution under 18 U.S.C. § 1084(b), and thus no crime has been committed under the cited statute.  Because the indictment fails to specify a crime, each count would permit a jury to convict the defendant for conduct that is not criminal, and, thus, the indictment must be dismissed as a matter of law.  See United States v. Sampson, 371 U.S. 75, 78 (1962) (on a motion to dismiss, an indictment must be tested by its sufficiency to charge an offense).
Each of the seven counts of the indictment charge that the defendant accepted bets on sporting events over either the Internet or telephone lines, allegedly in violation of 18 U.S.C.  § 1084, commonly known as the Wire Act.  Subsection (a) of section 1084 delineates the acts prohibited by the Wire Act, it provides:
 (a) Whoever being engaged in the business of betting or wagering knowingly uses a wire communication facility for the transmission in interstate or foreign commerce of bets or wagers or information assisting in the placing of bets or wagers on any sporting event or contest, or for the transmission of a wire communication which entitles the recipient to receive money or credit as a result of bets or wagers, or for information assisting in the placing of bets or wagers, shall be fined under this title or imprisoned not more than two years, or both.

There are three essential elements of the Wire Act that the government must prove beyond a reasonable doubt: (1) the defendant must be in the business of betting or wagering; (2) the defendant must knowingly use a wire communication facility; and (3) the defendant must transmit bets or wagers using wire communication facilities.   Subsection (b) of the Wire Act excepts from prosecution however "transmissions" that assist "in the placing of bets" between two states, or a state and a foreign country, so long as both jurisdictions permit such betting.  Specifically, subsection (b) provides, Nothing in this section shall be construed to prevent the transmission in interstate or foreign commerce . . . of information assisting in the placing of bets or wagers on a sporting event or contest from a State or foreign country where betting on that sporting event or contest is legal into a State or foreign country in which such betting is legal.
 
The legislative history of subsection (b) makes clear that its purpose is to exempt from prosecution "the transmission of gambling information from a State where the placing of bets and wagers on a sporting event is legal, to a State where betting on that particular event is legal." H.R. REP. 987, 87th Cong., 1st Ses. 2631, annexed hereto as Exhibit B; Telephone News System, Inc. v. Illinois Bell Telephone Company, 220 F.Supp. 621, 627 (N.D. Ill. 1963) (1084[b] specifically exempts transmissions sent from a state where betting is legal to another state where betting is legal).   The exception to 18 U.S.C. § 1084 contained in subsection (b) is applicable to this case for two alternative reasons: (1) that placing bets in New York, and betting in Antigua, are completely legal acts Telephone News System, Inc.; and (2) that even assuming arguendo that 1084(b) does not cover the actual placement of bets McDonough, Blair, the undercover agents in this case were merely transmitting gambling information to the defendant's Internet web-site in Antigua.

A. The Defendant's Conduct Falls Squarely Within the Statutory Exception to Prosecution Under 18 U.S.C. § 1084(b) Because it is Legal to Place a bet in New York and Legal to Receive a bet in Antigua.

The indictment alleges that on six separate occasions, undercover agents and/or private investigators located in New York "placed" bets or requested information regarding the placement of bets with the defendant or his company, the World Sports Exchange (hereinafter "WSE"), located in the sovereign nation of Antigua.  See Exhibit A.  Under New York State Penal Law Article 225, which governs New York State gambling laws, neither the act of placing a bet, nor the act of requesting information regarding the placement of bets, are illegal.  See N.Y. Penal Law Article 225; see also People v. Giordano, 87 N.Y.2d 441 (1995) (considering the scope of Article 225).   Instead, Article 225 prohibits accepting bets or profiting from unlawful gambling activities in New York State.   In Antigua, it is lawful to receive bets.   Under these circumstances, this case involves acts occurring in two jurisdictions where the conduct occurred in each jurisdiction is completely legal, thus making the exception delineated in subsection (b) entirely applicable to this case.  Accordingly, the indictment is defective for failing to state a crime.

B. Even Assuming Arguendo That 18 U.S.C. § 1084(b) is not Applicable to Placing Bets, the Defendant's Conduct Remains Squarely Within the Statutory Exception to Prosecution Under 18 U.S.C. § 1084(b) Because Information Assisting in the Placement of Bets was Transmitted From one Legal Jurisdiction to Another.
 
Even assuming arguendo that subsection (b) is inapplicable to the placement of bets or wagers, but instead only covers the transmission of information assisting in the placement of bets or wagers, subsection (b) remains entirely applicable to defendant's case.  To be sure, the structure of WSE is such that the information transmitted by the agents in New York only assisted in the placement of bets.  The bet itself was ultimately "placed" within the jurisdiction of Antigua.  This is because when an individual entered the WSE web-site, he or she opened an account and was assigned a pass-word for future use.  WSE then required the client to wire money to WSE in Antigua, prior to placing a bet.  Once the money had been received by WSE the client was able to place an actual bet.  The bet was placed by "clicking" on icons on the WSE web-site, which is located, maintained, and operated in Antigua.  See  State of Missouri v. Coeur D'Alene Tribe, et. al., 1997 WL 603834 (W.D.Mo. 1997) (an Internet lottery web-site operated by an Indian tribe is located on tribal lands where the web-site is maintained and operated).  Accordingly, the government agents in New York were merely sending information that assisted in the placement of a bet, and that when it came time to actually place the bet, the entire transaction took place in Antigua.  Under these circumstances, the exception in subsection (b) is clearly applicable to the defendant's case, and the indictment therefore fails to allege a crime.  The indictment must be dismissed as a matter of law.
 
POINT II
THE INDICTMENT MUST BE DISMISSED BECAUSE THE UNITED STATES LACKS JURISDICTION OVER THE DEFENDANT'S ACTS WHICH OCCURRED WITHIN THE SOVEREIGN NATION OF ANTIGUA

As early as 1804 courts have permitted the United States "to secure itself . . . from injury from beyond the limits of its territory." Church v. Hubbard, 6 U.S. 187, 234 (1804).  Congress has the authority to attach extraterritorial jurisdiction to its penal enactments and to pass legislation that regulates extraterritorial conduct.  Theoretically, the United States may exercise jurisdiction in the event that an offense occurred partially in the United States or was intended to affect the United States.  In determining whether federal law applies beyond the territory of the United States, courts must look at the express language of the relevant statute and ascertain whether it was intended to encompass acts committed outside of the United States.

As the United States Supreme Court has observed, the exercise of extraterritorial jurisdiction "depends on the purpose of Congress as evinced by the description and nature of the crime and upon the territorial limitations upon the power and jurisdiction of a government to punish crime under the law of nations." United States v. Bowman, 260 U.S. 94, 97-98, 43 S.Ct. 39, 41 (1922).   Before a court can extend extraterritorial jurisdiction over a an extraterritorial matter, even with regard to the enforcement of United States criminal laws, it must assess the "reasonableness" of such an application.  United States v. Noriega, 746 F.Supp 1507, 1515 (S.D. Fla 1980).   Moreover, according to the Restatement of Foreign Relations Law of the United States, Third, "reasonableness" is determined by balancing principles of sovereignty and commerce against that of the need to apply the law.  Courts have traditionally abstained from hearing those cases which call into question the wisdom or validity of a foreign sovereign's laws or protection.  Banco Nacional de Cuba v. Sabbatino, 376 U.S. 398, 428-32 (1964); Shapleigh v. Mier, 299 U.S. 468 (1937); Oetjen v. Central Leather Co., 246 U.S. 297 (1918).

In this case, the sovereign nation of Antigua has clearly determined that online and telephone gambling is legal.  The legalization of such activity in Antigua was based on Antigua's reasonable and rational desire to boost its economy and create jobs.  It would thus be wholly unreasonable for the United States to prosecute individuals acting within the scope of Antigua's laws.  This is particularly true in this case where Antigua specifically passed the laws legalizing gambling businesses such as the defendant's, in order to improve its economy.

Moreover, as the district court observed in the ACLU case,  "the Internet deserves the broadest possible protection from government-imposed, content-based regulation."  There is thus a strong policy argument that the United States government is not the appropriate body to legislate -- either through Congress or the Judiciary -- what the content of the Internet should be.  Clearly, the regulation of the Internet would be better left to an international tribunal so that interests of global diversity will be met.  Even the Department of Justice embraces the notion of international regulation of the Internet.  Thus, as Deputy Assistant Attorney General Kevin Di Gregory told the House of Representatives, "[t]he United States needs to be very sensitive to issues of international law and comity in the Internet context."  Statement of Kevin V. Di Gregory, Deputy Assistant Attorney General, Criminal Division, Before the Subcommittee on Crime, Committee on the Judiciary, U.S. House of Representatives, June 24, 1998, at p. 7, annexed hereto as Exhibit C.

The prosecution of the defendant in this case ignores the truly international nature of the Internet.  Currently,  "[t]he Internet is an international system..[and] [n]o single entity -- academic, corporate, governmental, or non-profit -- administers the Internet," ACLU v. Reno, 929 F. Supp. at 832, and "it would not be technically feasible for a single entity to control all of the information conveyed on the Internet."  Id at 832.   Despite this truism, the United States has indicted the defendant for acts he allegedly committed on the Internet.  The United States is not the appropriate body to regulate the Internet, particularly in this case, where the defendant was operating solely, and legally, within the sovereign nation of Antigua.
Under these circumstances, the United States lacks jurisdiction over the defendant's acts and the indictment must be dismissed.

