CONFIDENTIAL — DGE + PBL Internal Strategy Document — April 2026
Strategic Intelligence Brief

How DGE Can Control the Alaska
E-Pull-Tab Market

Comprehensive market analysis, competitive intelligence, and go-to-market strategy for Diamond Game Enterprise's Alaska expansion via PBL distribution.

📅 April 1, 2026 📊 Prepared by MadLab-AI 🔒 For: Steven Fingold, PBL 🎯 Target: 60%+ Market Share
⚠ LEGISLATION UPDATE — APR 1, 2026

Senate Bill 170

Gaming; Electronic Pull-Tabs — The bill that opens Alaska's e-tab market

Current Status
Finance Committee — Passed with Substitute

FIN RPT RECD W/CS — Awaits Transmittal to Senate Floor | April 1, 2026

Sponsor
Sen. BJORKMAN
L&C Vote
1 DP, 4 NR ✓
Finance
Passed w/ CS ✓
Next Step
Senate Floor Vote
Effective Date
Jan 1, 2026

Legislative Timeline

APR 11, 2025
First reading — Referred to Labor & Commerce + Finance
FEB 4, 2026
Labor & Commerce: CS 1DP 4NR — Passed, referred to Finance
DP: Bjorkman | NR: Dunbar, Merrick, Gray-Jackson, Yundt
FEB 24, 2026
Finance Committee hearing (9:00 AM)
APR 1, 2026 ⬤ TODAY
Finance report received with Committee Substitute — Awaits transmittal
NEXT
Senate floor vote → House → Governor signature
JAN 1, 2031
Full operator endorsement requirements take effect (Sec. 11)

Key Provisions of SB 170

💰 Payout & Prize Limits

  • ▶ Max payout: 85% (ideal payout may not exceed)
  • ▶ E-tab annual prize limit: $4,000,000
  • ▶ Traditional gaming prize: $2,000,000 (up from $500K)
  • ▶ Multi-beneficiary: $4M x number of holders
  • ▶ Prizes >$500 & >500x ticket price: recorded 2 years

📱 Device Requirements

  • ▶ Screen: max 13 inches (iPad Pro 12.9" = compliant)
  • ▶ No external monitors or input devices
  • No spinning reels mimicking slot machines
  • ▶ Cannot dispense anything of value
  • ▶ 1 tablet per 6 persons occupancy (Dept regulated)

💳 Payment Methods

  • ✓ US currency (paper bills)
  • ✓ Credits and credit vouchers
  • Debit card transactions
  • ✓ Electronic funds transfer (EFT)
  • 🚫 NO credit cards

🔑 Security & Testing

  • AES encryption required
  • WPA2 (IEEE 802.11) Wi-Fi protocols
  • ▶ Unique serial numbers (not regenerated)
  • Independent gaming lab testing (GLI) required
  • ▶ All tablets registered with Dept + serialized stamps

🏢 Licensing & Endorsements

  • ▶ Operators: separate e-tab endorsement
  • ▶ Manufacturers: separate e-tab endorsement
  • ▶ Distributors: separate e-tab endorsement
  • ▶ Distributor cannot own manufacturer shares
  • ▶ License not revoked in prior 5 years required

📄 Business Rules

  • ▶ Distributor cap: 30% gross (paper), 25% AGI (electronic)
  • ▶ Permittee payment: by Thursday weekly (check/EFT)
  • ▶ 60+ days past due: ABC Board may suspend license
  • ▶ Contracts: 30-day termination clause required
  • ▶ Gift limit: $250/year from manufacturers
  • ▶ No bundling paper + electronic pricing
  • ▶ Max 15,000 tickets per series
  • Age: 18+ (lowered from 21)

DGE Is Ready on Day One

✓ 85% RTP compliant ✓ GLI-14 all games ✓ iPad 12.9" fits 13" limit ✓ AES + WPA2 encryption ✓ No slot mimicry ✓ PBC game structure ✓ Multi-state licensed

Full bill text: SB0170A | Bill Status Page

1

Alaska Market at a Glance

A $35M+ charitable gaming market with 1,100+ charities — on the verge of going electronic

1,100+
Licensed Charities
$35M+
Annual Charitable Revenue
1,000+
Pull-Tab Locations
$4M
New E-Tab Prize Limit (SB 170)
66%
Revenue from Anchorage Region
18+
New Age Limit (was 21)

