Way Out West – Wickenburg, AZ

Sitting in the shadows of the rising Phoenix, a small town full of cowboy history and culture awaits just a short jaunt away. I could have used the description short “drive”, but out here a horse is considered a major part of the public transportation system, and many locals tend to “drive” the cows. This town is well known for dude ranches and open spaces, but more know it as the stop on the way to the gambling destinations of Nevada. Why not take a gamble on Wickenburg, Arizona? It is your best bet along the way.

Wickenburg was founded in 1863 when Henry Wickenburg, a Austrian prospector, found gold around the area of the Vulture Mountains of central Arizona. Soon after the mining and ranch foundations of the town were laid, and a western town was born. The town celebrates it’s history in many ways, much which can be seen still today. From ghost towns to festivals, there are numerous opportunities to immerse yourself in Wickenburg’s western heritage.

One of the biggest western festivals of it’s kind, the annual Gold Rush Days draws thousands of visitor’s from all over to celebrate the mining history of the area. The weekend in February offers mining competitions, melodramas, and one of the largest parades in the state on Saturday. If you are in town at any time of year, be sure to visit the Chamber of Commerce located in the historic railroad depot on Frontier Street. This is a great place to start and get the skinny on the history of the town and the places and things you will want to do. Be sure to check out the old Santa Fe steam engine right outside the station. Many shops and artisans are located around the downtown area from here. Some of the highlights include Ben’s Saddlery Shop, Buckshot Babe’s, and some of the best Turquoise jewelry in the state at Danny’s. Take a walking tour of downtown and you will find a few “guides” around town to help you learn a little about it’s history. These guides are actually statues located around town and with the push of a button will tell you a tale of the town’s past.

For a town of it’s size, the selection of restaurants is pleasantly plentiful. The best thing you will find about Wickenburg’s eating establishments is character. Mom and Pops are very well represented, with Anita’s, Rancho Bar 7, and the Cowboy Cafe to name just a few. After a good meal check out a movie over at the historic Saguaro Theater, built in 1948 it’s signage and original ticket booth are still intact. And as far as movie popcorn goes, this place knows how to pop those kernels. Wickenburg is the obvious place for that Dinner and a Movie date that you need to take.

The two best things about Wickenburg to do we have yet to mention. Desert Caballeros Western Museum and the Vulture Mine townsite. For a town of less than 10,000 people, the museum here is the toast of the town. With a western art collection that includes greats like Remington, Russell, Moran, and Weighorst, this is the little museum that could…and does. Besides the ever changing exhibits to keep you coming back, the permanent historical part of the museum includes a 1915 Arizona street scene complete with a saloon, watch shop, livery stable, post office, church, and general store. There is also a Victorian house recreation to show how things were back in the old west. This is a must see in Wickenburg, appreciate, learn, and enlighten.

Vulture Mine was the original location of Henry Wickenberg’s gold find. Just in sight of Vulture Peak, the town of Vulture City was founded here to support the mining. At one point the population was as high as 5,000 who would call this desert town home. Many of the original buildings are here, and a self guided tour is offered to those that are up to it. The original hanging tree is still there, in a town where 18 were hung from this old Ironwood. Some say there are ghosts that still haunt this area. Isn’t this a little obvious? I mean this is a Ghost Town.

There are many things we have not covered, but there is so much to be discovered. Wickenburg is just a short distance from Phoenix and a long distance away in your mind. Be sure to take a trip soon and get in touch with that western spirit that this great Arizona town has to offer.

The "Amish Mafia", Underage Drinking and Host Liability

The new television show, “Amish Mafia,” is creating quite a stir in both the Plain and English communities. Reports indicate that this is the most successful show ever launched by the Discovery Channel and that there are now in excess of 3 million viewers per episode.

A small group of Amish and Mennonite men and women are portrayed as an organized crime family, with “Lebanon Levi” heading the operation and directing its activities. Levi Stoltzfus, the son of an actual Amish Deacon (David Peachey), has a number of henchmen, including Alvin, John and Jolin. In an initial episode, Alan Beiler, (the adopted son of a Lancaster Mennonite family and described by his colleagues on the show as “Schwarz Amish”) was indicated to have been a key associate of Levi’s, but criminal charges landed him in hot water with both the gang and the Pennsylvania State Police. He disappeared from subsequent episodes but just reappeared at the end of the season, being shown leaving prison. Levi also has a love interest, Esther Schmucker, a woman portrayed in what is described as Amish garb, who is the sister of John Schmucker, both in the show and in real life. Alvin Lantz, described and portrayed as Amish, acts as Levi’s right hand man. He is second in command and takes over when Levi travels to a Florida beach for a get away with Esther.

John and Esther express dissatisfaction with John’s limited role in Levi’s operation. Their father had headed this organized crime operation prior to his death. For some reason, John was unable or unprepared to step up and take over. Levi stepped in to fill the void. John is also frustrated by the limited income he receives for his efforts. He is the only gang member who has yet to have enough money to buy a car. This is a source of significant conflict between John and the others. As a result, John becomes an easy recruit for Merlin, an Amish-man from Holmes County, Ohio who is looking to extend his criminal enterprise to Lancaster County. He has plans to force Levi out and take over his operation in Lancaster.

Merlin, who explains that he became tough while serving a sentence after a criminal conviction as the only Amish inmate in an Ohio prison, comes to Lancaster to compete in what Levi describes as a “Pimp Your Buggy” competition. This event takes place in conjunction with a small car show and includes a number of buggies. Merlin arrives in his very fancy buggy and, based on a prior understanding with John, expects to win the money that goes along with first prize. That plan goes awry when a ringer, a friend of Levi, shows up in a hot rod t-bucket type buggy. At that point Merlin realizes he has been outmaneuvered. He becomes very angry and describes how he will get even.

The final episodes of the first season depict Merlin’s efforts to make this happen. He recruits John to arrange and stage buggy races. The show indicates that such races are very popular in Ohio and a source of revenue for Merlin’s operation. Levi does not allow such races in Lancaster. John is successful in putting a race together. There is much betting on the several entries. Alvin and Jolin find out about the race, show up, and proceed to destroy John’s buggy at the conclusion of the race. Merlin, unhappy with this show of strength by Levi’s guys, follows Levi and Alvin to a bar in Lancaster. While Levi and Alvin are inside drinking, one of Merlin’s strongmen smashes out the front window of Levi’s Cadillac with an ax. To be sure that Levi understands who was behind this act, a business card with the name “Merlin” is left under the driver’s side windshield wiper. Subsequently, Merlin’s associates destroy Levi’s office and then torch the temporary trailer he was using as an office.

Levi and Alvin then drive to Ohio to meet with Merlin’s Bishop. When Merlin goes to collect protection money from one of his “customers”, the client will not deal with him. It is said that Merlin is being shunned at the Bishop’s direction and that it can take up to six months to be reinstated into the community. Merlin is angry and he vows to get even. About the same time, Alan Beiler is being released from prison. He borrows a cell phone to call Levi. He tells Levi that he is mad because he spent four months in prison after Levi called the cops on him. He warns Levi to “watch his back.”

