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USNB gave petitioner a list of alumni cardholders each
quarter. Petitioner's employees spent about 2 hours each quarter
entering data regarding credit card holders.
E. Postagreement Activities by USNB
1. USNB Mailings to Petitioner's Members
USNB hired and paid an advertising agency and direct mail
house to write, design, print, and mail solicitation materials to
petitioner's members. These mailings cost about $1.25 per item.
Petitioner gave signatures of its president to USNB to duplicate
on the promotional materials. USNB placed petitioner's logo on
the promotional materials in three places. An employee of
petitioner spent about 1 hour reviewing the material for each
mailing and occasionally suggested minor changes or made
corrections. Petitioner might suggest that USNB "tone down" the
pitch of the solicitation or correct the spelling of a name.
Petitioner had no authority to finally approve USNB's materials.
2. USNB's Advertising in the Oregon Stater
Petitioner's primary means of communicating with its alumni
is through the Oregon Stater and mailings. During the years at
issue, the Oregon Stater was mailed six times per year and had a
circulation of about 85,000. USNB paid petitioner to advertise
the affinity credit card program in the Oregon Stater. USNB gave
petitioner a copy of each advertisement to review and approve.
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Last modified: May 25, 2011