POINT III
THE INDICTMENT MUST BE DISMISSED BECAUSE THE DEFENDANT'S ACTS DO NOT VIOLATE 18 U.S.C. § 1084(a) AS A MATTER OF LAW

Rule 12(b) of the Federal Rules of Criminal Procedure provides that "[a]ny defense or objection which is capable of determination without the trial of the general issue may be raised before trial by motion."
In this case, the indictment must be dismissed on the ground that the defendant's acts do not constitute a crime under 18 U.S.C. § 1084(a) as a matter of law.   Indeed, because the defendant purposefully established the World Sports Exchange (hereinafter "WSE") in Antigua, where Internet and telephone gambling is legal, licensed, and actually proactivly encouraged by the Antiguan government, the requisite mens rea of "knowingly and willfully conspiring" to commit the offense of illegal gambling through interstate or foreign commerce against the United States, is absent.  Absent the necessary mens rea element of this crime, the indictment fails to allege criminal activity in violation of 18 U.S.C. § 1084(a) and must be dismissed.  See United States v. Levin, 973 F.2d 463 (6th Cir. 1992) (indictment properly dismissed where government was incapable of proving beyond a reasonable doubt requisite intent required to convict the defendant).   Moreover, because the Internet is not a "wire communication facility" within the meaning of the Wire Act, the defendant's acts are outside of the Act's scope.   Thus, the indictment must be dismissed on the ground that the defendant's acts do not come within the purview of behavior prohibited under 18 U.S.C. § 1084(a).

 A. The Indictment Must be Dismissed as a Matter of law Because the Defendant Lacked the Requisite Mens Rea to Violate 18 U.S.C. § 1084(a)

The mens rea of the Wire Act is that one knew, or should have reasonably foreseen, that interstate or foreign communication would be used to transmit gambling information or actual bets.  United States v. Southard, 700 F.2d 1, 24 (1st Cir. 1983); United States v. Barone, 467 F.2d 247, 249 (2d Cir. 1972).   The Second Circuit has construed this requirement as necessitating proof beyond "mere geographical location" in order to establish that a defendant had the requisite knowledge.  Barone, at 249.  In order to prove the defendant's guilt to conspire to do an illegal act under 18 U.S.C. § 371, it is well-established that the government must establish that the defendant knew that the intended act was illegal.  United States v. Vanwort, 887 F.2d 375, 386 (2d Cir. 1989) (whether defendant willfully participated in activities of conspiracy with the knowledge of its illegal ends is determinative of whether defendant may be convicted of said conspiracy); United States v. Alessi, 638 F.2d 466, 473 (2d Cir. 1980) (whether defendant participated in alleged conspiracy with "a consciousness of its general nature and extent" is determinative of whether defendant may be convicted of said conspiracy); United States v. Gleason, 616 F.2d 2, 16 (2d Cir. 1979), cert. denied. 444 U.S. 1082 (1980) (whether defendant agreed to participate in a scheme which he knew to be illegal is determinative of whether defendant may be convicted of said conspiracy).  Here, there is overwhelming evidence that the defendant held the reasonable belief that his actions were entirely within the letter of the law.

 i. The Defendant Purposefully Established his Business in Antigua, Where the Antiguan Government has Taken Affirmative Steps to Regulate, License and Legalize On-Line and Telephone Gambling.

The defendant purposefully established his business in Antigua where online and telephone gambling is not only legal, but fully licensed by the Antiguan government.  Indeed, the Antiguan government established the Antigua Free Trade Zone to exercise authority over the gaming industry within that country.  Within the Free Trade Zone is the Gaming Commission, whose purpose is to receive complaints from customers and investigate fraudulent gambling operations in Antigua.  Pursuant to the licensing of Internet gambling businesses, the Antiguan government issues the "Standard Conditions for the Licensing of Wagering" which sets forth, among other things, the application process, documentation, software, regulatory questions and fees regarding online gambling.  See Standard Conditions for the Licensing of Wagering, annexed hereto as Exhibit D.  Moreover, there is a due diligence procedure, that involves government screening. See Due Diligence Procedure, annexed hereto as Exhibit E.

It was pursuant to these standards that WSE obtained its license and its Certificate of Good Standing prior to beginning its business in Antigua.  See Certificate of Good Standing and License annexed hereto as Exhibit F.  This rigorous, multi-tiered, government sponsored and required licensing procedure that the defendant underwent prior to operating WSE demonstrates the reasonableness of his belief at the time he started his business, that the operation was squarely within the letter of the law.

 ii. The Defendant's Open and Legitimate Business Operation Belies a Finding of Criminal Intent

The defendant's actions once WSE was up and running do not suggest that he acted with criminal intent.  Thus, the defendant placed advertisements in Pro Football Weekly, provided insights and interviews regarding online gambling to national newspapers and television programs, debated the Attorney General of Wisconsin on CNBC, spoke at conferences, and even submitted testimony before the Senate Judiciary Committee in July 1997, with regard to regulating Internet gambling.  See Testimony of Mr. Jay Cohen Before the Senate Judiciary Committee, July 28, 1997, annexed hereto as Exhibit G.   These actions hardly suggest those the activity of one engaged in an "organized gambling" operation, that the Wire Act was intended to abolish.

