Office of the Commissioner

MAJOR LEAGUE BASEBALL

Bryan Seeley
SVP & Deputy General Counsel

February 20, 2019
Via UPS & Electronic Mail
Sandra Douglass Morgan
Chairwoman
Nevada Gaming Control Board
1919 College Parkway
Carson City, Nevada 89706
Re:

Major League Baseball’s Request to Restrict Wagering on Spring Training

Dear Chairwoman Morgan:
I write on behalf of the Office of the Commissioner for Major League Baseball (“MLB”)
and its 30 Clubs to request that the Nevada Gaming Control Board restrict all sports wagering on
MLB’s Spring Training games. Such games are exhibition contests in which the primary focus
of Clubs and players is to prepare for the coming season rather than to win games or perform at
maximum effort on every single play. These games are not conducive to betting and carry
heightened integrity risks, and the Board should not permit bookmakers to offer bets on them.
The Office of the Commissioner is the governing body for MLB and is tasked with
protecting the integrity of America’s national pastime. MLB’s concerns discussed herein
sufficiently establish good cause to prohibit betting on Spring Training games. MLB’s preseason
is commonly known as “Spring Training” and commences when pitchers and catchers report to
training facilities in Arizona and Florida in mid-February. Spring Training includes practices
and a series of exhibition games between MLB’s 30 Major League Clubs. On occasion, Clubs
also play exhibition games against collegiate, Minor League, and national teams from other
countries. In 2019, Spring Training games will commence on February 21 (tomorrow) and
conclude prior to Opening Day on March 28.
Spring Training is practice. Players work to improve their individual performance and
ability to perform together as a team. Clubs and coaches develop, test, and refine strategy in
preparation for the regular season. Spring Training statistics and win-loss records do not count
for anything. In short, the emphasis of Spring Training is on preparation for the regular season
rather than winning or performing at maximum effort on every single play.
Spring Training is also an opportunity for Clubs to evaluate non-roster players and
finalize their regular-season rosters. Clubs invite Minor League players, as well as veteran free
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 Chairwoman Morgan
February 20, 2019
Page 2
agents, to participate in Spring Training alongside the players likely to make the regular-season
roster. By the later innings of a typical Spring Training game, the field is largely populated with
Minor League players who will not make the Opening Day roster.
For these reasons, Spring Training games are not conducive to betting and carry
heightened integrity risks. Any game or play in which winning or losing may not be the primary
objective is much more vulnerable to manipulation. This risk is particularly acute when many of
the participants are lower-paid non-roster players. Moreover, Spring Training games provide
greater opportunity for the misuse of inside information. The outcome of games sometimes
depends heavily on non-public managerial decisions that are made in advance and are
independent of Club or player performance, such as how many innings a pitcher will throw or in
which inning Minor League players will replace Major League players.
There is no less restrictive alternative to prohibiting betting on Spring Training. Even if
in-play bets are disallowed, bettors could still wager on games that have no consequence on the
standings and on players who are targets for manipulation. Any wagering on Spring Training
presents integrity risks that are sufficiently high to warrant a total betting restriction. Further, at
a time when other major professional and collegiate sports leagues are in season, bookmakers do
not need to offer betting on Spring Training to remain financially viable. The risk to MLB and
baseball fans in Nevada far outweighs the reward to Nevada bookmakers for offering such
betting.
Accordingly, MLB requests that the Board restrict all wagering on Spring Training
games. MLB is making this request now because legal sports betting is rapidly expanding
throughout the United States. Limited and historically in-person betting on Spring Training in
one state did not pose nearly the same integrity risks that widespread betting on Spring Training
in multiple states will pose, particularly when some of those states have populations several
times the size of Nevada’s population. In order to discourage the development of betting
markets around Spring Training games nationwide, MLB will request the same restriction to the
appropriate state regulator in any state where such betting is offered.
We would be happy to discuss this request with the Board at its convenience, though we
note that Spring Training begins tomorrow, which makes this request time-sensitive. Thank you
for considering this important request and for assisting our efforts to protect the integrity of the
sport. We look forward to working with you.
Sincerely,

Bryan Seeley