The stage is set for the drama to continue in the second season.

A key question being raised among viewers (evidenced by numerous message board posts in response to newspaper articles about the show), bloggers and the media is whether or not this show is portraying actual events or if the show is a total fabrication.

The promotional material on Discovery’s website states that for many years the Amish, “due to a distrust of outside law enforcement,” have turned to this gang in order to maintain peace and order within the Lancaster County Amish community. The site provides the following description.

“This is a side of Amish society that exists under the radar, and the Amish church denies the group’s existence. Amish Mafia provides eyewitness accounts of the incidents, misdeeds and wrongdoings within the Amish community, as well as a rare look at Levi and his team members who work together to maintain harmony. To protect participants and their family members, some identifying information and property has been changed. Some scenes have been reenacted.”

There are many scenes in which members of the gang are shown engaging in violence, using profanity and acting in ways many may think do not show the Amish community in a positive light. In a scene in one episode, the gang responds to the report of an Amish Bishop in a motel room with a prostitute. In another, Esther, now infatuated with Jolin, accompanies him to a gun range and is shown shooting Jolin’s AR-15 rifle. Esther is shown attending a fair with a girlfriend and riding a mechanical bull. She comments that both of these activities are not permitted for Amish women.

The show suggests that these gangs collect money for “fixing” problems, from business owners paying protection money, from gambling, by holding barn fights and hut parties and other illegal activities. Regrettably, the promoters of the show even use the tragedy of the Nickel Mines School incident to promote the show, writing on their website:

“The 2006 School shootings in Lancaster County during which five young Amish girls were killed and five more seriously injured by a non-Amish milk truck driver brought to the nation’s attention the vulnerabilities of the Amish community, and their need for continued protection.”

Archangel Investigations is currently conducting an in-depth investigation into the show, its actors and the events shown to determine if there is any truth at all to either the existence of this organized crime operation or the incidents portrayed. The results of that investigation will be shared with readers in a subsequent issue.

In this issue, we want to address a very delicate and somewhat controversial topic – that being the tradition of drinking by youth. This underage drinking raises a number of concerns, including the risk of criminal charges for the children and their hosts, the severe financial consequences the hosts of the party will face if one of the attendees at party where alcohol is being served is involved in an accident with non-Plain community members and the potential for starting the alcohol abuse ball rolling for our children. And many believe that alcohol is a gateway substance, that can lead to the use and abuse of more serious illegal drugs. The purpose of this article is not to address the social, religious or community issues surrounding this issue. Rather, as business people who on a regular basis evaluate the risks involved in business transactions, it is important to also evaluate the risks you may be unwittingly exposing your business assets to by way of actions in your personal life.

Several times in the first season episodes of the show, scenes are shown of Amish, Mennonite and English young men and women attending “hut” parties. The suggestion given by the show is that these parties occur regularly and are an important source of revenue for the gang member promoters. While we are not, at this point, confirming the existence of parties hosted by Lancaster’s supposed Amish Mafia, it has been a long tradition for Plain community youth to attend parties at which alcohol is served. As businessmen and property owners, it is important for you to have an understanding of the risk to both your liberty and assets that you assume by hosting, or allowing these parties to be hosted, on your property.

Some parents may feel that underage drinking is something akin to a “rite of passage” and that it is better to let their minor children and their friends indulge in the consumption of alcohol on their own property, under adult supervision, rather than for the kids to be out drinking somewhere else. This is a completely understandable sentiment, but unfortunately it is also completely wrong, legally speaking, and may result in very severe criminal and costly financial consequences for you. The fact is that furnishing alcohol to minors is against the law in nearly every circumstance and the police will arrest you if they discover that it has occurred (by the way, in case you were wondering, there is a limited exception that is intended to exclude traditional religious communion service. The aforementioned criminal statute does not apply to any religious service or ceremony which may be conducted in a private home or a place of worship where the amount of wine served does not exceed the amount reasonably, customarily and traditionally required for the ceremony.

While a Plain community parent is very unlikely to report underage drinking parties to the police, it appears that these parties are also frequently attended by non-Plain young men and women. If one of these kids arrive home drunk and the parents find out, it is very likely that the police will be called. If that happens, the police will come calling and it won’t be for a social visit. You may find yourself under arrest even though you were acting with the best of intentions.

Furnishing alcohol to a minor is a crime. The definition of furnishing alcohol to minors can be found in the Pennsylvania Crimes Code at 18 Pa.C.S. Section 6310.1. The Statute is entitled “Selling or Furnishing Liquor or Malt or Brewed Beverages to Minors.” In order to be convicted of furnishing alcohol to minors, the Commonwealth must prove the following beyond a reasonable doubt:

(1) you intentionally or knowingly;

(2) sold, furnished or purchased with the intent to furnish;

(3) any liquor or malt or brewed beverage (i.e. any alcoholic beverage;

(4) to a person who is less than 21 years of age.

If the Commonwealth meets its burden of proof as to all of the elements of this crime, a misdemeanor of the third degree will be on your record and you will be required to pay a mandatory fine of not less than $1000 for a first offense and $2500 for each subsequent offense. A misdemeanor of the third degree carries a maximum sentence of 1 year incarceration. This means the maximum probationary term for a conviction of furnishing alcohol to minors is 1 year. One year probation and a mandatory $1000 fine would be a typical sentence for the first offense of this crime.

The criminal sanctions set forth above, as unpleasant as they are, can almost be considered mild compared to the financial consequences that may result if one of the minors you “hosted” and furnished with alcohol should become intoxicated and cause serious injury to himself or others. Pennsylvania courts hold all persons liable under social host liability laws if they knowingly serve a minor alcohol.

The Pennsylvania Supreme Court case of Congini vs. Porterville Value Company, 504 PA. 157, 470 A.2d 515 (1983) held that social hosts may be liable for supplying minors with alcohol. In this case, the Court determined that social hosts serving alcohol to minors to the point of intoxication are negligent per se and can be held liable for injuries resulting from the minor’s intoxication. The Court explained the reason for having a different rule for minors as opposed to adults served alcohol by a social host is that “… our legislature has made a legislative judgment that persons under twenty-one years of age are incompetent to handle alcohol.” Later cases have expanded the ruling to hold that the service of intoxicating liquors to a minor by a social host is negligence” per se”, even if the liquors are not served to the point of intoxication.

Naturally, certain elements must be proven to hold a social host liable for damages caused by the minor drinker. The key factors are knowledge and intent. The Pennsylvania Courts have established the following three part test to determine whether a social host would be subject to liability for injuries arising out of a minor’s intoxication.

1 the defendant must have intended to act in such a way as to furnish, agree to furnish or promote the furnishing of alcohol to a minor;

2 the defendant must have acted in a way which did furnish, or promote the furnishing of alcohol to a minor; and

3 the defendants act must have been a substantial factor in furnishing, agreement to furnish, or promotion of furnishing alcohol to the minor.

