Dear Hon. David Harris,

I am writing to bring to your attention a matter of utmost importance regarding the operations of promotional lotteries within the state of Victoria. Specifically, there are certain entities that are exploiting a legal loophole by offering subscriptions or backends to their promotional lottery business, effectively running commercial lotteries under the guise of promotions.

One prominent example of such exploitation is the case of LMCT+ Group, a promotions and giveaway business operated by Adrian Portelli, a well-known Melbourne social media identity. This business, which generates substantial revenue through its promotional lottery activities, offers memberships and subscription packages as part of its operations. This approach allows them to profit from the element of chance involved in their promotions, effectively transforming their activities into commercial lotteries.

The practices employed by LMCT+ Group and similar entities raise serious concerns about the fairness, transparency, and legality of such operations. By offering subscriptions and backends, they not only bypass the regulations set forth by the Gambling Regulation Act 2003 and Gambling Regulations 2015 in Victoria but also create a significant loophole that allows them to exploit the system in other states and territories.

As the Minister of Gaming and Racing, I kindly request your attention and action in addressing this issue promptly. It is crucial to safeguard the integrity of the gambling and promotional industry, ensuring that all businesses operate within the boundaries of the law and adhere to the principles of fair competition.

I humbly urge you to consider the following actions to crack down on the exploitation of this promotional lottery loophole:

  1. Conduct a thorough investigation into the operations of entities, such as LMCT+ Group, that are offering subscriptions or backends in conjunction with their promotional lottery activities.
  2. Review and potentially revise the existing regulations to close any loopholes that allow for the transformation of promotions into commercial lotteries.
  3. Increase enforcement efforts to ensure compliance with the Gambling Regulation Act and related regulations, particularly in the realm of promotional lotteries.
  4. Enhance public awareness and education campaigns to inform individuals about the risks and potential pitfalls associated with engaging in these types of activities.

By taking decisive action against the exploitation of this loophole, you will not only protect the interests of consumers but also maintain the integrity of the gambling and promotional industries. 
Your leadership in this matter will send a clear message that Victoria is committed to upholding the highest standards of fairness and transparency in commercial and promotional activities.

I greatly appreciate your attention to this urgent matter and your dedication to ensuring the proper regulation and oversight of the gambling and promotional sectors. I am confident that your decisive actions will help safeguard the interests of all Victorians.

Thank you for your time and consideration. I remain at your disposal should you require any further information or assistance.

Yours sincerely,

Dean Foley
Founder at Barayamal

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