Furthermore, the legality of the defendant's business was even given credit within the gaming industry.  For example, WSE used the services of the Las Vegas Sports Consultants, which sell odds to casinos nationwide and internationally.  It is obviously imperative, and pursuant to their own Nevada Gaming License, that Las Vegas Sports Consultants sell odds only to licensed and legitimate casinos.  Thus, the Las Vegas Sports Consultants web-site explicitly sets out that they "provide odds and pointspreads to legal sports bookmaking operations and sports lotteries worldwide." See Las Vegas Sports Consultants Web Site (emphasis added), annexed hereto as Exhibit H.   Las Vegas Sports Consultants sold odds to WSE.   This further demonstrates that even within the gaming industry the legality of the defendant's business was assumed.

iii. The Defendant's Use of the Internet Makes it Impossible for him to Know That the Alleged Bets Were Being Placed in Interstate or Foreign Commerce

Because he used the Internet, the defendant lacks the knowledge required by section 1084 that the bets were being placed interstate, or for that matter, from jurisdictions where such acts were illegal.  Indeed, at the time a bet is placed on the WSE web site, the defendant is incapable of knowing where the bettor is located.  The only location the defendant ever learns of is that of where the money to establish the client's account came from.  Moreover, the fact that WSE is operating from Antigua, does not prove that the defendant had knowledge of the interstate nature of the call, for, in the words of the Second Circuit, "mere geographical location" is insufficient to establish this element of the Wire Act.

B. The Indictment Must be Dismissed Because the Defendant's Acts are not Within the Intended Purview of 18 U.S.C. § 1084

The legislative history of 18 U.S.C. § 1084 demonstrates that the defendant's acts were not with the scope of the Wire Act.

Congress enacted the Wire Act in 1961 to suppress illegal "organized gambling activity," to assist states in the enforcement of anti-gambling measures, and to allow federal intervention in interstate gambling. See Exhibit B at 2631; Martin v. United States, 389 F.2d 895, 898 (5th Cir. 1968).  Aware of the importance of rapid "transmission of gambling information," Congress passed the Wire Act as a means to combat organized gambling by denying gamblers the availability of interstate wire communications facilities.  See Exhibit B at 2631.     In providing examples of the ills of using wire communication facilities, the legislative history reveals that the telephone was the object of the legislation.  For example, the Statement asserts, "bookmakers are dependant upon telephone service for the placing of bets and for layoff betting on all sporting events."  See Exhibit B at 2632, (emphasis added).  Furthermore, "section 1084(a) was not passed to protect bettors from their gambling proclivities.  Its stated purpose was to assist the states in enforcing their own laws against gambling."  United States v. Southard, 700 F.2d 1, 20 (1st Cir. 1983); United States v. McDonough, 835 F.2d 1103, 1104-1105 (5th Cir. 1988) (Section 1084 has two purposes, to assist states in enforcing gambling laws and suppress organized gambling activity).

The prosecution of the defendant in this case for openly operating a legitimate and licensed Internet gambling business would constitute a perversion of the Congressional intent behind the Wire Act.  Indeed, it stretches credulity to define defendant's business as "organized gambling activity".  Moreover, to apply the Wire Act to the Internet, where clearly it was the telephone that was the object of the Wire Act legislation, would be an overbroad reading of the Act's scope.  In addition, because New York State has not made the placing of bets illegal, the prosecution of the defendant would not assist New York in enforcing its gambling laws, but instead run completely afoul of those laws.
 
Moreover, the exception in subsection (b) of the Wire Act is further evidence that Congress did not intend to completely ban the transmission of bets or wagers in interstate commerce.  In fact, in U.S. v. Edge Broadcasting Co., 509 U.S. 418 (1993), the Court determined that the government has a substantial interest in supporting the policy of non-lottery States and in not interfering with the policy of States that permit lotteries.  However, it is the nature of the Internet that web sites are available for access in all states and foreign countries whether or not betting is legal.  Moreover, communication over the Internet can travel through various routes prior to reaching its destination.  The example provided in the stipulated factual findings in the ACLU case bears this out, "[A] message sent from a computer in Washington, D.C., to a computer in Palo Alto, California, might first be sent to a computer in Philadelphia, and then be forwarded to a computer in Pittsburgh, and then to Chicago, Denver, and Salt Lake City, before finally reaching Palo Alto."  ACLU v. Reno, 929 F.Supp. at 832.  Since transmission over the Internet cannot be prohibited from entering non-gambling States without also preventing the legitimate transmission into States where such gambling is permitted, the duality policy in subsection (b) would be impossible to maintain.  Therefore, the Internet presents a technology Congress surely did not consider when adopting the interstate gambling statutes, and therefore prosecution under the Act is improper at worst, and an application of an ambiguous law at best.

