Sierra Club, Inc. - Page 15




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          contained the letterheads of both petitioner and Chase Lincoln              
          and facsimile signatures of officers of both organizations.  ABS            
          paid all of the costs of that letter.                                       
          Advertisements                                                              
               Advertisements for the credit card program appeared in                 
          three issues of petitioner’s magazine, Sierra, during each of               
          1986 and 1987.  Those advertisements (the advertisements) were              
          designed by JMP Marketing and Design, a design agency retained by           
          ABS.  The advertisements instructed petitioner’s members to                 
          submit applications to Chase Lincoln and to direct questions to             
          ABS.  ABS was billed for the advertisements at the same prices              
          and on the same terms as applicable to any unrelated advertiser.            
          ABS failed to pay amounts billed to it for the 1987                         
          advertisements in the amount of $8,230.  Petitioner attempted to            
          collect that amount but was unsuccessful.                                   
               ABS also placed advertisements for the credit card program             
          in publications of local chapters of petitioner.  ABS paid for              
          those advertisements and received no discount from the rates                
          charged others.                                                             
          Administration of the Program                                               
               Petitioner did not maintain individual files concerning                
          each member’s participation in the credit card program.  The                
          credit card program was administered, and records kept, by ABS              
          and Chase Lincoln.  Members’ complaints and inquiries with                  
          respect to the credit card program were directed to ABS or Chase            
          Lincoln.                                                                    

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Last modified: May 25, 2011