LOL, yes they are, It is ultimate bets software and affiliate program with no blackjack commission and no tournament fees either!!!
I found this out when i signed up for a tournament and an email from ultimate bet said i just entered a tournament at bet21.com
I asked to join the affiliate program, they sent me to ultimate bets program. Only after 10 emails to join and about a month of begging them!!!
Just not a good group at all 