As soon as the Kahnawake Gaming Commission released its final decision in the UltimateBet cheating scandal, the questions started hitting. Most of them concerned the secrecy around the list of 31 names said to be associated with Russ Hamilton. A discussion with Chuck Barnett, member of the Board of Supervisors of Mohawk Internet Technologies, provided his reasons for not releasing that list of names.

Mr. Barnett first told me that implicating Hamilton in the scandal was not a problem, as it was “very clear” that he was directly connected and responsible for the crimes being alleged. The names of the 31 individuals associated were another story, he says. The Commission had lengthy discussions regarding the release of those names and ultimately consulted their legal team and law enforcement officials.

On the legal front, they deemed it a civil liability issue, as the suspects are directly linked to Hamilton or the 117 accounts listed BUT there is the possibility that they had no knowledge of the scheme. If they were accused and found to be completely oblivious to or innocent of the crimes, there would be liability in falsely accusing them. There is also some question as to each person’s level of culpability, which can’t be known until they are questioned by the proper authorities. And per law enforcement, naming the individuals would impede a criminal investigation, as anyone named may be able to flee the country, hide, etc. With all things considered, the KGC made the decision to withhold the names.

When asked about the law enforcement agencies involved, Mr. Barnett wouldn’t say much. Legally, all he said he could say was all information from the KGC investigation was turned over to “law enforcement,” which had expressed a distinct interest in pursuing the case. He could not say, however, whether those were Canadian or U.S. authorities, only that there were discussions with “regional and national” agencies.

If/when indictments are handed down or prosecutions are made, or if some other permission is given by law enforcement, the KGC will make public the names – and be happy to do it. Until then, based on overwhelming advice, the list will remain a mystery.

The Kahnawake Gaming Commission’s investigation into the UltimateBet cheating scandal has been concluded with the release of its final decision. The 11-page document does provide some new information.

• In total, Tokwiro, owner of UltimateBet, refunded $22,054,351.91 to players affected by the cheating incidences.
• Tokwiro paid $1.5 million in fines, plus the costs of the investigation, to the KGC.
• Tokwiro is on a one-year “probation” period, during which time it must provide all details of daily operations, including financial and gaming records.
• Going forward, Tokwiro must maintain three sets of web/game logs, one of which will be housed at the offices of the KGC.
• All officers, directors, shareholders, and key people associated with Tokwiro must be known to the KGC.
• There were 23 accounts and 117 usernames used in the cheating.
• Much of the stolen money was disbursed through player-to-player transfers on UB.
• Russell Hamilton, associated at the time with eWorld Holdings Group, was primarily responsible for the scandal. The “vast majority” of the IP addresses used were directly connected to Hamilton.
• Hamilton’s actions that constituted “criminal behaviour” were associated with 31 other individuals, whose names were not released in the document.
• All information has been provided to law enforcement authorities to determine if criminal charges can be filed.

The entire decision can be accessed here by clicking on the “News” link.

The accompanying press release stated:

The decision released today reviews the corrective actions that have been taken by Tokwiro over the past 12 months, and concludes that Tokwiro has provided sufficient evidence to justify the continuation of its license to operate, subject to a number of additional conditions of licensure.

“Despite the unfortunate circumstances that resulted in this cheating, we are satisfied that the actions taken by the Commission provided an equitable result for affected players – our first priority. We remain optimistic that this experience and the lessons learned from it will result in a higher standard of gaming regulation for companies licensed and regulated within the Mohawk Territory of Kahnawake and elsewhere,” said Chairman Montour.

Many in the poker industry consider the UltimateBet and Absolute Poker scandals resolved, at least as much as we can expect them to be considering the sources of any information and the lack of the ability to involve U.S. law enforcement due to jurisdictional issues. And while some of us still have eyes and ears open for further developments, such as those that may appear on a Russ Hamilton twitter feed, Haley Hintze, former Editor-in-Chief of PokerNews, has decided to put out all of her well-informed conjecture on her own blog and gives one of the more detailed explanations of how, when, and why the UB/AP scandals were perpetrated. Though she has only posted Part 1, the rest of the story, we presume, is forthcoming.

