Tiltproof Incorporated Document No. Effective Date Revision Date Approval 5.2.

13 12/21/2007 GN SM

FirePay Deactivations/Reactivations

1.0 Purpose:

This document establishes how to handle FirePay deactivations and reactivations.

2.0 Persons Affected: 3.0 Forms, Checklists, Flowchart:

1) Fraud Analysts

1) Spreadsheet of players with outstanding returns owed from FirePay: [S:\FTP_Fraud_Department\Processors and Monthly Reports\PW protected files\Outstanding Returns Owed From Firepay Players.xls]. 2) Daily deposits and seizure request spreadsheet: [S:\FTP_Fraud_Department\(MONTH)DAILY DEPS+SEIZURES\]. 3) Printable version: \\tpfs1nw\workflow$\HANDBOOK-FRAUD\Print Versions\Fraud Handbook\5.2.12 FirePay Deactivations Reactivations.doc 1) Players must repay any debt owed to Full Tilt Poker (FTP) before their account is reopened. This is the same process as credit card chargebacks. 2) Confirm all deactivation amounts in WAT notes with the Outstanding Returns Owed From Firepay Players.xls spreadsheet. The WAT notes are not reliable. 3) If a players name does not appear on the Outstanding Returns Owed From Firepay Players.xls spreadsheet, they were deactivated due to a deposit made on another website. The player does not owe FTP. 1) Open Outstanding Returns Owed From Firepay Players.xls and look up the players email address to determine how much the player owes. a) If the player does not owe FTP, unpause their account and send them frd.firepay.nodebt. b) If the player owes an amount equal to or less than their current FTP account balance, proceed to section B) Seizing Funds. c) If a player owes an amount more than their current FTP account

4.0 Policy:

5.0 Procedure:

Tiltproof Incorporated balance, proceed to section A) Handling Requests to Deposit Funds Owed. A) Handling Requests to Deposit Funds Owed 1) Under the Security and Limits tab: a) Restrict the Player Rights by selecting: No Chat No Mix No Txfr No Play No Tour b) Notate with: UNPAUS: Unpaused and placed restrictions on account so player can repay FirePay debt of $____. Once player has deposited, pause account and route email to the "FirePay Deactivation & Debt Reconciliation" queue in the Fraud Investigation Root.

c) Select Save. 2) Unpause their account in WAT. 3) Email the player frd.firepay.owes. 4) When the player has deposited and responded to the email, pause the account and proceed to section B) Seizing Funds. B) Seizing Funds 1) Request the funds seizure by adding the required information to [S:\FTP_Fraud_Department\DAILY DEPS+SEIZURES\(MONTH)DAILY DEPS+SEIZURES LOG.xls] as per 5.17 Requesting a Seizure or Deposit. Date Type: Seizure Player ID Amount Fraud Analyst Email Required: Yes/No 2) Save the spreadsheet. 3) Notate the player account with: FYI: Seizure for $______ has been requested to repay FirePay debt.

C) Completed Seizure 1) Shaun from Dublin will confirm the funds have been seized by emailing <fraudoperations@fulltiltpoker.com>. 2) Set the players deposit limits at $600/$1,500/$2,000 as per 3.3.6. Deposits and Limits. 3) Notate the player account with: LIMITS: Limits must stay at 600/1,500/2,000 for 60 days due to FirePay Deactivation.

Tiltproof Incorporated

4) Under the Security and Limits tab: a) Restore the Player Rights by unselecting: No Chat No Mix No Txfr No Play No Tour b) Notate account with: UNPAUSE: Player has repaid debt
to FirePay. Account in good standing.

c) Select Save. 5) Unpause the players account. 6) Email the player frd.firepay.repaid. 7) Add the appropriate information to [S:\FTP_Fraud_Department\DAILY DEPS+SEIZURES\(MONTH)-DAILY DEPS+SEIZURES LOG.xls] as per 5.17 Requesting a Seizure or Deposit. Item Actioned: Yes/No if the seizure has been completed Fraud Analyst Email Sent: Yes/No Additional Notes: Chargebacks 8) Save the spreadsheet.

6.0 Definitions:

7.0 Revision History: