P. S. Docket No. 38/122
July 24, 1992
In the Matter of the Complaint Against: )
)
DIRECTORY PUBLISHING SERVICES )
1326 S.E. 17th St., Suite 285 )
Fort Lauderdale, FL 3316-1708 )
)
and )
)
6454 N.W. 5th Way )
Fort Lauderdale, FL 33309-6112 )
c/o )
HOWARD ALLEN COHEN )
One Biscayne Tower, Suite 3750 )
Miami, FL 33131-1803 )
)
and )
)
DAVID JOHN GLENN )
99 Harbour Square, #1509 ) P. S. Docket No. 38/122
Toronto, Ontario )
Canada M5J2H2 )
)
and )
)
RALPH LAWRENCE DIVINE )
Rural Route 1 )
Bolton, Ontario )
Canada )
)
d/b/a )
YELLOW PAGES OF ALABAMA )
421 S. McDonough St. )
Montgomery, AL 36104-4262 )
)
and )
)
YELLOW PAGES OF ARIZONA )
5399 E. 29th Street )
Tucson, AZ 87511-6598 )
)
and )
)
YELLOW PAGES OF CALIFORNIA )
256 S. Robertson Blvd., Suite 42 )
Beverly Hills, CA 90211-2898 )
)
and )
)
YELLOW PAGES OF CALIFORNIA )
1255 Post Street, Suite 625 )
San Francisco, CA 94109-6709 )
)
and )
)
YELLOW PAGES OF CALIFORNIA )
2443 Fillmore Street, Suite 317 )
San Francisco, CA 94115-1825 )
)
and )
)
YELLOW PAGES OF COLORADO )
1750 - 30th Street, Suite 435 )
Boulder, CO 80301 )
)
and )
)
YELLOW PAGES OF FLORIDA )
1326 S.E. 17th Street, Suite 285 )
Fort Lauderdale, FL 33316 )
)
and )
)
YELLOW PAGES OF GEORGIA )
2625 Piedmont Ave., Suite 56 )
Atlanta, GA 30324 )
)
and )
)
YELLOW PAGE OF ILLINOIS )
3023 N. Clark St., Suite 311 )
Chicago, IL 60657 )
)
and )
)
YELLOW PAGES OF INDIANA )
4010 W. 86th St., Suite D )
Indianapolis, IN 46268-1779 )
)
and )
)
YELLOW PAGES OF IOWA )
150 1st Ave., NE, Suite 300 )
Cedar Rapids, IA 52401-1110 )
)
and )
)
YELLOW PAGES OF KENTUCKY )
607 South Broadway )
Lexington, KY 40508-3125 )
)
and )
)
YELLOW PAGES OF LOUISIANA )
651 Laurel Street )
Baton Rouge, LA 70802-5632 )
)
and )
)
YELLOW PAGES OF MARYLAND )
444 East Belvedere Ave., Suite 349 )
Baltimore, MD 21212 )
)
and )
)
YELLOW PAGES OF MICHIGAN )
3319 Greenfield Road, Suite 323 )
Dearborn, MI 48120 )
)
and )
)
YELLOW PAGES OF MINNESOTA )
2200 West 66th Street, Suite 206 )
Richfield, MN 55423 )
)
and )
)
YELLOW PAGES OF NEW ENGLAND )
1430 Massachusetts Ave., Suite 3000 )
Cambridge, MA 02138 )
)
and )
)
YELLOW PAGES OF NEW JERSEY )
555 Route 1 South, Suite 2000 )
Iselin, NJ 08830 )
)
and )
)
YELLOW PAGES OF NEW YORK )
9728 3rd Ave., Suite 340 )
Brooklyn, NY 11209 )
)
and )
)
YELLOW PAGES OF NORTH CAROLINA )
500 N. College Street, Suite 100 )
Charlotte, NC 28202 )
)
and )
)
YELLOW PAGES OF OHIO )
23200 Chagrin Blvd., Suite 2-160 )
Cleveland, OH 44122 )
)
and )
)
YELLOW PAGES OF OREGON )
5430 N. Gay Ave. )
Portland, OR 97217-4494 )
)
and )
)
YELLOW PAGES OF PENNSYLVANIA )
813 Copeland Way, Suite 24 )
Pittsburgh, PA 15232 )
)
and )
)
YELLOW PAGES OF SOUTH CAROLINA )
1218 Henderson Street )
Columbia, SC 29201-3422 )
)
and )
)
YELLOW PAGES OF TENNESSEE )
95 White Bridge Rd., Suite 304 )
Nashville, TN 37205-1427 )
)
and )
)
YELLOW PAGES OF SOUTHWEST )
13931 N. Central Expwy., Ste 318-130 )
Dallas, TX 75243 )
)
and )
)
YELLOW PAGES OF VIRGINIA )
9056 W. Broad Street, Suite 801 )
Richmond, VA 23294 )
)
and )
)
YELLOW PAGES OF WASHINGTON )
7030 15th Ave., N.W. )
Seattle, WA 98117-5598 )
)
and )
)
YELLOW PAGES OF WISCONSIN )
5464 N. Port Washington Rd., Ste. 111 )
Milwaukee, WI 53217 )
APPEARANCE FOR RESPONDENT: Frank J. Shannon, III, Esq.