What this all means, in layman’s terms, is that if you furnish alcohol to minors you run a great risk of suffering arrest and criminal punishment, including a possible jail sentence and a heavy fine and/or perhaps more significantly, civil liability for the damages caused by the minor to whom you have furnished alcohol. Certainly, if the intoxicated youth causes a mere fender bender with little property damage and no injuries or minor injuries, the financial consequences may not be earthshaking and perhaps little more than a nuisance. Consider, however, the situation where the accident is not so insignificant and where a third party received permanent injuries such as paralysis, requiring long term, life time care of the injured party. Under America’s tort system the injured party and his family are going to seek compensation from every conceivable person and the “social host” will be a prime target. Your financial assets, including personal and real property, along with your business holdings, could very well be targeted by the plaintiff in a lawsuit.

The consequences of a well intentioned desire to allow minors to enjoy a rite of passage on your property, where they will be safe and supervised while imbibing alcoholic beverages, could be cataclysmic. The decision to allow such an event could cost you dearly. Fortunately, this is a rather easy problem to avoid. No matter what the traditions, simply do not furnish alcohol to minors and do not allow them to drink alcohol on your property.

Pick 4 Lottery Strategy System Picks the Right Pick 4 Strategies to Win

A good Pick 4 Lottery System has more than just one Strategy; it has a number of Pick 4 Strategies to offer the lottery players multiple ways to find the next winning number.

These multiple Pick 4 Strategies open the door for the players to take advantage of various number trends that can take place at any given time during this lottery game.

In March 2010 there seems to be an overabundance of Pick 4 Triples and Double-Doubles based on the low percentage for these types of Pick 4 numbers to be drawn over a period of time. These two groups of numbers represent just 6.3% of all 10,000 Pick 4 numbers. Their collective combinations total 135 of 715 combinations for all Pick 4 numbers. There were approximately 125 of these types of numbers drawn in the U.S. and Canadian Pick 4 Lotteries in March 2010.

Another Pick 4 lottery anomaly is the current amount — over twenty — of traveling numbers that began in March 2010 and is carrying over into April 2010. A traveling number is the same set of four digits that make up a winning Pick 4 number that is drawn two or more times over a short period of time in more than one State. The perfect definition of a traveling number includes that the same number being redrawn in the exact order. But the traveling Pick 4 Box form is quite acceptable for the purposes of winning free money.

Triples and double-doubles are the highest paying Pick 4 Box numbers. Triple numbers, such as 1112, pay $1200 for one single $1 investment. The dollar investment on the double-double number, such as 1122, returns $800.

The key to being a successful winning Pick 4 player is to have a multiple Lottery Strategy System. It provides the right Pick 4 Strategies which enable Pick 4 players to have strategies to create and play these ongoing number trends as they occur.

Combining strategies for playing triples and double-doubles with the traveling number strategy gives the player the right Pick 4 strategies to win some very nice payoffs. A perfect example of the double-double traveling number occurred with the combination draws of 8877 first in the Delaware Pick 4 Midday draw, March 22, 2010, and the April 4, 2010, Evening draw in the Kentucky Pick 4 Lottery. Players of this lottery game using both these strategies have put the 8877 on the watch list. The New York Win 4 lead the way with the evening drawing on March 30, 2010, of 0660 and followed up with this same number being drawn in the evening draw in the West Virginia Pick 4 Lottery.

The Indiana Hoosier Lottery Daily 4 began this imperfect trip, but nevertheless a profitable one for the New York Win 4 players when the third box form of 5757 was drawn in the midday draw on March 31, 2010. The Indiana Daily 4 first drew 7755 on March 18, 2010, midday draw. Traveling east to the Ohio Pick 4 Lottery, the OH Pick 4 drew 7557 in the evening draw on March 22, 2010.

The Big Apple State continued to provide big winning slices of cash for their Big Apple Win 4 players when it drew the third box form of the triple 7111 on the evening of April 4, 2010.

Previously, again starting out in the Indiana Daily 4 on the evening of March 16, 2010, the first triple box form was drawn as 1171. Then, traveling southeast to the Georgia Cash 4 was 1711 which was drawn in the evening draw on March 30, 2010. Like the New Year’s Eve Times Square countdown it gave New Yorkers one more thing to celebrate, another pocketful of NY Win 4 Lottery Free Money.

In a rare return home Pick 4 traveling number, trend players keeping an eye open for these two strategies to converge once again, Oregonians in the Oregon Pick 4 Lottery were glad to welcome back the 0400 on March 18, 2010, in the 7pm drawing. It was first drawn here in the 1pm Pick 4 drawing on March 8, 2010. It then traveled to Florida and was drawn in the Florida Play 4 as 4000 on the evening of March 16, 2010 before boarding the flight home to the Oregon Pick 4.

To be a Pick 4 Winner you need a Pick 4 Lottery Strategy System with multiple Pick 4 strategies. It is the only way that Pick 4 players around the country and around the world have a real chance to win some big money. Systems that offer just one strategy to play or recommended to play just the single Pick 4 type numbers do not give you the same chance to win. Often times the reality is that the one strategy or the recommended “Pick 4 Single Number Pick 4 Systems” create “automatic losers” for both the numbers and the players.

All Pick 4 players need to keep their eyes open for these traveling numbers in all forms, 0660, 7755, 1711, and 0400, that could travel to the remaining Pick 4 U.S. Lotteries, the Caribbean Pick 4 Lottery, Ontario Pick 4 and La Quotidienne 4, the two Canadian Lottery Pick 4 Games. One or more of the other strategies in the Pick 4 System may just predict the arrival of one of these traveling numbers to your local favorite Daily 4 Lottery game.

Where Internet Jurisdiction Can Get Your Business Sued!

The concept of Internet jurisdiction can be complicated and unclear. What happens when a dispute arises over an item or service purchased from your business through the internet? If that dispute turns into a lawsuit, it could be with an individual residing across the country from your business. What happens then? If you live in California, could your business actually be dragged into a state court in Maine?

Any business with an Internet presence should understand how courts gain authority to hear claims made against out-of-state businesses. The bottom line is that establishing Internet jurisdiction over your business can potentially end up being very costly!

Establishing Internet Jurisdiction Over Your Business

No matter what the subject of the dispute is about, a court must have what is known as “personal jurisdiction” over all the parties involved. This applies to all courts, including state and federal district courts. Establishing personal jurisdiction means that the court has the legal power to make a binding decision over the plaintiff and the defendant in a given dispute. State and federal courts always have personal jurisdiction over state residents. But, when the defendant’s principal residence or place of business is not in the state where the lawsuit is filed (often called the “forum state”), matters are much more complex. This is often the case with suits involving e-commerce.

(Note: A corporation is treated as a citizen of the state in which it is incorporated and the state in which its principal place of business is located. A partnership or limited liability company is considered to assume the citizenship of each jurisdiction of its partners/members. If you understand the nature of how a court can gain jurisdiction to hear a claim filed against your business, you can avoid certain practices that may expose you to out-of-state claims.)