Part 1 dives into the beginnings and how Hamilton got involved and possibly recruited help. Here is a portion of the post:

There are three reasonable scenarios for how the cheating spread, as spread it surely did:

1) One or more software engineers working on the UB code recognized the illicit profit potential for themselves, and also began to slice money from the games;

2) Hamilton himself recruited one or more Costa Rican workers to assist him in the cheating, as a way of expanding the total money being stolen;

3) Someone at UB caught Hamilton — probably noticing unusual withdrawal amounts relative to the amount of play Hamilton was logging — and decided to cut himself in for a slice of the action.

From some time in 2006, I believe, it was game on in a big way for the cheats. I’d heard whispers as far back as 2005 that something was wrong with the cash games at UB, but I played there very little, only at small stakes, and couldn’t really speak to it.

The post in its entirety can be found here.

Ultimate COO Paul Leggett has given an update to the blog at Ultimate Bet about the Phil Hellmuth v DOUBLEBALLER hand that caused all sorts of controversy in the online community since Saturday morning, a portion of that comment is excerpted below:

As we explained in our press release, the incorrect payout was caused by a software malfunction. The software malfunction occurred when the winning player was disconnected from the hand at the precise millisecond the software was determining whom to award the prize. This in conjunction with the “player’s state” data being cleared from memory caused this extremely improbable incident to occur.

Originally we were unable to reproduce the error in our test environment, until we programatically forced a disconnect to happen at the precise millisecond the hand was being awarded.

We have never had an issue like this reported previously and we have reviewed all of our database and application logs for December and November and have been unable to find any historical occurrences. We are continuing to go back further into the historical data to ensure no hands from the past need to be corrected. Analyzing this data takes time but we will continue to go back further and further into our history to ensure no one else was affected.

Leggett’s entire statement can be found at the Ultimate Bet blog.

Tokwiro Enterprises, who own Ultimate Bet and Absolute Poker, issued their own statement on the matter, after the jump:

More…

Tokwiro Enterprises announced that it has chosen to follow the Kentucky court order and block Kentucky residents from accessing Absolute Poker and UltimateBet. In an explanation, COO Paul Leggett said, in so many words, that the purpose it to protect the domain names for the entirety of its customer base.

Being anxious about following the letter of the law when trying to rebuild a reputation is one thing, but could this be jumping the gun a little? The case is currently on hold due to the appeal process, and the deadline for blocking Kentucky residents has been postponed until the appeals court hears the petition, which is scheduled for December 12th. Today is December 2nd. Just sayin’.

The entire press release from Tokwiro is as follows:

TOKWIRO BLOCKS ACCESS BY KENTUCKY RESIDENTS
TO ITS ONLINE POKER SITES

Customers Connecting from IP Addresses in Kentucky Will Be Unable to Play on Absolute Poker and UltimateBet Sites

MONTREAL, CANADA (DECEMBER 2, 2008) — Tokwiro Enterprises ENRG (Tokwiro), the owner of the Absolute Poker (AP) and UltimateBet (UB) poker sites, announced today that, in order to fully comply with the Franklin County (Kentucky) Circuit Court’s recent orders, it is restricting access to Tokwiro’s sites by Kentucky residents.

More…

OK, I just read Part 1 of the Washington Post story by Gilbert Gaul on cheating at Absolute Poker and Ultimate Bet. I thought it was great and on target and technically correct to the letter when discussing legal matters. I learned a bunch of stuff I didn’t know, too.

Two-and-a-half specific things caught my eye:

(The name of the alleged cheater has circulated widely among poker players on the Internet. The Post is not publishing his name because, even though he purportedly confessed to AbsolutePoker, the company did not release its records and would not discuss the matter. The alleged cheater declined requests to be interviewed.)

Maybe I just haven’t been following it close enough on the forums, but I’m wondering whom they’re referring to here.

The story also doesn’t reference the new formation of Cereus, after acknowledging that UB would likely lose its license and be out of business soon. Hmmm. But that’s really new, and this story was possibly put to bed a few weeks ago?

The other thing is the last graf:

The Kahnawake now say they operate one of the most secure Internet gambling operations in the world. Tokwiro says it has “established cutting-edge security systems that make us the safest site in the industry.” But Catania said he does not expect cheating to stop: “I’m sure there are people out there right now figuring out, let’s say, ‘Here’s a way we can do it again.’

Yikes, that last sentence leaves it open-ended as to how part two of the story will fall when it comes to legalization efforts.

