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Statutory language: Section 1081 defines a "gambling establishment" as "any common gaming or gambling establishment operated for the purpose of gaming or gambling, including accepting, recording, or registering bets, or carrying on a policy game or any other lottery, or playing a game of chance, for money or other thing of value." [75] However, the term "gambling establishment" does not appear in section 1084. Kennedy to Speaker of the House of Representatives, dated April 6, 1961)).

A narrow construction approach is further bolstered by looking at the Interstate Transportation of Wagering Paraphernalia Act, [76] which was enacted as part of the same anti-organized crime legislation as the Wire Act.

[86] Specifically, Senator Kyl stated that the bill was necessary, because "[i]t dispels any ambiguity by making it clear that all betting, including sports betting, is illegal.

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[88] Case law: most notably the recent decision by the United States District Court for the Eastern District of Louisiana, clearly supports this conclusion. ."[92] The case is currently on appeal to the Fifth Circuit.

In In re Master Card Int'l, et al., a class action against several banks and credit card companies alleged unlawful interaction with Internet casinos in violation of RICO. sought to amend Title 18 to prohibit the use of the internet to place a bet or wager upon a "contest of others, a sporting event, or a game of chance. If on the other hand the term "contest" is to be viewed more broadly to encompass traditional casino games or games of chance, then on-line gaming, as some have argued, [93] will be prohibited by the Wire Act.

[85] "[U]ntil the legislature manifests its intent to include on-line gambling within the purview of present gambling laws, courts should not apply Section 1084 to Internet gambling activities." Harley J.

1, at 8; see also Scott Olson, Betting No End to Internet Gambling, supra, n.

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The title of the legislation is "Sporting Events- Transmission of Bets, Wagers, and Related Information." [80] The House of Representatives Report on Senate Bill 1656, dated August 17, 1961, states that the bill is in response "modern bookmaking." [81] In the "Sectional Analysis" of the report, the terms "sporting event or contest" and "sporting event" seemed to be interchangeable.

[82] Included in the report is a letter from Attorney General Robert F.

The statute, however, does not expressly discuss its possible application to other forms of gambling.

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