June 3, 2024 Senate of Canada Standing Committee on Transport and Communications Re: Bill S-269,

an Act respecting a national framework on advertising for sports betting Dear Committee Members; Hello. I wish to contribute to the study of Bill S-269 to regulate sports betting advertising. I am a retired lottery advertising executive in Western Canada. I have advertised and operated legal sports wagering in Western Canada under the SPORT SELECT brand for the Western Canada Lottery Corporation. I am not writing to you with respect to whether sports wagering advertising should be regulated. I am in favor of more regulation.

In particular I am critical of how Ontario sports wagering advertising has been permitted to be implemented without controls on media spill outside of Ontario. Certainly, Ontario's sports gambling business model is partly the cause of the inundation of sports gambling advertising across the country. Ontario has chosen to allow multiple private sector operators to operate sports betting, which pits them against each other for market share, hence the need for an ultra-high level of advertising.

These operators are buying media time wherever they can, including on national media sports broadcasts, whose signals spill over into other provinces where they are not licensed to operate. The fine print in the ad may state 'Only in Ontario' but this does little to the viewer located out of province who is constantly exposed to the ads. This issue was always faced in the lottery industry, where Ontario may have bought national airtime to promote their regional games.

It is not desirable, as advertising a regional game, such as Ontario advertised in Alberta for example, is a waste of media spending for Ontario and confusing for consumers in Alberta. The five lottery corporations in Canada always had a 'gentleperson's agreement' to not place ads that could not be geo-controlled to appear in their own market only. This practice would be most appropriate in this new sports betting world; however, this would not be favored by the Ontario operators as it would reduce available media inventory and drive up costs.

It would also not be favored by sports media companies, who could lose revenues. These same media companies also have a vested interest in some sports media companies. I have written to the Ontario regulator asking for this to be considered but was re- directed to my provincial regulator. This makes no sense as only the Ontario regulator can place controls on the Ontario operators. As you move forward with Bill S-269, I ask you please consider incorporating regulation on gambling advertising to appear only in the jurisdiction the operator is permitted to conduct business in.

While this would not address the sports betting advertising volume in Ontario, it would almost eliminate it in all nine other provinces. Thank you for your consideration. Regards Ken Schulzke Red Deer, Alberta