The Concept of Minimum Contacts

One way a foreign court can claim personal jurisdiction over your business is by establishing that some sort of meaningful connection exists with the state in question and your business. States can exercise jurisdiction over your business through their “long-arm statutes” (which I discuss separately). However, the Due Process Clause of the U.S. Constitution mandates that certain “minimum contacts” must exist between the forum state and the defendant in order for a state to assert jurisdiction over the defendant. This basically means that activities which are deemed to establish substantially sufficient contacts with the residents or businesses of a particular state can be used by its courts to establish jurisdiction over your business. For example, you are not subject to the personal jurisdiction of an out-of-state court simply because you are involved in an automobile accident with a resident of that state where you live. All the events necessary to give rise to the claim occur outside the state of the other resident.

Activities establishing minimum contacts with another state are not always clear, but usually any substantial presence in the state will justify personal jurisdiction. Regularly soliciting business in that state, deriving substantial revenue from goods or services sold in that state, or engaging in some other persistent and continuous course of business conduct in the state are all examples of activities that would establish minimum contacts with that state.

Minimum Contacts Define Internet Jurisdiction

As stated, the concept of minimum contacts becomes more complicated when it involves the Internet. The courts have recognized that exposing the owners of a website to personal jurisdiction simply because the website can be viewed nationally is not enough to establish minimum contacts in a given state. Personal jurisdiction is “directly proportionate to the nature and quality of commercial activity that a business conducts over the Internet.” Businesses that enter into contracts or subscriptions with residents of another state that involve the “knowing and repeated transmission of computer files over the Internet will be subject to the jurisdiction of out-of-state courts. But, websites that only post information without making active sales are unlikely to establish personal jurisdiction in a foreign state (except in the state where the owner(s) resides or conducts other business).

The ‘Zippo’ Sliding Scale Guide

Generally speaking, minimum contacts for Internet retailers and marketers are directly related to the nature and quality of electronic contacts they establish with residents of another state. In other words, mere advertising alone is not enough to establish jurisdiction. Most courts across the nation have adopted the “sliding scale” approach used in Zippo Manufacturing Co. v. Zippo Dot Com, Inc. (1997). The court in Zippo determined that the act of processing the applications from Pennsylvania residents and assigning passwords was sufficient to demonstrate sufficient minimum contacts with the state. But, the Court held that jurisdiction is not proper when a website passively posts information on the Internet which may or may not be viewed by residents of that particular jurisdiction.

In the Zippo case, the district court described a spectrum consisting of three categories websites fall under. This spectrum ranges from: 1) businesses clearly conducting commercial activities over the Internet by entering into contracts with residents of the forum state; 2) interactive web sites with which a user in the forum state can exchange information and jurisdiction is proper if the level of interactivity is sufficient and there is a commercial component to the web site and 3) web sites which are “passive” by merely allowing users to post information accessible nationwide or globally that do not target a particular plaintiff in a particular forum (i.e. by intentional trademark or copyright infringement or in cases of defamation). Basically, under the Zippo sliding scale jurisdiction is more likely to be established when your Internet business engages in commercial activities directed at residents of a given state.

Of course, many cases fall in the middle of the Zippo sliding scale. In these instances, the courts generally have determined that “the exercise of jurisdiction is determined by examining the level of interactivity and commercial nature of the exchange of information that occurs on the website.” Making multiple sales to state residents is likely to expose an Internet-based business to personal jurisdiction in that state. A single sale may also be enough, provided it is accompanied by numerous intentional communications with a resident customers so that the transaction can be said to be purposefully aimed at the residents (or businesses) of that state.

Typically, the courts require “something more” than passive Internet advertising or more than just a single sale for jurisdiction to exist over a non-resident Internet business. Jurisdiction is often triggered by repeated or commercially significant sales to out-of-state residents, deliberate target marketing to out-of-state residents or significant non-Internet based contacts with the state.

State Long Arm Statutes

All states have enacted “long-arm statutes” setting forth what will be considered sufficient contacts with that state. In a nutshell, the long-arm statute allows that state’s courts to gain personal jurisdiction over Internet businesses. These statutes form the legal basis allowing the courts to exercise personal jurisdiction over your business. Under these statutes, service of process outside the state on nonresident individuals and businesses is allowed for claims generally arising out of: (1) the transaction of any business in the state; (2) the commission of a tortious act within the state; (3) the ownership, use, or possession of real estate in the state; or (4) contracting to supply goods or services to any person or business in the state; or 5) causing injury or damage in this state to any person by breach of warranty expressly or impliedly made in the sale of goods; 6) contracting to insure any person, property, or risk located within this state at the time of contracting; 7) an act or omission outside the state causing injury in the state.

State courts typically exercise personal jurisdiction over Internet businesses under the “transacting business” provision of the long-arm statute. Like the Zippo court, state courts will look at jurisdiction in an Internet setting by looking at the “nature and quality” of the contacts with the state. Some Long-arm statutes set forth factual situations likely to satisfy the minimum-contacts test. Others contain much broader provisions not inconsistent with constitutional restrictions.

Helpful Case Summaries

Here is a summary of some decisions that have helped shape the law regarding internet jurisdiction. Hopefully, these summaries can provide some guidance.

  • Thompson v. Handa-Lopez, Inc. (1998): A Texas court gained personal jurisdiction over an out-of-state online gambling enterprise because the gambling operation entered into contracts with Texas residents to play online gambling games, sent emails to the Texas residents, and sent winnings to Texas residents;
  • ChloĆ© NA v Queen Bee of Beverly Hills LLC (2010): The US Second Circuit Court of Appeals held that specific personal jurisdiction over an out-of-state website operator located in California may exist based on a single act of shipping a handbag into New York, along with other substantial business activity in the state. The single act of shipping an infringing handbag to New York combined with other substantial contacts, such as the shipment of several other items in-state and operating a commercial interactive website available to New York residents was sufficient to obtain specific personal jurisdiction;
  • Verizon Online Services, Inc. v. Ralksky (2002): The court held that nonresident defendants’ transmission of spam emails through plaintiff’s servers, located in Virginia, to nonresident Internet subscribers created a substantial connection to forum sufficient for exercise of personal jurisdiction on a claim of trespass to chattel;
  • Gates v. Royal Palace Hotel (1998): The court decided that the combination of a concentrated advertising effort within the state of Connecticut, active booking of reservations for Connecticut citizens through state travel agents, and an invitation to Connecticut citizens to make reservations through the Internet, constituted the transaction of business within the state such that exercise of personal jurisdiction was proper.

Causing an Injury within a State

Your Internet business can also be subject to jurisdiction in another state for purposefully causing a physical or economic injury (i.e. a “tort”) to a business or resident of that state. This is a separate avenue of liability outside of a breach of contract claim where your business is dragged into court by one of your unhappy customers. If you use the Internet to cause an injury in one state, you or your business may be brought into court in the state where the injury occurred. For example, under state long arm statutes, committing a tortious act within the state is a basis of jurisdiction.

Of course, in cases where the connection between the activity and the injury is not clear, courts have looked for evidence that the activity was “purposefully directed” at the resident(s) of the forum state, or that the person causing the injury had substantial contacts with the state. Most courts are less inclined to exercise personal jurisdiction over non-residents in cases involving tort claims arising from Internet use. Generally speaking, an Internet business must direct its activities at an in-state resident, or have a continuing obligation with that resident, in order reasonably to anticipate being hauled into court in the state.