Under these circumstances, the indictment fails to allege, as a matter of law, acts for which the defendant could be convicted.  Accordingly, the indictment must be dismissed.

POINT IV
THE INDICTMENT MUST BE DISMISSED AS A MATTER OF LAW BECAUSE THE INTERNET IS NOT A WIRE COMMUNICATION FACILITY WITHIN THE MEANING OF 18 U.S.C. § 1084(a).

A necessary element of section 1084(a) is that a defendant knowingly use a "wire communication facility" to transmit bets or wagers.  United States Code Title 18, section 1081 defines a "wire communication facility" as,

[A]ny and all instrumentalities, personnel, and services (among other things, the receipt, forwarding, or delivery of communications) used or useful in the transmission of writings, signs, pictures, and sounds of all kinds by aid of wire, cable, or other like connection between the points of origin and reception of such transmission.

Because the indictment alleges the use of the Internet, which is not a "wire communication facility" within the meaning of section 1081, the acts alleged in the indictment do not violate the Wire Act.
 The Internet does not fall into any of the categories delineated in section 1081 because it is not a "transmitter" of information.  Instead, the Internet is an unregulated world-wide network of computer systems, connected by high-speed communications, facilitated by either wire or satellite, which share a common protocol that enables the computers to communicate with one another.  The Internet's "web browsers" enables users to easily navigate the Internet, and its graphical component, the World Wide Web.  These programs offer users the opportunity to view pictures and hear sounds from around the world, and to move from one location to another -- commonly called web-sites -- simply by highlighting and selecting the destination they wish to visit.   Notably, however, a web-site cannot, on its own, communicate with those who are visiting it.  It is this characteristic of one-way communication that makes the Internet unique, by providing links around the world, without necessarily "transmitting" information.

Indeed, as the Supreme Court observed in ACLU v. Reno, 117 S.Ct. 2329 (1997) , the world wide web "consists of a vast number of documents stored in different computers all over the world." (emphasis added) Id. at 2335.  The Court analogized the Internet as "comparable, from the readers' viewpoint, to both a vast library including millions of readily available and indexed publications and a sprawling mall offering goods and services . . .  [and] from a publishers' point of view, it constitutes a vast platform from which to address and hear from a world-wide audience of  millions of readers, viewers, researchers, and buyers." Id. 2335.  Thus, while it is true that one may communicate with a web site by entering information onto it or by using the "links" provided on the site, the web site itself is not communicating with the person who has logged on.  Instead, the web site is a mere venue for pre-stored information, that is incapable of communicating with the reader or user of that information.

Applying the qualities and characteristics of the Internet to this case, it is revealed that when a bet is placed on the WSE web site a "transmittal" of information has not taken place.  Instead, a "virtual" visit has been made to Antigua where the WSE web-site is operated and maintained, see State of Missouri v. Coeur D'Alene Tribe, et. al., and all of the information needed to place a bet is stored.  United States v. Stonehouse, 452 F.2d 455 (7th Cir. 1971) presents an analogous situation.  In Stonehouse the defendant received, over a ticker tape machine, information which assisted in the placing of bets on sporting events.  The Seventh Circuit held that because the defendant was using a ticker tape machine, he was merely receiving information, rather than "transmitting" information within the meaning of the Wire Act and thus, the defendant's conviction for violating the Wire Act was reversed.  In this case, the defendant's use of a web-site presents a set of circumstances similar to those in Stonehouse, because like the ticker tape machine, the WSE web-site is not transmitting information but instead, is merely receiving it.  Accordingly, the defendant's acts are not criminal under 18 U.S.C. § 1084(a).

Moreover, while the Circuits are split on the interpretation of "transmit" and whether it includes the sending or the receipt of a transmission, or both,  in the Second Circuit this issue has not been decided.  Persuasive on this issue, however, is United States v. Lamar, 240 U.S. 60 (1916), where the Supreme Court held that when a person uses a telephone to commit a crime, the offense takes effect in the place where the hearer, not the speaker, is located.  This holding supports a finding that for the purposes of 18 U.S.C. § 1084(a), the proper conclusion is that transmission encompasses only the receipt of information.   Similarly, as a matter of statutory construction, the fact that subsection (d) of section 1084 contains both the term "transmitting" and "receiving" supports the conclusion that the use of the word "transmitting" in subsection (a) is not inclusive of receiving.   In this case, the information regarding, and the actual placements of bets, were received in Antigua where the defendant's acts are legal, and accordingly, the indictment fails to specify a crime for which the defendant could be convicted.
Furthermore, the government's reliance on the bald assertion that the defendant "used telephone wires" utterly fails to bring defendant's acts within the purview of the Wire Act because the Internet may be accessed in a variety of ways.  Indeed, even the complaint underlying the indictment concedes, "[t]he Internet is comprised of many smaller computer networks that are connected to each other via telephone and other data lines" See Complaint at  7, annexed hereto as Exhibit I.  In fact, the Internet may be accessed through methods that have nothing to do with telephone wires; including cellular based wireless service and low-earth-orbit satellites.  See PETER WAYNER, Plugging In to the Internet:  Many Paths, Many Speeds, N.Y. TIMES,  July 2, 1998, at G2, annexed hereto as Exhibit J.  These other methods of Internet access clearly remove the Internet from the statutory definition of a wire communication facility.
 Under these circumstances, where the Internet is not a "wire communication facility within the meaning of the Wire Act, the defendant's alleged acts do not constitute a crime and the indictment must be dismissed.
POINT V
THE INDICTMENT MUST BE DISMISSED BECAUSE THE PROSECUTION OF THE DEFENDANT UNDER THE FACTS OF THIS CASE WOULD VIOLATE HIS DUE PROCESS RIGHTS