I really like poker’s chances (because I sincerely believe despite our internal battles with shadiness, our industry is on the right side of legal issues here) … and from what I’ve learned in my rookie dabblings in poker (and strip-club) politics, the treatment this story is getting in Washington DC — a big investigative feature spread out over two days with lots of informative sidebars — now guarantees (I’m like 86 percent sure) that our issue is on the 2009 political agenda. I’m not totally comfortable yet, of course. Current feeling in my gut is comparable to waiting for the river when all-in against an 8- or 9-outer. A little unsettling. But hey, that’s what we came here for, right?

In addition to the story itself, the WP’s got a bunch of goodies for those who want to dig deeper, or just check their work:

• Here’s a timeline titled “Internet Poker and the Law” — they get the UIGEA, imo.
• Paul Leggett’s defense (pdf)
• Video explaining Texas Hold’em — as in how to play … they clearly see poker as a fun skill game, not a dangerously addictive vice; if the investigation were about shady drug runners, after all, you wouldn’t see a similar vid on how to make good meth.

• Also: a video about David Paredes going from intelligent amateur to uber-skilled pro.
• A timeline about how the AP/UB/Cereus cheats got caught.
• And another timeline of the scandal, complete with cool Web 2.5-ish document pop-ups.
• “Reporter’s notebook” about The Mohawk Connection.
• And shoot, wish I had seen this one before linking to the above — an everything page chronicling the entire investigation, complete with fun little numbers about (taxable) online poker revenues.

So there you have it. It would hard to expect anything more thorough. Kudos to “special correspondent Gary Wise“, too, for playing poker-biz fixer for the WP investigative team turning over rocks.

Dan Druff over at Neverwin breaks down the Paul Leggett memo in a way that might make some think the AP/UB scandal is still going on, or at least a cover-up is:

* Tokwiro agreed not to prosecute the perpetrator in the Absolute Poker cheating, and to protect that individual’s identity, because this was the only way to ensure that the ability to cheat was fully discovered and disabled. Because of this decision, AP could continue operating and begin to reimburse affected players as quickly as possible.

Pretty sweet deal for the guy, huh? Wouldn’t you like to work for a company that will agree not to prosecute you for stealing millions from them, provided that you just show them how you did it, if caught? There is zero chance that this is true. It would have been easy for them to deconstruct this after-the-fact without this asshole’s help. Obviously they are protecting him either due to continued association/affiliation (likely), fear that he will spill the beans on everyone and everything else there (also likely), or both (most likely).

Must-read for anyone who wants to understand what all the hubbub is about.

While most of the poker community will anxiously be awaiting the 60 Minutes piece on the Absolute Poker/Ultimate Bet incidents at around 7pm ET Sunday; the Washington Post, who were investigating the story along with CBS News, will have their own story available in their Sunday edition. Their piece, which will also be found on their website, may be a better indicator as to how the 60 Minutes story will be covered later that night. Also, it’s figured that the Washington Post won’t be as limited in trying to tell the complete story, since 60 Minutes has to try and explain the situation along with discussing the legality of online gambling in a 12-15 minute piece. . There will also be an online chat on Monday with WaPo investigative reporter Gilbert M. Gaul and Serge Ravitch, an online player who was also involved in the investigation.

Nat Arem sure has sources. He recently received a forward of an inter-company memo from Tokwiro Enterprises COO Paul Leggett regarding the upcoming 60 Minutes story. Leggett has reason to believe that there will be a bias against Tokwiro and its companies, going further to say that online poker will emerge with a bad reputation. Thus, they did not appear on camera for interviews. (A little like saying that the jury has a bias, the judge is going to declare me guilty, so why defend myself?)

Leggett wrote:

“We have every reason to believe that the 60 Minutes producers are intent on portraying the online poker industry and our companies in a negative light, and we do not expect that the program will be either fair or balanced.

Because of 60 Minutes’ apparent bias against Tokwiro and online poker, we have decided not to appear on camera. We have, however, had many conversations with the program’s producers. We provided them with extensive background materials and documents, and we answered questions on-the-record, but off-camera. Despite all this, it is not likely that our views will be properly represented. Therefore, it is important that all of our staff know the following facts about our company:”

The remainder of the memo states some facts about Tokwiro Enterprises and the cheating scandals, most of which were released to the public in UltimateBet, Absolute Poker, or Kahnawake Gaming Commission press releases or statements.