127 Peachtree Street, N.E.
422 Candler Building
Atlanta, GA 30303-1827
APPEARANCE FOR COMPLAINANT: Jerry Belenker, Esq.
Consumer Protection Division
Law Department
United States Postal Service
Washington, DC 20260-1144
INITIAL DECISION
In a complaint filed October 29, 1991, Complainant, the General Counsel of the United States Postal Service, alleged that Respondents Directory Publishing Services, Howard Allen Cohen and David John Glenn, d/b/a/ Yellow Pages of California are violating 39 U.S.C. § 3005 in conducting a scheme for obtaining money and property through the mails by means of false representations conveyed by solicitations which are in the form of invoices, nonmailable under 39 U.S.C. § 3001(d). The seven false representations alleged in paragraph 8 of the complaint are set forth in the Findings of Fact, below. The complaint was amended on January 28, 1992, to add Ralph Lawrence Divine as a respondent, further amended on March 20, 1992, to add Yellow Pages of Maryland, Tennessee and Virginia, and amended at the hearing to add addresses related to the Yellow Pages of Alabama, Arizona, Colorado, Florida, Georgia,Illinois, Indiana, Iowa, Kentucky, Louisiana, Michigan, Minnesota, New England, New Jersey, New York, North Carolina, Ohio, Oregon, Pennsylvania, South Carolina, Southwest, Washington, and Wisconsin. The opposition by Respondents to the amendments adding addresses will be discussed below.
Respondents' answer to the complaint denied violation of the statute as alleged in the complaint and, in addition, asserted jurisdictional and due process defenses.
An evidentiary hearing, before the undersigned, was held on March 30 and 31, 1992, in Washington, DC. Testifying for Complainant were Edward G. Blackman, vice-president of Yellow Page Publishers Association (YPPA); Michael K. Reagan, president and chief executive officer of Yellow Pages of Tennessee, Inc.; Ann P. Telthorst, regional products manager, Pacific Bell Directories; and consumer witnesses Gregory G. Russo, Alan Turner, and Brian Lamont Holmes. Ralph Lawrence Divine, co-owner of Directory Publishing Services, was the sole witness for Respondents.
The parties have filed proposed findings of fact and conclusions of law. To the extent indicated, they have been adopted. Otherwise, they have been rejected as irrelevant or contrary to the evidence or applicable precedent. Based on the entire record herein and my observation of the witnesses and their demeanor, I make the following findings of fact and conclusions of law.
FINDINGS OF FACT
1. Directory Publishing Services, Inc. (DPS) is a Florida corporation with a place of business at 6454 N.W. 5th Way, Fort Lauderdale, FL 33309-6112. It also receives mail at 1326 S.E. 17th Street, Suite 285, Fort Lauderdale, FL 33316-1703 (Ans. to Amended Complaint, ¶ 2).
2. Respondent David John Glenn resides at 99 Harbour Square,#1509, Toronto, Ontario, Canada M5J2H2. He has an ownership interest of fifty percent in DPS and, along with Respondent Ralph Lawrence Divine, who resides at Rural Route 1, Bolton, Ontario, Canada, and owns fifty percent of the company, directs and controls the corporations activities (Ans. to Amended Complaint, ¶ ¶ 3 & 4).
