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utilized much more efficiently than previously was possible.
Before the use of computers, mailing lists were maintained on 3-
by-5 cards or on metal plates.
Richard Viguerie (hereinafter sometimes referred to as
Viguerie) was an early pioneer in the contemporary direct mail
fundraising industry. By the late 1970's, Viguerie and his
company, Richard Viguerie and Associates (hereinafter sometimes
referred to as the Viguerie Company), had received considerable
press and publicity as a result of their ability to successfully
conduct direct mail fundraising campaigns for “conservative”
political candidates and causes. The Viguerie Company reportedly
had a master mailing list comprising the names and addresses of
millions of contributors. The Viguerie Company also conducted
nonpolitical direct mail fundraising campaigns for charitable
organizations exempt under section 501(c)(3).
As of the early 1980's, Viguerie and the Viguerie Company,
which maintained offices in the Washington, D.C., area, had
several competitors who offered similar fundraising services.
Some of these competitors were former employees of the Viguerie
Company.
By the 1980's, many States enacted charitable solicitation
statutes. Generally, such statutes require most charitable
organizations to register with a State governmental regulatory
agency before soliciting contributions from members of the
general public within that State. Some State charitable
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