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and other supporters (collectively supporters) to whom it
regularly sends mail (master list). The master list also
contains other information about the supporters, including their
gender and the frequency, recency, and amount of contributions
that each supporter has made to petitioner. Petitioner
communicates by direct mail with its supporters.
The master list is kept on large computerized databases that
petitioner regularly maintains and updates. Because it is very
valuable, petitioner builds its master list by acquiring new
names and addresses and guards its master list against misuse.
From the master list, petitioner creates another list that
contains names, addresses, and other limited information about a
segment of petitioner's supporters (rental list). Petitioner's
master and rental lists are intangibles in which petitioner has
ownership rights. Petitioner's master and rental lists are
valuable because they are collections of names and addresses of
people with similar characteristics such as willingness to
respond to solicitations received by mail and interest in
supporting certain types of tax-exempt organizations. Petitioner
makes its rental list available for rent or exchange with other
organizations.
The direct mail and mailing list industry has its own
industry standards and trade practices. In structuring its list
rental transactions, petitioner abides by the trade practices of
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Last modified: May 25, 2011