But, not all torts or injuries will expose your business to the personal jurisdiction of another state. Even if a plaintiff claims to feel the effects of the harm caused by an act causing injury in his or her forum state, there must still be “something more” than mere Internet use to satisfy due process under the Constitution. Purposeful conduct may still be insufficient in jurisdictions where the activity must be directed at the plaintiff in his or her capacity as a resident of that particular state.

More case examples:

  • EDIAS Software International v. BASIS International Ltd. (1996): A New Mexico company was sued for sending defamatory email and making defamatory postings about an Arizona business. The court claimed personal jurisdiction because the defamatory statements intentionally targeted the Arizona business and actually caused an injury (defamation) within the state.
  • Pavlovich v. Superior Court (Cal. 2002): Under the “effects test”, the trial court did not have jurisdiction over a foreign resident in a corporation’s suit alleging the resident misappropriated its trade secrets by posting the corporation’s program’s source code on his website. The website was accessible to any person with Internet access and the resident merely posted information and had no interactive features. The court determined that the resident could not have known that his tortious conduct would hurt the corporation in California when the misappropriated code was first posted and this did not establish express targeting of California residents.
  • Blumenthal v. Drudge (1998): In another early decision, Matt Drudge of The Drudge Report made alleged defamatory statements about a Washington, D.C. resident on his website and the resident filed suit in the District of Columbia. Although Matt Drudge lived and worked in California at the time of the suit, a court ruled that he was subject to personal jurisdiction in the District because the injury occurred in the District. The court also determined that the Drudge Report had substantial contacts in D. C. since Drudge personally emailed his column to a list of emails belonging to D.C. residents, solicited contributions and collected money from D. C. residents and he traveled to D. C. on two occasions to promote his column. All of this was enough for the court in that case to determine that Matt Drudge had substantial contacts with the District;
  • Cybersell, Inc. v. Cybersell, Inc. (1997): An Arizona plaintiff suing for trademark infringement argued that a Florida defendant’s mere use of the same trademark in its home page was sufficient for personal jurisdiction. The Florida defendant had “no contacts with Arizona other than maintaining a home page that was accessible to anyone over the Internet.” The court declined to exercise jurisdiction, noting the Florida defendant “did nothing to encourage residents of Arizona to access its site, and there [was] no evidence that any part of its business (let alone a continuous part of its business) was sought or achieved in Arizona.” The circumstances lacked the “something more” necessary “to indicate that the defendant purposefully… directed his activity in a substantial way to the forum state.”

Consenting to Jurisdiction over Your Business

A court can obtain personal jurisdiction if both parties consent to such jurisdiction. The most common type of consent is where a company is required to consent, in advance, to personal jurisdiction in a state for incorporating or organizing a business under the laws of that state. State business organization statutes require that a business provide the secretary of state with an agent to accept service of process. An Internet business can also consent to the court’s jurisdiction by filing a response to a lawsuit filed with that court.

Similarly, you may grant consent by signing a contract that has a provision requiring you agree in advance to be subject to the personal jurisdiction of a state. For example, a California website developer may sign an agreement with an Illinois service provider containing a clause stating: “The parties consent to the exclusive jurisdiction of the federal and state courts located in Cook County, Illinois, in any action arising out of or relating to this agreement. The parties waive any other venue to which either party might be entitled by domicile or otherwise.” (However, the States of Montana and Idaho do refuse to recognize such clauses).

You have now been introduced to the catch 22 of e-commerce! The Internet provides a great way for small businesses to operate and achieve massive growth. Unfortunately, such growth will inevitably expose your business to foreign jurisdiction and the ability to be hauled into court in some distant State. If you want to guarantee that you will avoid this risk and you plan on operating a commercial website, you will surely sacrifice sales and growth.

SportGamble.us Picks this Year’s College Football Bowl Games

Here are the consensus bowl picks from the SportGamble.us staff.

Tue., Dec. 14

New Orleans Bowl

North Texas vs Southern Mississippi

SG’s Pick: North Texas

If the So. Miss defense can stop Jamario Thomas from adding to his gaudy stats they should be able to keep this one close.

7:30 pm

Tue., Dec. 21

Champs Sports Bowl

Georgia Tech vs Syracuse

SG’s Pick: Georgia Tech

7:45 pm

Wed., Dec. 22

GMAC Bowl

Memphis vs Bowling Green

SG’s Pick: Bowling Green

I want to pick Memphis to win this battle, but the Falcon’s scoring offense, 4th in the nation, will simply outscore Memphis regardless of how well they play.

8:00 pm

Thur., Dec. 23

PlainsCapital Fort Worth Bowl

Cincinnati vs Marshall

SG’s Pick: Marshall

Marshall has shown up to play in big games this year. I consider a bowl game a “big” game, wouldn’t you?

6:30 pm

Las Vegas Bowl

Wyoming vs UCLA

SG’s Pick: UCLA

UCLA should burn Wyoming with it’s passing and running game. Although, Wyoming is playing in it’s first bowl game in 11 years…that’s certainly motivating.

9:45 pm

Fri., Dec. 24

Hawaii Bowl

UAB vs Hawaii

SG’s Pick: Hawaii

NCAA’s all time passing leader should have a hay-day against this no show UAB defense

7:00 pm

Mon., Dec. 27

MPC Computers Bowl

Fresno State vs 18 Virginia

SG’s Pick: Virginia

Fresno State failed to play with the big dogs this season and Virginia is on the horizon to become one.

2:00 pm

Motor City Bowl

Toledo vs Connecticut

SG’s Pick: Toledo

Connecticut has a football team? Well, that’s what we would have said last season but they have a QB that can rip the secondary. You probably haven’t heard of him but the NFL scouts know him very well. Connecticut has a chance if they grasp the mindset they had when meeting Pittsburgh earlier in the year.

5:30 pm

Tue., Dec. 28

Independence Bowl

Iowa State vs Miami (Ohio)

SG’s Pick: Iowa State

Iowa State’s explosive offense will give Miami all they want…plus some.

6:30 pm

Insight Bowl

Oregon State vs Notre Dame

SG’s Pick: Notre Dame

Notre Dame is going to fight its heart out in defense of Tyrone Willingham. Oh, did we mention they’re a pretty good football team anyway?

9:45 pm

Wed., Dec. 29

Houston Bowl

Texas-El Paso vs Colorado

SG’s Pick: Texas-El Paso

Jordan Carson (name sound familiar?) will finally have his chance to showcase his talent on national television. Colorado is still wondering what happened in the Big 12 championship…

4:30 pm

Alamo Bowl

24 Ohio State vs Oklahoma State

SG’s Pick: Ohio State

Oklahoma State is no stranger to big games. Unfortunately, they haven’t learned how to win them.

8:00 pm

Thur., Dec. 30

Continental Tire Bowl

25 Boston College vs North Carolina

SG’s Pick: Boston College

North Carolina has a lack of “big game” experience while Boston College has the “secret to success” for winning bowl games, they’ve won 4 straight.

1:00 pm

Emerald Bowl

New Mexico vs Navy

SG’s Pick: Navy

Did we say Navy? That’s right! These guys finally learned how to play football.