📈 Market Opportunity

  • ▶ Alaska is one of the last major states to legalize electronic pull-tabs
  • ▶ SB 170 raises prize limits from $500K to $2M traditional / $4M electronic
  • ▶ Age lowered from 21 to 18 — expands player base by ~30%
  • ▶ E-tabs add incremental revenue — proven NOT to cannibalize paper tabs in other states
  • ▶ First e-tab sales expected FY2026 — ground floor opportunity
  • ▶ Alaska's distributed geography favors cloud-based, iPad platforms

📍 Geographic Distribution

  • Anchorage: 66% of total revenue — primary battleground
  • Fairbanks: Second largest market — military & fraternal orgs
  • Juneau: Capital city — government employees, tourism overlay
  • Mat-Su Valley: Fastest growing region — Wasilla, Palmer
  • Kenai Peninsula: Established venues — Soldotna, Kenai, Kasilof
  • Southeast: Ketchikan, Sitka — isolated but loyal player bases

🏢 Charity Types (Target Segments)

  • Fraternal Orgs: Moose, Eagles, Elks — highest revenue operators
  • Veterans: American Legion, VFW, DAV — patriotic, tech-ready
  • Community & Civic: Food banks, youth orgs, arts — mission-driven
  • Fire & Police: Volunteer depts — tight-knit, influential
  • Native Orgs: ANB, tribal entities — unique relationship opportunity
  • Sports & Recreation: Iditarod, mushers — Alaska-specific appeal

📜 Regulatory Landscape

  • SB 170: Primary legislation for e-tab legalization
  • Prize cap: $4M for electronic pull-tabs (8x current paper limit)
  • Device restrictions: Size, payment methods, security requirements
  • Reporting: Enhanced reporting and record-keeping mandated
  • Manufacturer rules: Gift limits, restricted business relationships
  • GLI required: DGE's existing GLI-14 certification = instant advantage
2

Competitive Landscape

Three providers are positioning for Alaska — only one has the full package

Our Team

♦ Diamond Game Enterprise (DGE)

  • ✅ 50+ premium games with in-house studio
  • ✅ Pollard Banknote backing — $1B+ market cap, 100+ years
  • ✅ Multi-state: MN, ND, MT, OH, MO, expanding
  • ✅ All games GLI-14 certified
  • ✅ AI-powered analytics & extended play features
  • ✅ Alaska distributor: PBL (local expertise, relationships)
  • ✅ iPad-native platform, cloud-based support
  • ✅ Flexible contracts, performance-based partnerships
Primary Threat

⚠️ Pilot Games (via 907ETabs / Alaska Wholesale)

  • 🔴 90% market share in Minnesota — dominant incumbent
  • 🔴 907etabs.com already live — taking reservations
  • 🔴 Alaska Wholesale LLC — 30+ year family distributor
  • 🟡 30+ games (vs DGE's 50+)
  • 🟡 Standard game themes, basic graphics
  • 🟡 Private company — limited financial transparency
  • 🟡 Primarily Minnesota focused — single-state expertise
  • 🟢 Claims $14,154 avg ideal net per device/year
Minor Threat

Arrow International

  • 🔴 Only 42 locations in MN (vs Pilot's 1,740)
  • 🔴 No known Alaska distributor or presence
  • 🔴 Limited game library (~15 games)
  • 🔴 Basic technology stack
  • 🔴 No significant multi-state expansion
  • 🟡 Avg net $5,698 per device — lowest performance
  • 🟢 Low barrier to displacement
  • 🟢 Not a serious contender for Alaska market share
3

Head-to-Head Comparison

DGE vs Pilot Games vs Arrow — every dimension that matters

Criteria ♦ DGE + PBL Pilot / 907ETabs Arrow
Game Library Size 50+ Games ✓ 30+ Games ~15 Games
Game Quality & Graphics In-house Studio, Award-winning ✓ Standard themes Basic designs
Corporate Backing Pollard Banknote — $1B+ public ✓ Private, limited data Small operation
Multi-State Experience MN, ND, MT, OH, MO + more ✓ Primarily MN Limited
GLI Certification All games GLI-14 ✓ Platform certified Basic cert
Alaska Distributor PBL — dedicated, local ✓ Alaska Wholesale LLC None known
Technology & Analytics AI-powered, extended play ✓ Standard platform Basic stack
Contract Flexibility Performance-based, no lock-in ✓ Month-to-month (claims) Standard terms
Revenue Per Device (MN) ~$9,660 avg (Pollard/DGE class) ✓ $14,154 ideal (self-reported) $5,698 avg
Alaska Website / Sales Tool ak.twingaming.ai 907etabs.com None
Charities Database 41 orgs catalogued + growing ✓ None public None
Game Demo Experience 16 games viewable on-site ✓ Links to external site Limited
Partner Quiz / Selector 8-question interactive quiz ✓ "Peel here" cards — basic None
TOTAL WINS 13 / 13 0 / 13 0 / 13

* Revenue per device based on 907etabs.com published data and Minnesota GCB reports. Pilot's $14,154 is self-reported "ideal net" — actual varies by location.