3. The Respondents do business as the following Yellow Pages at the addresses set forth below:
YELLOW PAGES OF ALABAMA
421 S. McDonough St.
Montgomery, AL 36104-4262
and
YELLOW PAGES OF ARIZONA
5399 E. 29th Street
Tucson, AZ 87511-6598
and
YELLOW PAGES OF CALIFORNIA
256 S. Robertson Blvd., Suite 42
Beverly Hills, CA 90211-2898
and
YELLOW PAGES OF CALIFORNIA
1255 Post Street, Suite 625
San Francisco, CA 94109-6709
and
YELLOW PAGES OF CALIFORNIA
2443 Fillmore Street, Suite 317
San Francisco, CA 94115-1825
and
YELLOW PAGES OF COLORADO
1750 - 30th Street, Suite 435
Boulder, CO 80301
and
YELLOW PAGES OF FLORIDA
1326 S.E. 17th Street, Suite 285
Fort Lauderdale, FL 33316
and
YELLOW PAGES OF GEORGIA
2625 Piedmont Ave., Suite 56
Atlanta, GA 30324
and
YELLOW PAGE OF ILLINOIS
3023 N. Clark St., Suite 311
Chicago, IL 60657
and
YELLOW PAGES OF INDIANA
4010 W. 86th St., Suite D
Indianapolis, IN 46268-1779
and
YELLOW PAGES OF IOWA
150 1st Ave., NE, Suite 300
Cedar Rapids, IA 52401-1110
and
YELLOW PAGES OF KENTUCKY
607 South Broadway
Lexington, KY 40508-3125
and
YELLOW PAGES OF LOUISIANA
651 Laurel Street
Baton Rouge, LA 70802-5632
and
YELLOW PAGES OF MARYLAND
444 East Belvedere Ave., Suite 349
Baltimore, MD 21212
and
YELLOW PAGES OF MICHIGAN
3319 Greenfield Road, Suite 323
Dearborn, MI 48120
and
YELLOW PAGES OF MINNESOTA
2200 West 66th Street, Suite 206
Richfield, MN 55423
and
YELLOW PAGES OF NEW ENGLAND
1430 Massachusetts Ave., Suite 3000
Cambridge, MA 02138
and
YELLOW PAGES OF NEW JERSEY
555 Route 1 South, Suite 2000
Iselin, NJ 08830
and
YELLOW PAGES OF NEW YORK
9728 3rd Ave., Suite 340
Brooklyn, NY 11209
and
YELLOW PAGES OF NORTH CAROLINA
500 N. College Street, Suite 100
Charlotte, NC 28202
and
YELLOW PAGES OF OHIO
23200 Chagrin Blvd., Suite 2-160
Cleveland, OH 44122
and
YELLOW PAGES OF OREGON
5430 N. Gay Ave.
Portland, OR 97217-4494
and
YELLOW PAGES OF PENNSYLVANIA
813 Copeland Way, Suite 24
Pittsburgh, PA 15232
and
YELLOW PAGES OF SOUTH CAROLINA
1218 Henderson Street
Columbia, SC 29201-3422
and
YELLOW PAGES OF TENNESSEE
95 White Bridge Rd., Suite 304
Nashville, TN 37205-1427
and
YELLOW PAGES OF THE SOUTHWEST
13931 N. Central Expwy., Suite 318-130
Dallas, TX 75243
and
YELLOW PAGES OF VIRGINIA
9056 W. Broad Street, Suite 801
Richmond, VA 23294
and
YELLOW PAGES OF WASHINGTON
7030 15th Ave., N.W.
Seattle, WA 98117-5598
and
YELLOW PAGES OF WISCONSIN
5464 N. Port Washington Rd., Ste. 111
Milwaukee, WI 53217
(Ans. to Cplt. ¶ 4; Ans. to Amended Cplt., ¶ 5; RX-82; Exhibits 1, 2, and 3 to Cplt's. Motion to Amend Cplt. 3/9/92; Resp's. Proposed Findings of Fact 113; Resps. failed to deny the amendments allowed on 2/9/92 and at the hearing. They are, therefore, treated as admitted.)
4. a. The scheme alleged in the complaint, and proved at the hearing, employs direct mailings to business entities, soliciting business listings in Respondent's Yellow Page directories. A typical solicitation (CX-66-a) is annexed hereto as Exhibit A. Between June 20, 1991 and the dates of the hearing, Respondents mailed approximately 6.5 million such solicitations (RX-83).
b. The typical solicitation used by Respondents is captioned "YELLOW PAGES OF CALIFORNIA" (or other state or area), contains a proposed listing consisting of the recipient's business name, address and telephone number and the Yellow Page heading (or category) under which the proposed listing will appear. The recipient is requested to check a box authorizing DPS to "Print Listing as Shown in Next Edition" or to make "Corrections Indicated Before Printing." The solicitation states that "A free white page listing will be included for each listing published at annual rate of $117.00." Recipients are instructed to sign and return the bottom portion of the solicitation by the "printing deadline", a specified date, to "avoid omission." At the bottom of the solicitation, appears the statement, "Directory Publishing Services is not affiliated with AT&T or any local telephone company." In the middle of the solicitation in large, distinctive print appears the statement, "THIS IS NOT A BILL."
5. Between June 20 and August 15, 1991, on the face of the envelope in which solicitations were mailed appeared the words "Yellow Pages ... The Smart Choice" (CX-63, 64). Following August 15, after complaint made to Respondent by Pacific Telesis Group (publisher of Pacific Bell classified telephone directories) that use of these words by Respondent was misleading and constituted trademark and trade name infringement, Respondent discontinued use of these words (CX-18).
6. If a recipient returns the signed solicitation to Respondent, it receives a bill for a specified amount, usually $117.00, with a specified due date (for example, CX-41) to be sent to one of the captioned Yellow Page addresses (CX-44, 47, 61).
7. As of the date of the hearing (March 30-31, 1992), Respondent Ralph Divine was able to state with some certainty that five directories had been published; California, New England, Southwest, Colorado and Florida. As to the remaining directories, they had either not been published or he was unable to state whether they had been published (Tr. 354-357).
The Alleged False Representations
8. (a) the addressee has previously authorized a business listing in respondents' telephone directory This representation is implicit in the solicitation for the following reasons:
(a) Businesses are usually listed in a yellow page directory which covers their area or community (Tr. 90, 95). Many recipients of Respondents' solicitations are under the impression that it is from the publisher of a yellow page directory in which their businesses have previously been listed. This impression is conveyed by the words "Yellow Pages" and the walking fingers logo (Tr. 22, 27, 42, 214, 225, 227, 258, 262-264). The impression is enhanced by the repeated use of the word "listing" and the words "Record No." near the bottom of the solicitation which suggest that the recipient has an existing account reflecting previous authorization for a listing in the directory as do the phrases "ATTENTION: PRINTING DEADLINE/TO AVOID OMISSION ***" and "PRINT LISTING AS SHOWN IN NEXT EDITION (emphasis added). The disclaimer of affiliation with a telephone company, in small print at the bottom of the solicitation, is insufficient to overcome or alter the impression created by the foregoing factors that the recipient has previously authorized a business listing in Respondents' telephone directory. The representation is false because up to the time of the hearing, most, if not all, of the recipients of the solicitations had never been listed in a directory involved in this proceeding and Respondent had not published even one edition of most of such directories. The representation is materially false.
9. (b) the amount set forth on the face of the solicitation is due and owed to respondents
This representation is not made in the solicitations, either expressly, by implication or, as Complainant argues, "subtly." The solicitations state too plainly to be misconstrued, overlooked, or ignored that they are solicitations, not bills.
10. (c) respondents are the publishers of the phone directory or "yellow pages" customarily supplied to business telephone subscribers in the recipient's area
The following elements of the solicitations make this representation, by implication, to many recipients and in the mind of the undersigned: (a) the yellow paper on which the solicitations are printed and the heading "YELLOW PAGES OF CALIFORNIA" or other state or area; (b) the walking fingers logo in the upper left corner with the words "Yellow Pages" under it and the same logo much enlarged in the upper center of the page with the words "YELLOW PAGE HEADING" centered within it; (c) the sentence "A free white page listing will be included for each listing published at annual rate of $117.00" (emphasis added).
The walking fingers logo and the words "Yellow Pages" are associated with the local telephone company yellow page directory by many ordinary readers (Tr. 22, 27, 42, 134, 214, 225, 227, 258, 262-264). Free white page listings are ordinarily furnished by the company publishing the local yellow pages distributed free to telephone subscribers (Tr. 66, 97, 126). Businesses generally pay only for enhanced advertising in such directories (Tr. 66, 126).
This representation is false and material.
