For purposes of this request, “bet365” means bet365 Group Limited (“bet365 Parent”); all direct or indirect subsidiaries of bet365 Parent (including Hillside (Sports) MP Limited, Hillside (Gaming) MP Limited, Hillside (Sports) ENC, Hillside (Gaming) ENC, Hillside (Sports) GP Limited, Hillside (New Media Holdings) Limited, Hillside (Shared Services 2018) Limited, Hillside (Technology) Limited, Hillside (Trader Services) Limited, Hillside (Media Services) Limited, Hillside (Pennsylvania) LLC, Hillside (New Media Holdings US) Inc, Hillside (US New Media) Limited, Hillside (New Media Holdings Malta) Limited, and Hillside (Shared Services US) LLC); and all entities and individuals identified as a licensee, qualifier, key person, key employee, principal, controlling person, or holding a similar position, or ultimate beneficial owner of any of the foregoing (including Denise Coates, John Coates, and Peter Coates) (each, a “Relevant Person”).
I request the following records:
The complete application file for every granted or pending license, registration, permit, qualification, or approval (including operator/interactive, vendor/supplier, management-services, and platform-provider licenses; and comprising all applications, exhibits, attachments, amendments and supplements) in relation to bet365 and any online gambling and/or sports betting business branded as “bet365” (collectively, the “License”).
Please include all files and documents concerning the Relevant Persons.
Please include all internal-controls and house-rules submissions, and all market-access, platform, or management-services agreements submitted by or approved for bet365 (proprietary portions may be redacted).
All other documents provided by or to bet365 in connection with any of the foregoing applications.
All renewal applications and supporting materials for each renewal cycle, together with each license or certificate issued.
All waivers, exemptions, or variances in relation requested by, or granted to, bet365 (including any Relevant Persons).
All correspondence concerning the License or any of the Relevant Persons, and all correspondence concerning any other documents referred to in items 1 to 4 above (including letters, emails, memoranda, and notices — between the agency (including its staff, investigators, and counsel) and bet365 or its employees, directors, officers, attorneys, agents, consultants, or lobbyists).
All board or agency orders, resolutions, staff reports, recommendations, and written decisions granting, conditioning, renewing, denying, suspending, or revoking the License.
Transcripts and other records of all meetings held with employees, officers, directors or representatives of bet365 in relation to the License or any of the matters referred to in items 1 and 4.
Transcripts and minutes of all meetings at which any matters related to bet365 (including a grant of the License) were considered or resolved.
All deficiency notices and requests for additional information issued to bet365, and bet365’s responses.
Records of any prior, withdrawn, surrendered, or denied bet365 application in this jurisdiction.
The roster of all Relevant Persons.
All final suitability determinations, findings, orders, or approval letters for bet365 and each qualifier. (I recognize that underlying background-investigation materials may be exempt. To the extent it is exempt, I request the final determinations and any reasonably segregable non-exempt portions.)
All correspondence between the agency and third parties concerning bet365, including other gaming regulators, law enforcement, and bet365’s market-access partner(s).
Time period. From January 1, 2023 to the present. This start date is chosen to capture bet365’s initial application, which predates its July 22, 2024 launch.