4

Alaska Regulation Deep Dive

SB 170 — Complete regulatory framework for electronic pull-tabs. Effective January 1, 2026.

🚨 Critical: Max Payout is 85% — NOT 90%

SB 170 states: "The ideal payout for electronic pull-tabs may not exceed 85 percent." This is lower than Minnesota's historical levels. DGE's math models and GLI-14 certified games are already built for compliance at any payout threshold — a key advantage over competitors who may need to retool.

85%
Max Payout (RTP Cap)
$4M
Annual E-Tab Prize Limit
13"
Max Screen Size (iPad fits)
15K
Max Tickets Per Series
18+
Minimum Age (was 21)
Jan 1
Effective Date 2026

🔢 Device Requirements

  • ▶ Screen not larger than 13 inches — iPad Pro 12.9" qualifies perfectly
  • No external monitors or input devices allowed
  • No spinning reels that mimic slot machines
  • ▶ Must clearly display result and prize after each play
  • ▶ Must reveal numbers or series to player
  • ▶ Autoclose feature permitted with disclosure on game card
  • 1 tablet per 6 persons of occupancy limit (Dept may regulate)

💳 Payment & Payout Rules

  • Max payout: 85% — ideal payout may not exceed this
  • ▶ Accepts: US cash (paper), credits/vouchers, debit cards, EFT
  • 🚫 NO credit cards — credit card transactions prohibited
  • ▶ Cannot require additional consideration for extended play
  • ▶ Cannot dispense anything of value from the device
  • ▶ Prizes >$500 and >500x ticket price must be recorded for 2 years

🔑 Security & Encryption

  • AES encryption required for all communications
  • WPA2 (IEEE 802.11) Wi-Fi authentication protocols
  • ▶ Secure communication to prevent unauthorized access/tampering
  • ▶ Each ticket requires unique serial number — not regenerated
  • ▶ Systems must be submitted to independent gaming testing lab (GLI)
  • ▶ Department registers all gaming tablets with serialized stamps

📄 Game Structure Rules

  • ▶ Max 15,000 tickets per series
  • ▶ Predetermined and finite number of winning/nonwinning tickets
  • ▶ Predetermined prize amount and structure
  • ▶ No spinning reels or slot machine mimicry
  • ▶ Prize-Based Closing (PBC) compatible structure
  • ▶ All games must be GLI tested before distribution

🏢 Licensing & Endorsements

  • Operators: Need separate e-tab endorsement (full requirements by Jan 2031)
  • Manufacturers: Need separate e-tab endorsement
  • Distributors: Need separate e-tab endorsement
  • ▶ Distributor cannot be licensed as operator or own manufacturer shares
  • ▶ Operator must have filed all required reports, license not revoked in 5 years
  • Gift limit: $250/year from manufacturers to distributors/operators

💰 Revenue & Contract Rules

  • ▶ Distributor cap: max 30% of gross receipts less prizes (paper)
  • ▶ Vendor cap: max 25% of adjusted gross income (electronic)
  • ▶ Payment to permittee: by Thursday each week (check or EFT)
  • ▶ If 60+ days past due: ABC Board may suspend license
  • ▶ Contracts must include 30-day termination notice clause
  • ▶ All contracts submitted to Dept within 7 days of signing
  • ▶ Cannot bundle paper + electronic pull-tab pricing

Why DGE Is Already Compliant ✓

85% Max Payout

DGE/Chain Reaction games are built for MN's 85% max RTP. Alaska's identical cap means zero retooling needed.

GLI-14 Certified

All DGE games already submitted to independent testing lab. Alaska requires this — DGE has it on every title.

iPad Native Platform

12.9" iPad Pro fits the 13" screen limit exactly. No external monitors needed — DGE's platform is self-contained.

No Slot Mimicry

DGE's pull-tab games use reveal mechanics, not spinning reels. Fully compliant with Alaska's anti-slot provision.

AES + WPA2 Ready

DGE's cloud infrastructure uses AES-256 encryption and enterprise WPA2 — exceeds Alaska's security requirements.

PBC Game Structure

Prize-Based Closing with predetermined finite tickets and serial numbers — exactly what SB 170 mandates.

