"Chuck Humphrey" <cehjr43@earthlink.netwrote in message
news:74l6htc37o6v9tiptgdeqn69i7ci8r2tm5@4ax.com...
To: Clora Edwards (Nevada Gaming Commission Audit Division)

My name is Chuck Humphrey.  I own the Tournament of Champions of Poker
("TOC"), a poker tournament presented annually at the Orleans Hotel
and Casino.  Two years ago the TOC started the concept of withholding
a percentage amount from the tournament prize pool to be divided among
the dealers and floor staff.  We advertised the toke pool amount would
be 2 1/2% of the total prize pool.  We also advertised that the toke
pool would be split 75% to the dealers and 25% to the floor staff.

Binion's Horseshoe copied this idea from the TOC, but raised the
withheld amount to 3% of the prize pool.  They advertised their toke
pool was being withheld for "Tournament Personnel."  Before the just
concluded World Series of Poker ("WSOP") started the dealers and floor
staff for the event learned that the Behnen family, which controls
Binion's Horseshoe, intended to split the toke pool in a new,
undisclosed manner.  At that point in time, I posted this news on an
Internet newsgroup-rec.gambling,poker ("RGP"). There were many
responses and a subsequent story ran in the Las Vegas Review-Journal.
Two players who were quoted in that article were then banned from the
Horseshoe, although they were subsequently reinstated when the
pressure on the Behnen family became so great that they had little
other choice.

Part of that pressure took the form of threatened job actions by the
dealers and the floor staff of the WSOP.  During that time a tentative
peace was made by Poker's greatest ambassador, Linda Johnson, the
former publisher of the industry's leading publication, Card Player
Magazine.  Linda met with Becky Behnen who, after reviewing the
following text, authorized Linda to publish it on RGP:

"Regarding the three percent being withheld from the prize pool, Becky
stated that the entire three percent would be given to employees in
the form of tokes.  She went on to explain that one and a half percent
is going directly to the dealers.  Out of the remaining one and a half
percent, the majority will go to the immediate tournament personnel
(tournament director, floor staff, brush/board personnel, etc.) and
the remainder will go to the people who work long hours behind the
scenes to insure the success of the WSOP.  She said that she wants to
make sure all appropriate personnel are toked and that this hasn't
always happened in the past."

After consulting with Linda I supported the peace effort and posted on
RGP my view that the promised split would be approximately 11/2% to
dealers, 1% to the floor staff and 1/2 of 1% to other worthy Binion's
Horseshoe personnel.  No job actions took place and the WSOP
successfully concluded.  Apparently the dealers did receive the amount
Becky promised.  However, the floor staff did not.  They received a
total of approximately $40,000 out of the $180,000 they would have
gotten if they were given the full 1% that Ms. Behnen promised.

I do not know what jurisdiction the Nevada Gaming Commission has in
this matter, nor what authority your division can bring to bear on
this disgraceful state of affairs.  I believe the players put up this
money on the strength of industry tradition and the express promises
of Ms. Behnen.  Industry tradition is that toke pools are split
between the immediate personnel involved in the tournament-dealers and
floor staff.  Industry tradition is that the share going to members of
the floor staff ranges from a low of 25% to a high of 35%.  The
express promise that Ms. Behnen made was that a "majority" of 1-1/2%
would go to the floor staff.  This has to mean something.  At a
minimum, a "majority" would come to more than 3/4 of 1%, or more than
$135,000, rather than the $40,000 that was paid to the floor staff.
The expectation that Ms. Behnen led the players and the floor staff to
believe would be paid to the floor staff was 1%, or $180,000.

Can your licensees get away with misleading the public?  Can your
licensees get away with misleading their customers?  Is this the kind
of behavior the Nevada Gaming Commission wants to implicitly instill
in its other licensees?  I certainly hope not.

Chuck Humphrey
Cehjr43@earthlink.net
(760) 408-6146