11. (c) the area of distribution of respondents' directory is the same as the one in which the recipient presently has a listing
This representation is implicitly made as a corollary to false representations (a) and (c), supra (Findings 8 and 10). It is false and material.
The statement near the middle of the front page of the solicitation that it is for "your statewide yellow page listing" would tend to be overlooked or given little attention by the ordinary recipient because of the dominant false representations in the solicitation found above in Findings 8 and 10.
12. (e) publication and distribution of respondents' directory will take place in accordance with time frames customary to the authorized "yellow pages" industry publication and distribution standards
This representation is implicitly made as a result of the false representation (found in Finding 10, supra) that Respondents'publication is the telephone directory or yellow pages customarily supplied to business subscribers in the recipient's area.
Yellow Page directories are normally issued yearly, at fixed times (Tr. 103). Respondent Ralph Divine testified that the target date for publication of all DPS directories is 12 months from the mailing of solicitations for each directory (Tr. 360, 362). Complainant has failed to present evidence proving that the representation is false.
13. (f) Respondents also provide a free white-page listing
This representation is made in the statement that "a free white page listing will be included for each listing published at annual rate of $117.00."
The ordinary reader of the solicitation would believe that the "white-page listing" is the listing in the white pages telephone directory distributed free to all telephone subscribers. But, in fact, Respondents' white-page listing is available only to businesses which pay for a listing in their directories and, therefore, is not free.
The representation is false and material.
14. (g) Respondents have previously published a telephone directory
This representation is implicitly made as a corollary to false representations (a) and (c), supra. It is enhanced by the use of the term "NEXT EDITION" ("PRINT LISTING AS SHOWN IN THE NEXT EDITION"). "NEXT" in this context would mean to the ordinary reader that there has been a preceding edition ("next *** 1: immediately preceding or following (as in place, rank or time) ***" Webster's Ninth New Collegiate Dictionary, Merriam-Webster Inc. 1986, p. 797). There has been no preceding edition of any of Respondents' directories involved in this proceeding. Therefore, the representation is false and material.
15. The purpose of the solicitations is to induce recipients to sign and return an order for advertising, thereby obligating them to pay for it. The representations found in Findings 8, 10, 11, 12, 13 and 14, supra, individually and collectively tend to create the desired inducement. Accordingly, they are material.
16. Respondents' solicitations, for the reasons set forth in Finding 9, supra, are not in the form of invoices, nonmailable under 39 U.S.C. § 3001(d).
CONCLUSIONS OF LAW
1. (a) Respondents' solicitations must be considered as a whole and the meaning is to be determined in light of the probable impact of this material on a person of ordinary mind. Donaldson v. Read Magazine, 333 U.S. 178, 189 (1948); Peak Laboratories, Inc. v. U. S. Postal Serv., 556 F.2d 1387, 1389 (5th Cir. 1977). The statute is intended to protect the gullible, naive, and less critical reader, as well as the more sophisticated, wary reader. Fields v. Hannegan, 162 F.2d 17 (D.C. Cir. 1947), cert. denied, 332 U.S. 773 (1947); M.K.S. Enterprises, Inc. v. United States Postal Service, 459 F. Supp. 1180, 1184 (E.D.N.Y. 1978); Gottlieb v. Schaffer, 141 F. Supp. 7 (S.D.N.Y. 1956); Leo Daboub, P. S. Docket No. 19/185 (P.S.D. July 10, 1986). Express misrepresentations are not required. It is the net impression which the advertisement is likely to make upon individuals to whom it is directed which is important, and even if an advertisement is so worded as not to make an express representation, if it is artfully designed to mislead those responding to it, the false representation statute is applicable. G. J. Howard Co. v. Cassidy, 162 F. Supp. 568 (E.D.N.Y. 1958); See also, Virginia State Board of Pharmacy v. Virginia Citizens Consumer Council, 425 U.S. 748 (1976).
(b) Where an advertisement is ambiguous or capable of more than one meaning, if one of those meanings is false, the advertisement will be held to be misleading. Rhodes Pharmacal Co. v. F.T.C., 208 F.2d 382, 387 (7th Cir. 1953); Ralph J. Galliano, P. S. Docket No. 19/15 (P.S.D. May 2, 1985 at p. 9). It is not difficult to select words that will not deceive. See, United States v. 95 Barrels of Vinegar, 265 U.S. 438 (1924).