The tone of the memo and words chosen by Leggett indicate that the 60 Minutes piece could portray online poker in a bad light. In fact, what Leggett fears is that Tokwiro and its online poker entities will look bad. Well, that is entirely possible because the way in which the scandals were handled was bad, and if that comes out in the reporting, who is really at fault, especially when the company in question refuses to go on camera with a statement and show otherwise? And in truth, what is said about AP, UB, and Tokwiro really doesn’t reflect on the entire online poker world, and there still remains some hope that the reporters for 60 Minutes and the Washington Post will make that clear distinction.

Of particular interest to me in this series of Tokwiro-sponsored videos was Leggett’s confirmation that no one was or will be legally prosecuted in the Absolute Poker scandal.

When the perpetrator was discovered in the AP insider cheating scandal, he was given protection from prosecution in exchange for information about the crime. If he told Tokwiro exactly how he got the hole card information, his name would not be released to the public and no legal action would be pursued. Leggett said that the Kahnawake Gaming Commission still reserves the right to prosecute if they so choose, but Tokwiro will not.

Leggett noted that the $800K that was stolen during the crime was still in the cheater’s online account and thus confiscated by Tokwiro to repay customers. However, Tokwiro had to pay an additional $800K out-of-pocket in interest to those customers. I guess the perpetrator’s inside info was worth nearly a million bucks…

Also interesting was the specific mention of Scott Tom in order to clear his name. Leggett said that he was only implicated because his IP address was used by the cheater. Really? So, does this make AJ Green a.k.a. AJ Grimard the one and only perpetrator, as no effort was made to clear him? And I suppose the lessons learned in the AP scandal better prepared Tokwiro to identify the problems in the UB scandal, not needing any information from Russ Hamilton and allowing prosecution in that case.

This is discussed in the video below (Part 2, Section 2) and starts at the beginning:

It’s not quite 60 Minutes … in fact, it’s closer to 73 minutes. Absolute Poker/Ultimate Bet honcho Paul Leggett speaks with the CBC’s (Canadian Broadcast Company) Susan Reisler for an extremely detailed and stoic Q&A. I can tell you I’m very suspicious. This looks like an infomercial to me. (The apparent title of the show is simply “Poker” — I wasn’t aware of that investigative journalism news program.) Though she gets into all the controversial issues — and even the inbred nature of AP/UB/Tokwiro/Norton/Kahnawake — there’s no follow-up to anything that might sound peculiar (like the inbred nature of AP/UB/Tokwiro/Norton/Kahnawake) … she just allows him to state the facts and timelines, as if he were giving a legal deposition under questioning from his own attorney.

CONFIRMED: This is indeed a production by Tokwiro Enterprises, aka AP/UB. Anyone wanna wager on how many attorneys were standing off-camera to keep all commentary in legal line?

Sorry if I sound cynical. Really, it’s an admirable effort from Paul Leggett, the guy Annie Duke stands so strongly behind. Via the mock news program format, he addresses just about any question any of us have had about the whole Black Sox of Poker sitch. Kudos to you, Mr. Leggett, seriously, and thanks for finally coming forward with so much candid info. Personally, I’m starting to see your point of view on all this … and there were only a few questions where your answers made me wonder why Ms. Reisler didn’t follow up with: “But don’t you think that sounds fucked up?”

Click here for the entire 9-part library … bonus points if you can find the point where Leggett says “We were the victim here.”

Also check out the vid below, where Annie Duke speaks her mind on why she’s so loyal and has so much faith in AP/UB security … right down to algorithms and dealing with bots … and be sure to watch 4 minutes and 10 seconds in, where Reisler does her 60 Minutes style wrap-up: Everything is safe and secure, and Russell Hamilton is the Ultimate Bad Guy — he’s not part of Tokwiro and is in really big trouble if they can ever get their hands on him.

[Cue neoclassical new-age healing music.]

NOTE: KafkaCR? That’s the new YouTube video uploader’s name … OK, the CR is for Costa Rica … but Kafka? The Jewish-Bohemian novelist who, according to Wikipedia, wrote about “troubled individuals in a nightmarishly impersonal and bureaucratic world”?

Oh, wait … I get it … Metamorphisis! Very clever project name, whether intentional or not.

A press release was just received from Tokwiro Enterprises, noting that a settlement was reached between Excapsa Software (previous owner of UltimateBet) and Tokwiro Enterprises (current owner of UB) for $15 million. The amount is the same as what was still owed to players who were cheated in the UB scandal, as determined by the Kahnawake Gaming Commission in its decision on the case, and those players have now received their refunds.