The United States Constitution forbids the federal government from depriving any person of life, liberty, or property without due process of law.  U.S. CONST. amend. V.   Part of this due process guarantee is that a statute be declared void when its application is so vague or unclear that "men of common intelligence must necessarily guess at its meaning and differ as to its application."  Connally v. General Constr. Co., 269 U.S. 385, 391 (1926).   This concept of fundamental fairness is particularly important in criminal cases where the need for fair warning is particularly acute because the potential for the loss of one's liberty is at stake.  Accordingly, the Supreme Court has commanded that the judicial branch exercise restraint in determining the scope of a federal criminal statute.  United States v. Aguilar, 115 S.Ct. 2357, 2362 (1995); Dowling v. United States, 473 U.S. 207, 213 (1985).  The purpose for such restraint is two pronged; one, to give deference to the prerogatives of Congress and two, to provide "fair warning" to "the world in language that the common world will understand."  Id. (quoting Dowling; McBoyle v. United States, 283 U.S. 25, 27 [1931]).

Moreover, any ambiguity in the reach of a penal statute must be construed in favor of the accused.  United States v. Dowling, 473 U.S. at 213-214 ("The rule that penal laws are to be construed strictly . . . [i]s founded on the tenderness of the law for the rights of individuals; and on the plain principle that the power of punishment is vested in the legislative, not in the judicial department" [citations omitted]); United States v. Bass, 404 U.S. 336, 347-48 (1981) (the principle of strict construction is based upon the need for the legislature to provide "fair warning" to individuals); United States v. Campos-Serrano, 404 U.S. 293, 299 (1971) ("The principle of strict construction of criminal statutes demands that some determinate limits be established based upon the actual words of the statute."); United States v. Margiotta, 688 F.2d 108, 120 (2d Cir. 1982), cert. denied, 461 U.S. 913 (1983).  For example, in a case construing an earlier version of the federal statute regulating gambling activities, the court in United States v. Whelpley, 125 F. 616  (WD Vir. 1903) considered whether the language "from one state to another" included the transportation of lottery tickets into the District of Colombia.  In that instance, the court stated that any substantial doubt should be resolved against the government.  Similarly, any doubt existing with regard to the application of the Wire Act to the defendant in this case must be resolved in his favor.

Furthermore, it is axiomatic that in our system of jurisprudence, no person shall be held criminally responsible for conduct which could not reasonably be understood to be proscribed.  See United States v. Harriss, 347 U.S. 612, 617 (1954); United States v. Chestman, 947 F.2d 551, 564 (2d Cir. 1991).   In assessing the reach of a criminal statute, a court must "pay close heed to language, legislative history, and purpose in order strictly to determine the scope of the conduct the enactment forbids."  Dowling v. United States, 473 U.S. at 213; see United States v. Rooney, 986 F.2d 31, 33 (2d Cir. 1993).

Applying these principles to the facts of this case, where neither the plain language of 18 U.S.C. 1084, nor its legislative history, see supra Point III, support a conclusion that the defendant's actions are within the purview of the Act, this Court should apply the rule of lenity, and conclude that the Act is not applicable to his case.  See United States v. RLC, 503 U.S. 291, 303-304 (1992) (rule of lenity applies to situations where a "reasonable doubt persists about a statute's intended scope even after resort to 'the language and structure, legislative history, and motivating policies' of the statute.'") (citations omitted).

In this case, the defendant had no notice, nor any reason to believe, that his acts were illegal.  In fact, the only notice that the defendant did have was that operating an Internet gambling site was squarely within the letter of the law.   Indeed, at the time the defendant committed the acts alleged in the indictment: (1) the Internet Gambling Prohibition Act -- amending 18 U.S.C. § 1084(a) to expressly prohibit Internet gambling -- was pending in the United States Congress; (2) the National Gambling Impact Study Commission National Commission was in the midst of studying the legal issues presented by the Internet; (3) the United States had assisted in setting up the licensing process in Antigua where the defendant's business is located; and (4) there existed numerous state-run on-line gambling web sites.   Moreover, neither the plain language nor the legislative history of 18 U.S.C. § 1084 gave the defendant notice that his acts were illegal.  Under these circumstances, where the defendant did not have fair notice that his acts were prohibited at the time he did them, the indictment violates his due process rights under the Federal Constitution.  Accordingly, the indictment must be dismissed.

