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Who Are CC-1 and CC-2 in the Superseding Bitar Indictment?

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As most know by now, Full Tilt Poker head Ray Bitar reportedly turned himself in to US authorities earlier today despite apparently not having any sort of deal in place. Hope he’s saved his “one time.”

More or less simultaneously, a superseding indictment was filed against Bitar that dropped more than a few bombshells about FTP’s financial situation.

The full text of that indictment is here. Of particular interest to many readers may be the identities of CC-1 and CC-2, the unnamed co-conspirators mentioned frequently throughout the document.

To aid in the speculation, we’ve extracted all mentions of CC-1 and CC-2 from the indictment and summarized them below. While nothing points the finger indisputably at any one person, it’s safe to say that whoever the two are, they were about as high up at Full Tilt as you could be without being named Ray Bitar.

It’s also fairly reasonable (but still purely speculative) to conclude after reading the indictment that one – or both – of the unnamed parties may be cooperating with the US Government.

CC-1 is …

(Section 5) Someone who was a Tiltware LLC “owner, “co-manager” and “professional poker player.” (h/t to @AgentMarco).

(Section 13) Someone who would have been directly above the Customer Service Manager at Full Tilt. Section 13 details a customer support inquiry regarding whether player funds were “held in trust” that was escalated by the Customer Service Manager to Bitar and CC-1. The situation was dealt with directly by Bitar, with CC-1 copied on the entire conversation between Bitar and the Customer Service Manager. This section also suggests, but does not state, that CC-1 was the source of the email.

(Section 17) Someone who would have been privy to the highest level (and most sensitive) discussions at FTP. This section references an email sent in 2008 by Bitar to FTP’s general counsel and CC-1 concerning the assurances Full Tilt was providing players regarding security of funds. As no other parties are mentioned as receiving the email and Full Tilt’s lawyers would be highly unlikely to release any correspondence to the DOJ, that leaves Bitar and CC-1 as the likely sources of the email (assuming the DOJ didn’t just gain wholesale access to company email via an ISP or some similar channel). Again, pure speculation, but the emails referenced in the indictment would theoretically be known of by only a few individuals.

(Section 20) Someone who was well-known to the other Full Tilt owners. This section details a recorded conference call from 2008 apparently directed by Bitar and CC-1 (again, no word as to source of the recording) that was attended by “Full Tilt Poker owners.” This recording reportedly includes frank discussion of the legal liabilities the company could face at the hands of the DOJ. Interestingly, CC-2 is not mentioned in this section.

(Section 29) Someone who was a Full Tilt owner themselves. This section references an email Ray Bitar sent to “CC-1 and other Full Tilt Poker owners.”

(Section 32 a) Someone who would have needed to know in January of 2007 that payment processors were mis-coding credit card transactions for Full Tilt in an attempt to circumvent credit card industry policies designed to block online gambling transactions. This section describes an email sent from Bitar on the subject in Janurary of 2007 to CC-1 and CC-2.

CC-2 is…

(Section 18) The indictment describes CC-2 as “Full Tilt’s Director of Finance.”

(Section 19) Someone who dealt directly with the AGCC on Full Tilt’s behalf and was responsible for submitting at least one financial statement to the AGCC.

(Section 23) Someone who might not have had total control over the finances of the company. This section details a report prepared by Bitar’s “financial staff” in February of 2011 that predicted the company would be out of cash within three months; the section does not, however, make any mention of CC-2. To not have the director of finance involved in such a report seems odd indeed. The source of this report is also unclear.

(Section 28) Someone who communicated the financial difficulties facing Full Tilt post-Black Friday directly to Bitar via email in June of 2011. It’s unclear from the email excerpts provided in the indictment whether CC-2 was actively managing the financial situation of Full Tilt Poker at that point or simply passing information along to Bitar. No other parties are mentioned as receiving the email in question.

(Section 29) Someone who was still signing off on financial reports to the AGCC in June 2011 – reports that allegedly knowingly misrepresented Full Tilt Poker’s financial situation.

(Section 32 a) Someone who would have needed to know in January of 2007 that payment processors were mis-coding credit card transactions for Full Tilt in an attempt to circumvent credit card industry policies designed to block online gambling transactions. This section describes an email sent from Bitar on the subject in Janurary of 2007 to CC-1 and CC-2.

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Chris Grove
- Chris is the publisher of OnlinePokerReport.com. Grove also serves as a consultant to various stakeholders in the regulated market for online gambling in the United States.