4:30 pm

Holiday Bowl

4 California vs 23 Texas Tech

SG’s Pick: California

Cal will punish Texas Tech for being pushed out of the BCS picture.

8:00 pm

Silicon Valley Bowl

Troy vs Northern Illinois

SG’s Pick: Northern Illinois

Troy has never been to a bowl game and they’re not ready to win one either. N. Illinois has a ground attack that will out-muscle this Troy defense.

11:00 pm

Fri., Dec. 31

Music City Bowl

Alabama vs Minnesota

SG’s Pick: Alabama

This isn’t because we like the SEC. Minnesota isn’t playing at home…

12:00 pm

Sun Bowl

Purdue vs 21 Arizona State

SG’s Pick: Purdue

Arizona State is coming with their 2nd string QB that Purdue’s young, yet darn good, defense should contain. Expect Purdue to light up the score board in this one!

2:00 pm

Liberty Bowl

10 Boise State vs 7 Louisville

SG’s Pick: Louisville

This may be bowl game of the year. If you like fast attack offenses and aggressive scoring, this game is for you! Vegas will be exploding with “total points” bets on this one.

3:30 pm

14 Miami (FLA.) vs 20 Florida

Peach Bowl

SG’s Pick: Florida

If Chris Leak (Gators) isn’t the best QB in the land he will be. When the Gators are operating on all cylinders I would pick them to beat anyone in the country. Keep an eye on this one because it should be a money maker!

7:30 pm

Sat., Jan. 1

Cotton Bowl

15 Tennessee vs 22 Texas A&M

SG’s Pick: Tennessee

The Vols simply ran out of time in the SEC championship. I suspect they will pick up where they left off. Neither team “should” be here so it will definitely be one of the better games to watch.

11:00 am

Outback Bowl

16 Wisconsin va 8 Georgia

SG’s Pick: Georgia

Wisconsin can play offense buy GA’s fast defense will stop the run and force Wisconsin to throw resulting in too many mistakes to overcome. Georgia wins.

11:00 am

Gator Bowl

17 Florida State va West Virginia

SG’s Pick: Florida State

Florida State has put the lost to Florida behind them. Bowden’s ability to dominate bowl games has a “W” written all over it.

12:30 pm

Capital One Bowl

11 Iowa vs 12 LSU

SG’s Pick: LSU (restrictions apply…)

LSU is young but managed to fight their way to a good bowl game this year. If LSU’s defense can keep the score close they can pull this one off.

1:00 pm

Rose Bowl

13 Michigan vs 6 Texas

SG’s Pick: Texas

If Mack can persuade his players they’re as good as he did the nations coaches Texas will overcome a solid Michigan team.

4:30 pm

Fiesta Bowl

5 Utah vs 19 Pittsburgh

SG’s Pick: Utah

Pittsburgh slipped through the back door to win the Big East but I’m afraid Utah will show Pitt what it’s like to play with the Big Boys.

8:30 pm

Mon., Jan. 3

Sugar Bowl

3 Auburn vs 9 Virginia Tech

SG’s Pick: Auburn

Auburn should be playing for the national title. Look for Auburn to win big for the slight possibility of sharing the title.

8:00 pm

Tue., Jan. 4

Orange Bowl

1 Southern California vs 2 Oklahoma

SG’s Pick: Oklahoma

This one should come down to the last quarter. Oklahoma should prevail with stamina.

8:00 pm

World’s Top Golf Resorts: Train and Play for Your Vacation!

The finest golf resorts in the United States, Europe, Mexico and the Caribbean can be your choice for your next vacation. Make it a train-and-play golf vacation! So many package deals are available to make your trip much more than a break from your routine. A golf vacation will be a practical experience of improving your golf game, enjoying a phenomenally peaceful and luxurious setting, and visiting a different state or a different country! This planning guide will point you to some of the best-rated golf resorts in the world.

Whether you ultimately book for yourself or through an experienced golf travel specialist, begin your research online where you can find premium golf courses and travel bargains. Rates, resort amenities and golf course details are available. But look further for the packages that include airfare, hotel accommodations and green fees to get your best value. The typical packaged Golf Resort Vacation will include most of these features:

  • Airfare
  • Resort Accommodations
  • Confirmed Tee Times
  • Prepaid Green Fees
  • Shared Cart for 18 Holes
  • Equipment Rental
  • Golf Lessons
  • Meals at Exclusive Restaurants
  • Transfers to the Course
  • Transfers to the Airport
  • All Taxes and Service Charges

Golf courses are planned in lovely surroundings where you can take in sea breezes or views of lush vegetation, and you can combine golf with other resort amenities to provide a well-rounded vacation.

For instance, try one of the many glamorous Club Med Golf Resorts with beautiful fairways in the most unforgettable, inviting locations around the world. Club Med offers deals including the best equipment and golf lessons for all levels! Its locations include Cancun, Mexico, as well as Punta Cana in the Dominican Republic. Other locations span the world: Turks and Caicos, Mauritius, Portugal, France, Italy, Brazil, Thailand, Morocco, Egypt, Senegal, and in the United States–Sandpiper Bay, Florida.

Scotland has some of the most beautiful golf courses in the world and there are approximately 100 resorts, called “golf hotels,” among the 500-plus golf courses throughout the country. Best known are Turnberry, Gleneagles and The Old Course Hotel St. Andrews. Each of these has spa, leisure facilities, excellent restaurants and “golf tuition” packages for all levels.

Mexico has numerous golf resorts perched in luxurious coastal locations. There are golf resorts at Cancun, Acapulco, Puerto Vallarta and Los Cabos. Also, Mexico has its championship Baja version of California’s famous “Pebble Beach” golf resort, called Bajamar, only a few hours’ drive from San Diego in Ensenada.

For the United States, check online for some of the golf resorts suggested by key magazines such as Golflink‘s which publishes The Top 100 United States Golf Courses. This issue ranks the best out of more than 21,000 public and private golf courses across the country. However, within that one hundred courses, you want to search for the resorts with package programs and golf lessons. Among the top hundred, you will find that the main vacation-destination states with golf resorts are in Arizona, California, Florida, Nevada, South Carolina and Texas. Let’s review these states for their best locations:

  • In sunny, always temperate Florida, Club Med’s Sandpiper Bay Golf Academy offers 2-day and 3-day golf courses. The Academy includes all aspects of the game, such as Chipping, Putting, Bunker, Pitching and Lob Shot, Full Swing with Irons and Woods. A video analyzing your swing is provided, as well as an optional video comparing your swing to that of a pro player. Also, the area within and around Miami has regional golf resorts for year-round vacationing. Each resort offers on-site amenities and services, both on and off the course, and minutes away from major Miami attractions, like South Beach and Miami MetroZoo. You will have a multitude of options during a golf vacation here.
  • Arizona has a climate that is suitable for many months of the year and Scottsdale has nearly 200 golf courses, many with the picturesque backdrop of the Sonoran Desert. It is a golf destination with golf schools and pro shops. Here, many resorts offer high-quality accommodations and championship golf courses. Most golf resorts offer packages where hotel guests can have discounted green fees. Also, Sedona, Arizona, offers numerous golf resorts with a mild year-round climate and spectacular red-rock scenic views.
  • In California, Pebble Beach has been known for being a small coastal golf destination nestled in beautiful Monterey County. It is home of the prominent Pebble Beach Golf Links, the Pebble Beach Lodge and the prestigious Inn at Spanish Bay. Each year, golfers return to rub shoulders with golf professionals and experience nature at its finest on the magnificent golf course laid out by leading golf course designers. The harmony of golf layouts and the majestic coast are awe-inspiring!
  • Another golfer’s paradise is conveniently located along the south Atlantic coast at Hilton Head Island, South Carolina. It combines natural beauty and world-class golf on a barrier island 12 miles long and five miles wide. Nicklaus, Palmer and other golf legends have frequently played these championship courses. Since the first course opened at Sea Pines in 1961, there are now emerald links at Harbour Town and outstanding courses in Bluffton, as the Hilton Head area has become a major golf center. It is legendary for its spectacular views of the Atlantic Ocean, scenic marshes, and maritime forests with abundant wildlife. The temperate climate and year-round sunshine also makes Hilton Head Island the perfect place to tee off.
  • Las Vegas, Nevada, is quietly emerging as one of the United States’ fastest growing golf destinations amidst the glitz and glamour of its casinos. The city’s huge convention center and innumerable hotel rooms make it a natural haven for large-scale golf events. With the year-round sunshine and mild temperatures, and plenty to do after a full day of playing golf from gambling to seeing entertaining shows, this golf destination will continue to grow.
  • CNN ranked Austin, Texas the No. 1 city for golf in its Golf.com of 2010. Framed by the Texas Hill Country, Austin’s golf courses are among the best in the United States. The region is highlighted by the Wolfdancer Golf Club which was named No. 56 in Golfweek‘s top 100 resort golf courses in 2009. In addition to being a great contemporary music city, and home of numerous celebrities, Austin offers vacationing golfers great barbeque, an idyllic, year-round climate and luxury accommodations.

Your best package deal will be at all-inclusive resorts, where air flight, lodging, meals and golf activities are rolled into one price. On the other hand, consider traditional hotels and resorts in the locations suggested. With a little online planning, one of the finest golf resorts in the world can be your affordable choice. Enjoy the location, the exploration of the region while you improve your golf game and provide a joyful, well-rounded vacation for your family and loved ones!

(c) 2012 Elizabeth McMillian

Harbour Island Bahamas – Best Kept Secret

Promise not to tell? One of the best kept secrets of the Bahamas is Harbour Island. This romantic little island, known as “Briland” by its inhabitants, is a short hop from the States. A one hour flight from Florida to North Eleuthera followed by a brief cab and water taxi ride gets you to this Bahamas gem in a hurry.

Harbour Island is less than 4 miles long and a 1/2 mile wide. Its long wide beach is famous for its hard-packed pale pink sand. The likes of Fodors and Conde Nast rate it as one of the “best Bahamas beaches.” The beach, combined with some great restaurants, hotels and vacation home rentals, makes Harbour Island a destination of choice amongst Bahamas enthusiasts. It’s no surprise to find a few “rich and famous” there — they know they won’t be hounded.

Central to Harbour island is Dunmore Town. This quaint and friendly community features old Victorian structures adorned with Bahama’s colorful pastel paint schemes. No high rise hotels, fast food or traffic jams on this island!

Golf cart rentals are the transportation of choice. Swimming, snorkeling, scuba diving, fishing, and just plain walking the beach are some of the popular activities. To be sure, Harbour Island is not known for its shopping and night life nor is there any gambling. If you seek large crowds, wild parties or theme park rides, this is not your destination.

Harbour Island’s weather is delightful; especially during late Winter and Spring when there is little chance of rain. Ocean breezes take any edge off of moderately warm temperatures ranging from the 70s to 80s during the day and late 60s at night. Air conditioning during season is unnecessary — ceiling fans are adequate. Nothing beats falling asleep to the sounds of the ocean through an open window.

Dining out is casual. The better restaurants include Pink Sands Hotel, Coral Sands, The Landing, Rock House, Romora Bay Club and Harbour Lounge. For local fare, Ma Ruby’s should not be missed. And there are more… Part of the pleasure of exploring the island is checking out the restaurants. When compared to other Bahamian islands, Harbour Island has one of the best selections of restaurants — all within close proximity to any place you stay.

On the ocean side, hotels include Pink Sands Hotel, Coral Sands Hotel and Dunmore Beach Club. On the bay side, it’s The Landing Inn and the Rock House. On a budget? There are other hotels to choose from. Visiting Harbour Island is not cheap, but if it was, then everybody would be there, right?

Harbour Island’s vacation home rentals and villas are numerous. Location and size come at a price. If you desire “beachfront”, the better locations are usually on the north and south along the east coast. If you want to save a little, there are some nice rentals in Dunmore Town and others located in the interior of the island. The beach is always minutes away.

Look for home rentals on the internet offering more than a few photos so you know what to expect. A number of rentals are handled by rental or real estate agents who may not provide much in the way of details, descriptions, map locations or photos. Owners who care about promoting their home rental typically have independent web sites and accept e-mail inquiries directly.

The better house rentals on Harbour Island are booked nearly a year in advance of prime season. Those who want the best make early reservations — many are repeat customers. You can also take a “standby” position on a number of rentals in hopes someone cancels. Ask for referrals and double check policies for deposits and refunds.

If you seek a memorable and relaxed Bahamas vacation coupled with sun, sea, great food and a romantic beachfront that will knock your eyes out, consider Harbour Island. See you on the beach!

Copyright © 2004 Perry Joseph

Luxury Hotels in USA – They Mean It

United States of America comprises of states, cities and towns adorned with luxury in every element. The luxurious lifestyle, splendid attractions and natural distinction make USA a highly worth visiting place. A large number of fabulous destinations in the country encourage you to plan a long itinerary. And if you are used to luxurious lifestyle, Luxury hotels in USA have everything to offer you a luxurious environment and amenities. Climate in the country ranges from sub tropical to Arctic. However, most of the part is temperate with four distinct seasons. USA is the third largest country in the world. On the east coast, New York, Boston, and Philadelphia are some of the destinations where you become aware of the vivid characteristics of America. New York is famous for splendid skyline. It is also known as the Melting pot of culture.

Obviously, you cannot miss out on visiting the capital city Washington D.C which is the home of the President. White House is an attractive building. Atlanta is another famous destination which is always crowded throughout the year. Farmlands, forests, large cities, smaller towns, mountains and prairies, all are in abundance. Do pay a visit to Miami which hold a lot of promise to entertain you with its wonderful traits–it is quite well-known for its Latin culture, exciting nightlife and amazing beaches.

If you like to roll the dice, come to Las Vegas, a paradise for gambling freaks. You can discover many fabulous monuments and exemplary architectures right here in the desert. And Kentucky provides multitude of avenues to explore the natural artifacts, for instance, the mammoth cave which is the largest cave systems in the world. Numerous campgrounds, state parks, and recreational lakes create an inviting atmosphere to draw thousands of tourists from all across the globe. And Florida’s popularity graph is always high with its sunshine, beaches and hurricanes.