 A. The Internet Gambling Prohibition Act of 1997 Demonstrates That the Defendant had no Notice That his Acts Were Illegal

The Internet Gambling Prohibition Act (hereinafter, "IGPA") would have  prohibited gambling over the Internet by amending 18 U.S.C. §§ 1081 and 1084 to create criminal penalties for those engaged in the business of betting and wagering, as well as individuals who engage in betting and wagering over the Internet.  See Internet Gambling Prohibition Act, S. 474, 105th Cong. (1997), annexed hereto as Exhibit K.  The IGPA would impose fines and possible prison sentences on operators of on-line gambling as well as private gamblers.  Additionally, the law would give local authorities the right to seek injunctions against Internet service providers who fail to block access to the gambling sites once they have been notified and have failed to block access.  Ultimately, the bill would penalize online gambling more harshly than off-line gambling.  Thus, the Act would subject amateur bettors to federal liability for gambling, whereas the existing Wire Act, by contrast, applies only to people "engaged in the business of betting or wagering."  The bill would also eliminate any ambiguity concerning terms and application of the statute as well as extend liability to on-line gamblers and access providers.  The existence of this Act demonstrates that there is an implicit understanding in the legislative branch of the United States government that the Wire Act does not cover the Internet.

Indeed, when Senator Jon Kyl, the Bill's sponsor, introduced the IGPA on the Senate floor, he stated that the IGPA was necessary because "[i]t dispels any ambiguity by making clear that all betting [on line], including sports betting, is illegal."  See Internet Gambling Prohibition Act, comments of Senator John Kyl, (emphasis added) annexed hereto as Exhibit L.   In addition, Senator Kyl observed that the IGPA would "mak[e] explicit the intent of Congress to create extraterritorial jurisdiction regarding Internet gambling activities."  Id.   A similar admission regarding the ambiguity of the applicability of existing laws to the Internet was articulated by Congressman Bob Goodlatte when he introduced the IGPA in the House of Representatives.  Congressman Goodlatte stated "[w]ith the development of the Internet, however, prohibitions and regulations governing gambling have been turned on their head."  See Introduction of the Internet Gambling Prohibition Act of 1997 -- Hon. Bob Goodlatte, annexed hereto as Exhibit M.    These comments make clear that the United States government does not believe that the Internet is governed by the existing Wire Act.

Moreover, it was not just members of the legislative branch that were articulating the need for the IGPA to close a gap in the existing Wire Act.  Indeed, the Department of Justice was also aware that the Internet was not within its scope.  Thus,  Kevin V. Di Gregory, the Deputy Assistant Attorney General of the Criminal Division of the Department of Justice, told the House Judiciary Committee that, "the Department generally supports the idea of amending the federal gambling statues by clarifying that the Wire Communications Act applies to interactive casino betting and that the Act covers all Internet use, even if the Internet transmissions use modern technology -- such as satellite communications -- that may not be included in the traditional definition of "wire communication".  See Exhibit C, at 4.

The clearest statement by the legislative branch that the IGPA was necessary to cure the ambiguity regarding the applicability of 18 U.S.C. § 1084 to the Internet was made just weeks ago when, on July 23, 1998, the United States Senate voted 90-10 to attach the IGPA to a Commerce, State and Justice Appropriations Bill, which is a "must-pass" federal spending bill.  See Senate Endorses Kyl Bill Prohibiting Internet Gambling With 90-10 Vote, Press Release, Office of Senator Jon Kyl (R-Arizona) at www.senate.gov/~kyl/mainpres.htm, annexed hereto as Exhibit N.  The fact that the IGPA was attached to this "must-pass" bill lends further support to the conclusion that the government does not believe that the Internet, or the defendant's alleged acts, are properly within the scope of the existing Wire Act.   Moreover, the defendant in this case was well aware that, at the time his alleged acts took place, that the Act was pending in Washington.  Indeed, the defendant submitted testimony regarding the IGPA to the Senate Judiciary Committee.  See Exhibit G.  Accordingly, the existence of the then pending IGPA provided the defendant with a good faith basis to believe that the existing Wire Act did not proscribe his acts.  Moreover, the fact that the IGPA has had such support in Washington and the Department of Justice, lends further support to the fact that people "of ordinary intelligence must necessarily guess"  at whether the existing Wire Act is applicable to the Internet.  Conally v. General Construction, 269 U.S. at 391.