(c) An inconspicuous disclaimer is not sufficient to dispel the effect of false representations. Leo Daboub, supra; Gottlieb v. Schaffer, supra.
(d) The Administrative Law Judge can determine whether the representations are made, their effect on the ordinary mind, and materiality without the assistance of lay or expert testimony. Standard Research Labs, P. S. Docket No. 7/78 (P.S.D. Oct. 27, 1980); The Robertson-Taylor Company, P. S. Docket Nos. 16/98-102, 16/120-121, (P.S.D. March 31, 1986 at page 29); Vibra-Brush v. Schaffer, 152 F. Supp. 461 (S.D.N.Y. 1957), rev'd on other grounds, 256 F.2d 681 (2nd Cir. 1958).
(e) The issue in this proceeding under 39 U.S.C. § 3005 is whether materially false representations are being made by the entire solicitation, not whether Respondents have a right to use any particular logo. See, Scott David Wilcox, P. S. Docket No. 18/147 (P.S.D. April 20, 1988); Telco Directories, Inc., P. S. Docket No. 22/111 (P.S.D. February 25, 1987. Although the "Walking Fingers" logo is not copyrighted, it has been held to contribute to the overall impression that a mailing is from the yellow page directory published by the local telephone company. Mid-Am Marketing, Inc., P. S. Docket No. 24/12 (P.S.D. January 5, 1987).
2. Applying the foregoing standards, I find that Respondents' solicitations make the representations alleged in ¶ 8(a) and 8(c)-(g) of the complaint. The language contained in the solicitations which makes these representations is set forth in the findings of fact. Representation 8(b) is not made.
3. As set forth in the findings of fact, the representations set forth in paragraph 8(a), (c), (d), (f) and (g) of the complaint are materially false. Complainant has failed to prove that Representation 8(e) is false.
4. The false representations found are material because they have a tendency to persuade readers to order and pay for Respondents' product.
5. The best evidence that a mailing appears to be an invoice is the mailing itself. Telex & twx Directory, P. S. Docket No. 13/6 (P.S.D. April 1, 1983). As set forth in the findings of fact under Representation (b), Respondents' solicitations do not appear to the ordinary reader to be a bill, invoice, or statement of account arising out of a previous obligation to pay for advertising in the Respondents' yellow pages telephone directories. Accordingly, the statute and regulations do not require the mailing to contain the statutory disclaimer. 39 U.S.C. § 3001(d).
6. With the exception of Representations 8(b) and (e), Complainant has established its case by a preponderance of the reliable and probative evidence of record. S.E.C. v. Savoy Industries, Inc., 587 F.2d 1149, 1168 (D.C. Cir. 1978).
7. Respondents argue that the undersigned lacked jurisdiction to hear this case because Complainant's oral motion to amend the complaint to add additional directories and addresses, made on the opening day of the hearing, was improperly allowed in that it was not in writing filed with the Recorder and was not served on Respondents at the various addresses involved. Respondents say the procedure followed by the undersigned was in direct conflict with 39 C.F.R. § 952.12. In support of this defense, Respondents cite several federal rules decisions which require, they contend, for valid amendment of a complaint that a new complaint including the amendments be drafted, filed with the court, and served on the parties. 39 C.F.R. § 952.12(a) provides that amendments proposed prior to hearing shall be filed with the Recorder, therefore necessarily in writing, and that amendments proposed thereafter shall be filed with the presiding officer. Routinely, presiding officers have allowed the oral filing of amendments on the record during hearings, treating this procedure as complying with the rule, as the undersigned did here. Respondents have shown no genuine resulting prejudice. In fact, by way of their proposed finding of fact no. 113, they admit they do business as the numerous Yellow Pages added by the amendment allowed at the hearing. The procedure followed in connection with such amendment was consistent with the rule as routinely applied and did not vitiate my jurisdiction to hear the case.
8. Respondents are engaged in the conduct of a scheme for obtaining remittances of money through the mail by means of materially false representations in violation of 39 U.S.C. § 3005.