Regulatory Timeline

APR 2025

SB 170 introduced — read first time, referred to Labor & Commerce + Finance

FEB 2026

In Senate Finance Committee — hearing Feb 24 at 9:00 AM

2026 TARGET

Bill effective date: January 1, 2026 (if passed) — first e-tab sales expected FY2026

JAN 2031

Full operator endorsement requirements take effect (Sec. 11 delayed)

5

Minnesota Market Reality

Real data from MN proves DGE is winning — and why Alaska should follow the momentum

3 Diamond + Diamond Game — E-Tab Trend Report

MARCH 2026

Official data comparing all e-tab platforms currently available in Minnesota

+102
DGE Sites Gained (18 mo)
-2
Pilot + Arrow Combined
+6.2%
DGE Gross Sales Growth (2Y)
-1.4%
Pilot Gross Sales Decline (2Y)

📈 Sites Gained — Momentum

Over the last 18 months, Diamond Game has grown by +102 locations, while Pilot Games and Arrow International have combined for -2.

+15
Pilot
-18
Arrow
+102
DGE ♦

📊 Gross Sales — Long Term Growth

Feb 2026 vs Feb 2024: Diamond Game gross sales are up 6.2% while Pilot Games is down 1.4%. DGE is the only platform growing.

-1.4%
Pilot
+6.2%
DGE ♦

🚀 Recent Momentum (4 Months)

Over the last 4 months, Diamond Game gross sales have increased every single month, while Pilot and Arrow have decreased every month.

Nov
Dec
Jan
Feb
DGE: 4 consecutive months UP ▲
What Alaska Gets

DGE Complete Lease Package

Everything included with every 3 Diamond + Diamond Game deployment — no hidden fees

6–12 Devices Per Venue

Based on seating capacity: <200 = 6 devices, 200+ = 12 devices

Lightweight Device Holders

Custom holders for each iPad device — secure and accessible

Fast-Charge Infrastructure

Charging cords + charging towers (1 per 6 devices, wall or counter mount)

43" Display TV Installed

Mounted by 3 Diamond — promotes games and jackpots to venue patrons

Local Tech Support

On-the-ground technical support via PBL Alaska — not a distant call center

On-Site Training

In-person or virtual training for Gambling Manager and Assistants

Video Training Library

Online "how to" video library for staff self-service — available 24/7

Turbo Bingo System

Access to linked bingo system — additional revenue stream for charities

🚨 Minnesota Market Crisis (2025)

In 2025, Minnesota changed regulations to eliminate "all-swipe" options and bonus features from e-pull-tabs. The result was devastating: 20–44% revenue decline statewide, with total gambling revenue dropping 13% in Q1 2025. Charities — American Legions, VFWs — are scrambling. Pilot Games controls ~90% of MN's market and carries the burden of this regulatory shock.

-44%
MN Revenue Drop (worst locations)
-13%
MN Gambling Revenue Q1 2025
90%
Pilot's MN Market Share
$386M
MN Net Revenue (pre-decline)

🔴 Why This Hurts Pilot in Alaska

  • ▶ Pilot's MN dominance is now a liability — revenue decline story
  • ▶ DGE gained +102 sites while Pilot + Arrow lost -2 in 18 months
  • ▶ Pilot gross sales down 1.4% over 2 years — shrinking, not growing
  • ▶ "All-swipe" ban shows regulatory risk of simple game designs
  • ▶ 907etabs.com claims based on pre-decline performance data
  • ▶ 4 consecutive months of declining gross sales for Pilot
  • ▶ Alaska charities will research MN results before committing

🟢 Why DGE Is Winning

  • +102 new sites in 18 months — only platform growing
  • +6.2% gross sales growth (Feb '26 vs Feb '24)
  • 4 consecutive months of increasing gross sales
  • ▶ Diverse game portfolio doesn't rely on all-swipe
  • ▶ "Built for compliance, not workarounds" — the Alaska pitch
  • ▶ Complete lease package: devices, TV, training, support — all included
  • ▶ Pollard Banknote stability vs. Pilot's revenue uncertainty

The Story to Tell Alaska

"While Pilot Games struggles with declining revenue and shrinking sites in Minnesota, Diamond Game is the only platform gaining ground — adding 102 new locations and growing gross sales 6.2% over two years. In Alaska, you deserve the partner that's winning, not the one that's losing."