COURT APPROVES $15 MILLION SETTLEMENT OF TOKWIRO CLAIMS AGAINST EXCAPSA SOFTWARE
Tokwiro Claimed Damages As A Result of UltimateBet Cheating Scandal
Refunds To Affected Players Completed

MONTREAL (NOVEMBER 5, 2008) — Tokwiro Enterprises, ENRG (“Tokwiro”), the owner of AbsolutePoker and UltimateBet, today confirmed the settlement of its claims against Excapsa Software, the previous owner of UltimateBet. The Honorable Madame Justice Sarah E. Pepall of the Ontario Superior Court of Justice endorsed the settlement on November 3, 2008. Under the terms of the agreement, Excapsa will pay US$15 million to Blast-Off Ltd., the Tokwiro-controlled company that originally acquired UltimateBet. This payment will be used immediately to refund players who were affected by the cheating scandal that Tokwiro inherited when it purchased the business from Excapsa.

Paul Leggett, Tokwiro’s Chief Operating Officer, said: “We are pleased that we have finally agreed to a settlement with the previous owners of UltimateBet, and we are happy to announce the completion of the final refunds to players. Together with our regulatory body, the Kahnawake Gaming Commission, we have fought long and hard to hold those responsible accountable for the fraud, to refund players, and to ensure this can never happen again. Now that the main perpetrator has been named, the settlement with the previous owners is behind us, and players have received refunds, it should now be apparent that Tokwiro had no involvement in this cheating and that we have fought to correct it with every tool at our disposal.

“We continue to reserve the right to pursue further legal action against any individual or individuals involved in stealing from us or our customers. With this settlement, however, our claims against Excapsa are satisfied, and all player refunds will be completed. This brings us significantly forward in our search for justice in the aftermath of the cheating scandal,” concluded Mr. Leggett.

As noted in the original post, I recently interviewed Tokwiro Enterprises Chief Operating Officer Paul Leggett about a number of issues the recent UltimateBet and Absolute Poker scandals.

The interview transcript has been broken up into three parts and posted on PokerWorks. Part 1 focuses on Tokwiro’s purchase of AP and UB, and how any inkling of impropriety could be missed in the due diligence phase.

Part 2 delves deeper into the investigations – the internal UB one concluded by Tokwiro itself, the ongoing UB investigation by Gaming Associates, and the “surprise” assignment of Frank Catania to audit Tokwiro as a company. Leggett also discusses the reasons for the reimbursement process lag time, whether or not Russ Hamilton was involved in the cheating, and the roles of Phil Hellmuth and Annie Duke in it all.

In Part 3 I gave Leggett a chance to discuss what has been done at UB to rectify the problem and improve security going forward, and why customers should have confidence in UB and AP.

I feel that Leggett was as forthcoming as he was allowed to be, considering the restrictions inherent in the pursuit of legal action. He helped dispel some myths and rumors, though his inability to discuss Hamilton’s alleged involvement or any evidence in the case keeps interested parties in limbo for awhile longer. However, he helped put somewhat of a timeline on information he hopes will be released to the public, and he provided some details about how Tokwiro has tried to overcome the scandals, close security gaps, and regain the trust of the poker public.

Some might say that I’ve been a raving lunatic somewhat vocal about my frustrations with the AP and UB scandals. This is true, and thus I attempted to contact UltimateBet once again in July for answers to some of my questions. To my surprise, I was contacted by the Vice President of PR at Tokwiro Enterprises, UB’s parent company, who said she would respond to my inquiries. After two weeks of no such thing, I was on the verge of writing another rant/post here sending a polite follow-up when I received an e-mail asking if I’d like to speak with the Chief Operating Officer of Tokwiro, Paul Leggett. Ummm, yes, please.

I conducted the interview on Friday, Aug. 8, via telephone, and I must say that I was pleasantly surprised at Mr. Leggett’s willingness to answer my questions as he was able and be as honest as the corporate attorneys would allow. He has been reaching out to other media outlets lately, having done guest appearances on 2+2 and Pocket 5 podcasts, and I was happy to finally have a door opened and someone coming out to answer questions.

The full interview has been submitted to PokerWorks in a three-part series due to the length of the transcribed interview. The first article is up now, and the others will be posted in subsequent days.