B. The National Gambling Impact Study Commission Established in 1996 to Determine the Jurisdictional Issues Presented by the Regulation of On-line Gambling Demonstrates That the Defendant had no Notice That his Acts Were Illegal

In further support of the argument that the defendant had no notice that his acts were illegal is the existence of the National Gambling Impact Study Commission.  This Commission, created in 1996 at the request of Senator Paul Simon and Congressman Frank Wolf, was to study the proliferation of gaming in the United States, and more specifically, to determine whether the Internet posed particular jurisdictional dilemmas for  the United States. See 18 U.S. C. § 1955 (Pocket Part Statutory Notes).  The Commission has not, to date, concluded its study.   However, the very fact that the legislative branch established the Commission lends further support to the existence of ambiguity regarding the application of the Wire Act to the Internet.

Indeed, Deputy Assistant Attorney General Di Gregory informed the House of Representatives that the IGPA should not be passed until the Commission concludes its study.  See Exhibit C at 1-2.  The fact that the Commission -- established by the legislature where "the power of punishment is vested" Dowling --  was working on the very question of whether the United States had jurisdiction over Internet gambling at the time the defendant's committed the alleged acts, demonstrates that his belief that his acts were legal were entirely justifiable.

C. The Involvement of the United States Government in Assisting Antigua to Establish Their Licensing Procedure for On-Line Gambling Web-Sites Demonstrates That the Defendant had no Notice That his Acts Were Illegal

The United States government has already given an implicit "stamp of approval" on Antigua's legalization of online gambling.  Indeed, the United States Advisor on Computer Fraud worked along-side those in Antigua to regulate and establish licensing procedures for the Antiguan gaming industry.  These communications reveal that from an early date the United States was not interested in challenging the licensing of gambling operations in Antigua.  In fact, the United States expressed an interest in assisting Antigua in establishing a regulatory scheme.  See Report to Prime Minister Lester Bird on Meeting With Mr. Scott Charney and Mr. Jonathan Winer, 21st and 22nd in Washington, D.C., annexed hereto as Exhibit O.  By providing assistance to the Antiguan government in establishing their licensing procedure, the United States government verified the reasonableness of the defendant's belief that his acts were legal at the time.

D. The Existence in the United States of State Operated On-Line Gambling Web-Sites Demonstrates that the Defendant had no Notice That his Acts Were Illegal

The existence of state operated on-line gambling web sites in the United States is demonstrative of the fact that the defendant had no reason to believe that his acts were illegal.

For example, in New York State, pursuant to the Racing Pari-Mutual Wagering & Breeding Law § 1012 (McKinney Pocket Part), the New York State legislature has legalized betting on horse races on the Internet and over the telephone.  Thus, OTB facilities for example are able to open telephone accounts for persons residing in other states.  When a patron calls from out-of-state, he simply informs the OTB facility to place a bet at the facility, using funds available from his account -- opened prior to placing the bet.  Because the facility must withdraw the funds and then place the wager, the Legislature concluded that the information provided by the telephone call was wagering information, as opposed to the wager itself.  The OTB web-site, facilitates this entire transaction.  See www.capitalotb.com; see also, www.ctotb.com (Connecticut OTB web-site); www.philadeplhiapark.com (Pennsylvania OTB web-site).   The procedure followed by OTB is identical to the one used by WSE, giving the defendant further reason to believe his acts were squarely within the letter of the law.

Finally, in a case of first-impression, where the defendant had an entirely reasonable belief that his acts were lawful, any existing doubt with regard to the proper application of the Wire Act must be resolved in the defendant's favor. Under these circumstances, it is crystal clear that the defendant in this case lacked the requisite fair notice that the operation of his on-line gambling web site was illegal.  Accordingly, the prosecution of the defendant under this indictment violates the defendant's Due Process rights and must be dismissed.
 
 
CONCLUSION
WHEREFORE, for all of the reasons cited herein, this Court should  dismiss the indictment as it fails to state a crime for which the defendant could be convicted because: (1) the defendant's acts fall squarely within the exception to 18 U.S.C. § 1084(b); (2) the United States lacks jurisdiction to prosecute the defendant; (3) the defendant's acts do not violate 18 U.S.C. § 1084(a) as a matter of law; (4) the Internet is not a "wire communication facility" within the meaning of 18 U.S.C. §§ 1081 and 1084(a); (5) the defendant had no notice that his alleged acts were illegal and therefore the prosecution of the defendant would violate his Due Process rights under the Federal Constitution.
 
Finally, this Court should grant such other and further relief as this Court deems just and proper.

Dated: New York, New York
August __, 1998

Respectfully submitted,
____________________
Benjamin Brafman, Esq.
Brafman Gilbert & Ross, P.C.
Attorneys for the Defendant
JAY COHEN
767 Third Avenue, 26th Floor
New York, New York  10017
(212) 750-7800

TO: Clerk
United States District Court
Southern District of New York

Joseph V. De Marco
Thomas S. Rubin
Assistant United States Attorneys