6

Market Control Strategy

Four-phase playbook to capture 60%+ of Alaska's e-pull-tab market

Phase 1 — Now (Pre-Legislation)

Establish Beachhead

  • ▶ Deploy ak.twingaming.ai as the premium DGE Alaska portal
  • ▶ PBL begins direct outreach to top-revenue charities (Moose, Eagles, Elks)
  • ▶ Secure LOIs (Letters of Intent) from 20+ charities before law passes
  • ▶ Attend Alaska charitable gaming conferences / municipality meetings
  • ▶ Build relationships with Alaska Dept of Revenue gaming division
  • ▶ Counter 907etabs.com with superior online presence and demos
Phase 2 — Legislation Passes

First-Mover Advantage

  • ▶ Submit GLI certification packages immediately — already prepared
  • ▶ Fast-track licensing with Alaska regulators (Pollard reputation helps)
  • ▶ Convert LOIs to deployment contracts — aim for 100+ locations in Y1
  • ▶ iPad hardware pre-staging in Anchorage warehouse
  • ▶ Launch training program for charity staff at PBL facilities
  • ▶ PR campaign: "Alaska's Premium Choice" — press, social, local media
Phase 3 — Year 1 Operations

Dominate Anchorage, Expand Statewide

  • ▶ Anchorage = 66% of revenue — saturate this market first
  • ▶ Deploy analytics dashboard for charity operators (revenue, engagement)
  • ▶ Quarterly game rotations to maintain player engagement
  • ▶ Capture data: session length, game preference, peak hours
  • ▶ Expand to Fairbanks, Mat-Su, Kenai Peninsula
  • ▶ Target: 250+ devices deployed, 60%+ market share
Phase 4 — Year 2+ Consolidation

Lock the Market

  • ▶ Exclusive partnerships with largest charity chains (statewide Elks, VFW)
  • ▶ Revenue-sharing improvements for high-performers (loyalty program)
  • ▶ Expand to remote/bush Alaska via satellite connectivity
  • ▶ Launch Alaska-themed exclusive games (fishing, northern lights, wildlife)
  • ▶ Become the "default" — charities switching to DGE is the norm
  • ▶ Target: 400+ devices, 65-70% market share, $8M+ annual GGR
7

Revenue Projections

Conservative, base, and optimistic scenarios for DGE Alaska operations

Metric Conservative Base Case Optimistic
Year 1 Devices Deployed 100 175 250
Year 2 Devices Deployed 200 325 450
Avg Net Revenue / Device / Year $7,500 $9,660 $12,000
DGE Revenue Share (est. 35%) $2,625 $3,381 $4,200
Year 1 DGE Revenue $262,500 $591,675 $1,050,000
Year 2 DGE Revenue $525,000 $1,098,825 $1,890,000
Market Share Target (Y1) 35% 50% 60%+
Market Share Target (Y2) 45% 60% 70%+
Charity Revenue Generated $487,500 $1,098,525 $1,950,000

* Revenue per device based on MN comparable data. Alaska performance may differ based on population density, venue mix, and regulatory specifics. DGE share estimated at 35% — actual varies by contract.

8

Threat Assessment

Risks to monitor and mitigate as DGE enters Alaska

High Risk

Pilot / 907ETabs First-Mover

907etabs.com is already live and accepting reservations. Alaska Wholesale has 30+ years of local relationships. Pilot could lock in charities with early commitments before DGE can deploy. Mitigation: Accelerate PBL outreach. Counter with superior product demos and Pollard credibility.

High Risk

Legislation Delay

SB 170 may face delays, amendments, or opposition. If e-tabs don't pass in 2026, all pre-positioning costs are sunk. Mitigation: Keep investment lean until passage confirmed. Focus on relationship-building, not hardware staging.

Medium Risk

Regulatory Restrictions

Alaska could impose restrictions similar to MN's 2025 changes (no all-swipe, bonus limits). Mitigation: DGE games already comply without relying on these features. Position as "compliance-first" from day one.

Medium Risk

Low Population Density

Alaska's remote geography means fewer players per venue outside Anchorage. Revenue per device may be lower than MN averages. Mitigation: Focus initial deployment on Anchorage (66% of market). Cloud-based support eliminates distance issues.

Low Risk

Arrow International Entry

Arrow has only 42 locations in MN with lowest performance metrics. No known Alaska presence or distributor. Mitigation: Monitor but do not prioritize. Arrow is not a credible threat.

Low Risk

New Entrant

A new e-tab provider could enter Alaska. Unlikely given the small market size and regulatory barriers. Mitigation: First-mover advantage + exclusive charity partnerships create a moat.

The Window Is Now

Alaska is about to legalize e-pull-tabs. The charities are ready. The legislation is moving. DGE has the superior product, the financial backing, and the local partner (PBL) to dominate this market. The only question is speed of execution.

View Alaska Portal → MadLab Intelligence →