Highlights of the interview included dispelling myths and rumors, speaking of the utmost confidence that the perpetrator(s) will be caught and prosecuted, and giving details about new security procedures and systems to prevent future improprieties.

A few excerpts:

In response to a question about how two companies, AP and UB, could be purchased without any knowledge of cheating going on at the highest levels:

“There definitely was due diligence done at the time of purchase… but this is a very large platform that we purchased. Unfortunately, during this due diligence process, we simply did not discover the code that was put on there…”

More…

Despite the fact that things are finally happening and some progress is being shown with regards to the UltimateBet investigation, it seems that everyone involved wants to suddenly be a part of bringing the scandal to some sort of resolution. After six months of acknowledging and investigating and hoping it goes away, the Kahnawake Gaming Commission, Gaming Associates, Frank Catania, Tokwiro Enterprises, and UB all care deeply about getting this done.

Funny how when a third party is brought in to investigate Tokwiro Enterprises, owner of UltimateBet and Absolute Poker, Tokwiro suddenly concludes its own UB investigation days later. Wait, Tokwiro was investigating its own company’s scandal? Sounds a little like the U.S. Government…but I won’t get into that here.

In a statement published on the UB website, Tokwiro comes to the surprising conclusion that it had no part in the cheating that took place on UB prior to the purchase of the company. It notes that there were 19 accounts and 88 usernames associated with the “complex web of player-to-player transfers and withdrawals” that took place to scam real players on the site, and refunds to cheated players are in the process of being determined and issued. All results of the investigation have reportedly been turned over to the KGC.

Here is the statement in full:

MONTREAL, CANADA – (July 25, 2008) – Tokwiro Enterprises ENRG (“Tokwiro”), proprietors of UltimateBet.com (“UB”), one of the ten largest on-line poker cardrooms, today announced that it has concluded the investigation into allegations of unfair play on UB’s web site.

Tokwiro has compiled complete forensic evidence including the IP addresses, devices, transfer and withdrawal histories, and names associated with the player accounts that benefited from illicitly viewing hole card information. The results of Tokwiro’s internal investigation have been turned over to the Kahnawake Gaming Commission (KGC) and its auditors, as that regulatory body continues its independent investigation. These results are in addition to the data which Tokwiro has already shared with the KGC.

Tokwiro has identified a total of 19 accounts and 88 associated usernames that were involved in the cheating, including the accounts that were named in Tokwiro’s publicly posted investigation updates of May 29, 2008 and July 8, 2008. The same perpetrators that were previously identified controlled all of these usernames. There are no new perpetrators involved, only new usernames. Usernames were changed many times over the course of the cheating scam in an apparent scheme to avoid detection. Our complete list of usernames involved in the cheating scheme has now been turned over to the KGC, and the Company does not expect to uncover any additional usernames.

Paul Leggett, Tokwiro’s Chief Operating Officer, said, “Make no mistake: our management team is outraged that this cheating occurred on our site through illicit software placed on the UB servers prior to our purchasing UltimateBet. Tokwiro is aggressively pursuing legal avenues of redress in order to protect and compensate our players and the business. Rest assured that we will release more information to the poker community and to the public at large as we enforce our and our players’ rights.”

“With respect to refunds to the affected players, we are continuing our analysis in order to determine the refund amounts. We will move forward with another round of refunds in the weeks ahead. We thank the poker community for its invaluable contributions to this investigation and assure it that we remain committed to fully investigating any claims of fraud on our site,” Mr. Leggett said.

The investigation revealed that the perpetrators logged into the client software, using an account that had the ability to view hole cards. The ability of a specific account to view hole cards was enabled by illicit software that was placed on the UltimateBet servers prior to October 2006, which was before Tokwiro acquired the business.

The account that was used to view hole cards never actually played in a game. Instead, the perpetrators used hole card information gained from logging in with this account while playing on other accounts, which thereby benefited from the cheating. The money won by the accounts that received hole card information was then moved around and off the site in a complex web of player-to-player transfers and withdrawals. This contributed to the complexity of Tokwiro’s efforts to uncover the truth.

Mr. Leggett concluded: “We cannot over-emphasize the fact that Tokwiro and its entire management team had no knowledge of the illicit software until it was revealed by our investigation; and no one associated with Tokwiro was involved in the cheating scheme at any point.”