First of all, I would like to Thank Virginia Alcoholic Beverage Control Authority for the opportunity to comment.

3VAC5-80-50.

C. No distributor shall locate more than six skill game machines at any ABC retail licensed establishment or more than 12 skill game machines at any truck stop.

Comment: This section is not clear as there are so many locations at the moment with more than one operator. Can both operators register six machines? Or maximum 6 machine at any ABC retail licensed establishment. Moreover, adding limit defeat the purpose of this legislation. Locations which can afford more than 6 machines will be caped at 6 machines where on the other hand location can hardly afford 1 machine will be allowed to keep 6 machines. Since $1200 is significant amount no cap should be placed as no business owner/operator will keep more than required and it will help fulfill the purpose of this legislation.

3VAC5-80-80. Relocation of skill game machine from one establishment to another.

A. Skill game machines may be relocated from one qualified location to another qualified location or warehoused and subsequently placed a qualified location, provided however, a distributor may not relocate skill game machines in excess of 10% of the total number of skill games initially registered and available for play on June 30, 2020, by any distributor (e.g., distributor registers 5,000 machines = 500 relocations prior to July 1, 2021).

Comment : 10% relocation cap would favor those distributors with larger market. Again, any cap would defeat purpose of this legislation as it will reduce number of machines among smaller distributor. For example A distributor decided to place 2 machine at a particular location where 1 machine works great however other one is not. Distributor should be allowed to replace the machine which is not working as per expectation otherwise that machine will be reduced hence $1200 Tax will reduce along with the machine reduction.

Additionally, all distributor should communicate clearly with locations regarding $1200 tax if any portion of tax is to be collected with location as to determine by location if its affordable especially with 10% cap. This will avoid injustice to location any dispute post July 1^st. to avoid dispute post July 1^st all distributor should take an approval from location, this will also help in the case there are more than one distributor providing service at any location.