Tiltproof Incorporated Document No. Effective Date Revision Date Approval 5.15.3.

4 4/24/2007 1/11/2008 SM

Collusion: Cash/Ring Game Cases

1.0 Purpose:

This document establishes how to investigate collusion in live cash games.

2.0 Persons Affected:

1) Fraud Analysts

3.0 Forms, Checklists, Flowchart:

1) Printable version: \\tpfs1nw\workflow$\HANDBOOK-FRAUD\Print Versions\Fraud Handbook\5.15.3.4 Collusion Live Cash Game Cases.doc

4.0 Policy:

1) When an account is paused for involvement in collusion, the case should be resolved within 72 HOURS. This includes account trapping, reimbursements, and emailing. 2) Only investigate hand histories if the reported players have one or more of the following: Serial relationship. MAC relationship. IP relationship. Transfer history. Shared processors. Shared account information. Address Name Similar account information. Player 1 has their real name listed as Jane Doe and Player 2 has the registered email address <jdoe@hotmail.com>. Players have played five or more cash game sessions with each other during the last 120 days.

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3) A collusion investigation initially involves a review of 30 hand histories (HHs) where both players participated. If three hands provide evidence of collusion, the player is confirmed guilty of collusion. If no hands show evidence of collusion, the investigation is closed. If one hand shows evidence of collusion, 30 more hands are reviewed (60 total). If two hands show evidence of collusion, 60 more hands are reviewed (90 total). If two hands show evidence of collusion after 60 hands are reviewed, 30 more hands are reviewed (90 total). 4) Any exception to the number of hands reviewed must be approved by a Fraud TL. 5) An investigation is closed if: a) Only one or two hands show evidence of collusion after 30-90 hands have been reviewed. b) The players have participated in a high amount of cash game sessions together but the hand histories contain insufficient evidence of collusion. c) A clear relationship is found between the players but the hand histories contain insufficient evidence of collusion. 6) 7) The amount redistributed must not exceed the amount seized unless a Fraud TL or Manager has given approval. If a seizure exceeds $5,000, the Fraud and Investigations Manager must be contacted in person or by email before any action is taken. The player must not be paused, trapped, or emailed. This document applies to all collusion investigations. If you are investigating a special case and feel an exception to this procedure is warranted, complete an Investigation Report and send it to <collusionreview@tiltproof.ca> and notify a Fraud TL or Manager.

8)

5.0 Procedure:

A) Handling Collusion Complaints 1) Investigate the following relationships between the players: a) Serial, MAC and IP relationships as per 2.4.2.9.8 Login Details Tab (Know101). b) Player transfer history as per 2.4.2.9.3 Transaction History Tab (Know101). c) Shared account information in WAT. Address Name Email address

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d) Similar account information in WAT. Player 1 has their real name listed as Jane Doe and Player 2 has the registered email address <jdoe@hotmail.com> e) If they have participated in five or more cash game sessions with each other in the last 120 days. i) Run a Know100 report for the players as per 2.5.1.1 Running a Know100. ii) Determine if the players have participated five or more cash game sessions with each other in the last 120 days as per 2.5.1.2.4. Table Balances, Table Play and Overall Threshold Balances of Players. 2) Input the results of the investigation into the spreadsheet Case Assignments.xls in [S:\FTP_Fraud_Department\COLLUSION\Case Assignments.xls]. Plaintiff name and email: Players first name, last name and email address. Suspect players: Player IDs suspected of collusion. Open Date: Todays date. Closed Date: Leave blank. Ownership: Your name. Game: SNGs or MTTs. Result/Response: Any important notes. B) No Relationship is Found Closing an Investigation 1) Review the complainers email history to determine if it is their first concern about collusion between the suspected players as per 2.9.2. Customer History. 2) If it is the complainers first concern about collusion between the suspected players: a) Send them col.not.cash. b) Input the results of the investigation into the applicable columns in the spreadsheet Case Assignments.xls in [S:\FTP_Fraud_Department\COLLUSION\Case Assignments.xls]. Closed Date: Todays date. Result/Response: Add summary of case conclusion. 3) If it is not the first time the complainer has expressed concern about collusion between the suspected players, review hands as per C) Relationship Found Reviewing Hand Histories. C) Relationship Found - Reviewing Hand Histories 1) If hand numbers were provided by the player that complained or can be determined using the information provided, run the HHs as per 2.5.2.1 Running a Hand History Report. 2) If no hand numbers were provided and cannot be determined using the

Tiltproof Incorporated information provided: a) Send complainer col.need.info. b) If complainer does not reply, or is unable to provide more information, the case is closed. c) If complainer replies, review the hand histories as per 2.5.2.1 Running a Hand History Report. 3) If insufficient collusion is found: a) Notate suspected offenders accounts with Col: Player cleared of collusion with player xxx.

b) If it is the complainers first concern about collusion between the suspected players, send them col.not.cash. c) If it is the complainers second concern about collusion between the suspected players, send them col.not.cash2. 4) If inconclusive evidence is found: a) Send the investigated players col.no.play. b) Notate accounts with COL: Issued warning not to play in SNGs or Cash Games with Player XXX.