Origins of Baccarat

Baccarat is known as the card game of the rich and famous. Baccarat was so enigmatically linked with the wealthy upper classes and rich and famous and as a result many people shunned the game its triumphant emergence online.

Baccarat is one of the easiest of casino games to learn and play and can really generate some excitement when played at an online casino. There is no skill involved in the game as the rules determine each hands action. The only variable involved is the betting. In short, Baccarat is a game of chance.

Baccarat is thought to have originated in either France or Italy during the middle Ages. The word baccarat is a derivative of the Italian word for zero. In the middle ages the game was played using Tarot cards as opposed to the modern day card used today.

As Baccarat’s popularity increased across Europe, as with most of the other forms of gambling in those days there was some rigorous opposition from the Church. The Church viewed Baccarat as the game of the devil and those who played it were carrying out the devil’s work.

Tarot cards were first used in a game of Baccarat by Felix Galguiere. The Etruscan nine gods are said to be the basis for Galguiere’s version of the game. In this early edition of Baccarat, dice were rolled to determine the fate of a woman since the nine gods required the sacrifice of a blond virgin.

A roll of either an eight or nine made her a priestess; a six or seven and she was banned from religious activities; a number less than six and she walked into the sea and disappeared.

This early Baccarat variant became the game of choice for the upper classes and aristocracy and eventually evolved into ‘Chemin de Fer’ and European Baccarat it is thought that this took place at approximately 1500. The game, even though extremely popular, was illegal at first, as any form of gambling was. Eventually, the government made it legal and placed taxes on it. This made the game even more popular because people could rationalize that they were doing something for the good of the poor when they played baccarat thanks to the tax involved. The game began to lose its popularity during Napoleon’s reign when it was again outlawed. It remained illegal until the early 1900’s. At around this time many of the grand casinos were established along the French Riviera.

This version is the one that eventually made it way over to America but was a different version of the game that came from England. Baccarat was legal in England during the period that it was illegal across the rest of the Continent.

The English version of Baccarat reached the shores of Argentina in early 1950, where it was called ‘Punto y Banca’. When the game eventually reached Havana, the aim of the game had differed somewhat as now the player played against the house. It is this version, American Baccarat that was played in the casinos in Havana.

The Capri Casino version is the Baccarat variant that migrated to Las Vegas in the mid 1950s via Francis Renzoni, after a Las Vegas casino opened a baccarat pit. The game began it new life in America as an unpopular addition to the casino game selection. Las Vegas adapted the game and made the banker the UK casino or house position. This made it possible to bet for or against the house with the banker position. This is the Baccarat variant that is now so popular in the United States, England and Australia.

Before the game of baccarat had reached Las Vegas, it was already being played in New York and Florida. The game was played at the Saratoga race track and at the Palm Beach resort in 1910, forty years before it was played in Las Vegas.

Since its origins in the Europe during the Middle Ages, Baccarat has steadily made it’s way across each continent eventually becoming one of the most famous and respected casino games in the world.

There are variations in play depending on the location at which you are playing, so it is always best to check the house rules. And, as so may other forms of gambling, baccarat has made its way onto the internet. Most online casinos offer baccarat games with some variation in house rules; the biggest I have found is that there are only two hands: the banker and one player. Again, it’s advised to check the house rules before you play. Some online casinos also play the game with a single deck of cards, which is unusual in a land-based casino.

NCAA Basketball Betting: How to Make Money on the Mid Majors

The vast majority of people analyzing the college basketball betting board, or squares as we call them, will always gravitate towards the lines of the top 25 teams. The big names in college basketball such as Duke, UNC, Kentucky etc. Games between ranked teams and teams in the power conferences always attract the most action with bettors but experienced college basketball handicappers will often look for the soft lines involving mid major teams or teams that rarely play on national television. Listed below are the reasons why you too should start to bet less on the marquee matchup and more on the mid majors. Betting Action

As we eluded to above, the majority of the betting public doesn’t care about mid major teams until March Madness. This is a mistake. When you’re looking at the daily odds take notice of the amount of action that is bet on the two teams. Whenever the betting action is heavier on a college basketball game the more concerned you should be with wagering your money. You’ll often find that with a top 25 game between two top programs the line can move depending on the public loyalties and smart money. Often times the value will be bet out of a line due to the books adjusting to the betting action. When you bet mid major teams the lines move much slower due because sportsbooks aren’t as concerned with their exposure. This is your chance to find significant value and you can become far more profitable then betting to name brand teams. This is where real college basketball handicappers make their money.

Public Knowledge and Media Coverage

The average college basketball fan knows may know a lot about Kentucky, Duke or UNC or about a specific conference such as the ACC. This is no surprise considering that ESPN will air games featuring ACC or Big East teams on a weekly basis. It’s no shocker that Dick Vitale has a love affair with Duke and UNC and so does the majority of America. The public consumes vast amounts of information regarding the major conferences and very little amounts of information on the mid majors. But did you know that Rhode Island’s starting PG E.C. Matthews, who lead the team with 16.9 PPG in 2014-15 and was a key component to Rhode Island going 16-10 ATS last season, will miss 2015 due to a knee injury? Public knowledge is general knowledge so you’ll need to dig deep and have a depth of knowledge pertaining to all teams in college basketball. With over 300 teams it’s hard to know everything about every teams so pick out a mid major conference such as the WAC or the Colonial Athletic Conference and become familiar with the team and players. Follow them on social media and receive alerts and updates relating to these teams. Your goal is know more about the lesser known teams then the general public. This is where real college basketball handicappers make their money.

Talent and Experience

Every year there is a new team that emerges on the national spotlight during the NCAA Tournament. George Mason in 2006, VCU in 2011, North Florida in 2013 and the list is long and wide of teams that gain national attention by upsetting major conference teams during the tournament. Often times you’ll find that these teams have starters that are juniors and seniors and have played together for several years. While power conference teams with the top recruits are starting true freshmen and sophomores will very little experience playing when the game is tight, win or go home. A lot of the top programs have adopted a “one and done” recruiting mentality. When the NBA required players to attend 1 year of college before entering the draft, teams like Kentucky were recruiting magnets for the top talent. It took Coach K and Duke several years to adopt this mentality and it paid off last season when they won the National Championship. What happened when the season ended? Duke lost their 3 top recruited freshman who were drafted in the 1st round of the 2015 NBA Draft. This type of overhaul doesn’t happen to the mid major teams which is hugely beneficial when it comes time to play the big boys. There is more of a team cohesion and team first mentality which pays big dividends when wagering. A good tip to remember is to research the teams rosters and player history. Teams with starting point guards that have experience are great teams to back. Experienced players with game tested nerves are often times a smart wager.

The above represents just a fraction of what experienced college basketball handicappers and bettors will research before placing a wager. You have to remember that more times then not the value is with the mid major programs and not the media darlings. Sharp bettors focus on soft lines and they can be spotted with the lesser known teams. So the next time you’re researching college basketball don’t forget what we discussed and look for the value in the mid major basketball teams. I would love to have you join me and commit to winning some money this season. Luck!