c) If it is the complainers first concern about collusion between the suspected players, send them col.not.cash. d) If it is the complainers second concern about collusion between the suspected players, send them col.not.cash2. e) Input the players information in Warned Player Follow Ups.xls in [S:\FTP_Fraud_Department\COLLUSION]. f) Save and close the spreadsheet. 5) Input the results of the investigation into the applicable columns in the spreadsheet Case Assignments.xls in [S:\FTP_Fraud_Department\COLLUSION\Case Assignments.xls]. Closed Date: Todays date. Result/Response: Add summary of case conclusion. 6) Save and close the spreadsheet. 7) If you have questions about the case: a) Fill out Investigations Notes in [S:\FTP_Fraud_Department\COLLUSION\Collusion Procedures\Investigation Notes - Template.rtf] b) Save the spreadsheet. c) Attach the spreadsheet to an email and send it to <collusionreview@tiltproof.ca>. d) A Fraud TL will respond to your concerns within 72 hours for your reference D) Collusion Confirmed Seizing or Redistributing Amounts Under $500 1) Fill out Investigations Notes in [S:\FTP_Fraud_Department\COLLUSION\Collusion Procedures\Investigation Notes - Template.rtf] and save it in your U: Drive for your own records. 2) Determine the offenders serials as per 2.4.2.9.8 Login Details Tab

Tiltproof Incorporated (Know101). 3) Trap the offenders accounts and serials as per 3.3.23 Trapped, Paused or Closed Accounts. 4) Notate the guilty accounts with COL + TRAP: Player is guilty of collusion with Player XXX in H# XXX. Permanently banned from Full Tilt Poker. Notate the innocent victims accounts with COL: Player was victim of collusion between Player XXX and Player YYY in cash games in H#XXX. Compensated $xxx. Send the offenders col.guilt. Send the complainer col.credit.cash. Send the innocent victims col.credit.cash2. Input any seizure or deposit requests in [S:\FTP_Fraud|Daily Reports\ (Month) Deps+Seizures Log.xls] for the current month. a) b) c) d) e) f) The current date. Type: Seizure/Deposit. Player ID of account. Amount. Fraud Analyst name. Email Required: Yes/No.

5) 6) 7) 8) 9)

A player will need to be sent an email when the seizure/deposit is complete if they have not been informed of the seizure/deposit, or if the status of their account will change. g) Item Actioned: Leave blank. h) Fraud Analyst: Leave blank. i) Email Sent: Leave blank. j) Additional Notes: The account notation in WAT. 10) Save and close the spreadsheet. E) Collusion Confirmed Seizing or Redistributing Amounts Over $500 1) Determine the offenders serials as per 2.4.2.9.8 Login Details Tab (Know101). 2) Trap accounts and serials as per 3.3.23 Trapped, Paused or Closed Accounts. 3) Send the offenders col.acc.review. 4) Fill out Investigations Notes in [S:\FTP_Fraud_Department\COLLUSION\Collusion Procedures\Investigation Notes - Template.rtf] and send an email to <collusionreview@tiltproof.ca> for a final decision on whether the players are guilty of collusion.

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5) If Fraud Management informs the collusion is inconclusive, the investigation is closed. a) Untrap the accounts and serials as per 3.3.23 Trapped, Paused or Closed Accounts. b) Send the investigated players col.no.play. c) Notate accounts with COL: Issued warning not to play in SNGs or Cash Games with Player XXX.

d) If it is the complainers first concern about collusion between the suspected players, send them col.not.cash. e) If it is the complainers second concern about collusion between the suspected players, send them col.not.cash2. f) Input the results of the investigation into the applicable columns in the spreadsheet Case Assignments.xls in [S:\FTP_Fraud_Department\COLLUSION\Case Assignments.xls]. Closed Date: Todays date. Result/Response: Add summary of case conclusion. g) Input the players information in Warned Player Follow Ups.xls in [S:\FTP_Fraud_Department\COLLUSION. h) Save and close both spreadsheets. If Fraud Management agrees there is sufficient evidence of collusion: a) Send the offenders col.guilt. b) Send the complainer col.credit.cash. c) Send the innocent victims col.credit.cash2. d) Notate the offenders accounts with COL + TRAP: Player is guilty of collusion with Player XXX in H#XXX. Permanently banned from Full Tilt Poker. Notate the victims accounts with COL: Player was victim of collusion between Player XXX and Player YYY in H#XXX. Compensated $xxx.

e)

f) Complete the document [S:\FTP_Fraud|Daily Reports\(Month) Deps+Seizures Log.xls] for the applicable month with: i) The current date. ii) Type: Seizure/Deposit. iii) Player ID of account. iv) Amount. v) Fraud Analyst name. vi) Email Required: Yes/No. vii) Item Actioned: Leave blank. viii) Fraud Analyst: Leave blank. ix) Email Sent: Leave blank. x) Additional Notes: The account notations in WAT. g) Save and close the spreadsheet. 7) If you disagree with the initial decision from Fraud Management:

Tiltproof Incorporated a) Enter an explanation and any additional information in the Investigations Notes in [S:\FTP_Fraud_Department\COLLUSION\Collusion Procedures\Investigation Notes - Template.rtf] b) Save and close the spreadsheet. c) Send an email to <collusionreview@tiltproof.ca> requesting a second and final review of the case.

6.0 Definitions:

7.0 Revision History:

Jan 11/08 Policy and Procedure major changes. Read entry again. Sept 28/07 Policy and Procedure major changes. Read entry again.