9. The attached False Representation Order and Cease and Desist Order should be issued.
Quentin E. Grant
Chief Administrative Law Judge
DIRECTORY PUBLISHING SERVICES, et al. ATTACHMENT 2
YELLOW PAGES OF ALABAMA
421 S. McDonough St.
Montgomery, AL 36104-4262
and
YELLOW PAGES OF ARIZONA
5399 E. 29th Street
Tucson, AZ 87511-6598
and
YELLOW PAGES OF CALIFORNIA
256 S. Robertson Blvd., Suite 42
Beverly Hills, CA 90211-2898
and
YELLOW PAGES OF CALIFORNIA
1255 Post Street, Suite 625
San Francisco, CA 94109-6709
and
YELLOW PAGES OF CALIFORNIA
2443 Fillmore Street, Suite 317
San Francisco, CA 94115-1825
and
YELLOW PAGES OF COLORADO
1750 - 30th Street, Suite 435
Boulder, CO 80301
and
YELLOW PAGES OF FLORIDA
1326 S.E. 17th Street, Suite 285
Fort Lauderdale, FL 33316
and
YELLOW PAGES OF GEORGIA
2625 Piedmont Ave., Suite 56
Atlanta, GA 30324
and
YELLOW PAGE OF ILLINOIS
3023 N. Clark St., Suite 311
Chicago, IL 60657
and
YELLOW PAGES OF INDIANA
4010 W. 86th St., Suite D
Indianapolis, IN 46268-1779
and
YELLOW PAGES OF IOWA
150 1st Ave., NE, Suite 300
Cedar Rapids, IA 52401-1110
and
YELLOW PAGES OF KENTUCKY
607 South Broadway
Lexington, KY 40508-3125
and
DIRECTORY PUBLISHING SERVICES, et al. ATTACHMENT 2
YELLOW PAGES OF LOUISIANA
651 Laurel Street
Baton Rouge, LA 70802-5632
and
YELLOW PAGES OF MARYLAND
444 East Belvedere Ave., Suite 349
Baltimore, MD 21212
and
YELLOW PAGES OF MICHIGAN
3319 Greenfield Road, Suite 323
Dearborn, MI 48120
and
YELLOW PAGES OF MINNESOTA
2200 West 66th Street, Suite 206
Richfield, MN 55423
and
YELLOW PAGES OF NEW ENGLAND
1430 Massachusetts Ave., Suite 3000
Cambridge, MA 02138
and
YELLOW PAGES OF NEW JERSEY
555 Route 1 South, Suite 2000
Iselin, NJ 08830
and
YELLOW PAGES OF NEW YORK
9728 3rd Ave., Suite 340
Brooklyn, NY 11209
and
YELLOW PAGES OF NORTH CAROLINA
500 N. College Street, Suite 100
Charlotte, NC 28202
and
YELLOW PAGES OF OHIO
23200 Chagrin Blvd., Suite 2-160
Cleveland, OH 44122
and
YELLOW PAGES OF OREGON
5430 N. Gay Ave.
Portland, OR 97217-4494
and
YELLOW PAGES OF PENNSYLVANIA
813 Copeland Way, Suite 24
Pittsburgh, PA 15232
and
2
DIRECTORY PUBLISHING SERVICES, et al. ATTACHMENT 2
YELLOW PAGES OF SOUTH CAROLINA
1218 Henderson Street
Columbia, SC 29201-3422
and
YELLOW PAGES OF TENNESSEE
95 White Bridge Rd., Suite 304
Nashville, TN 37205-1427
and
YELLOW PAGES OF THE SOUTHWEST
13931 N. Central Expwy., Suite 318-130
Dallas, TX 75243
and
YELLOW PAGES OF VIRGINIA
9056 W. Broad Street, Suite 801
Richmond, VA 23294
and
YELLOW PAGES OF WASHINGTON
7030 15th Ave., N.W.
Seattle, WA 98117-5598
and
YELLOW PAGES OF WISCONSIN
5464 N. Port Washington Rd., Ste. 111
Milwaukee, WI 53217
3
DIRECTORY PUBLISHING SERVICES, et al. ATTACHMENT 1
POSTMASTERS AT:
Montgomery, AL 36119-9998 Minneapolis, MN 55401-9998
Tucson, AZ 85726-9998 Cambridge, MA 02139-9998
Beverly Hills, CA 90210-9998 Iselin, NJ 08830-9998
San Francisco, CA 94188-999 Brooklyn, NY 11256-9998
Boulder, CO 80302-9998 Charlotte, NC 28228-9998
Fort Lauderdale, FL 33310-9998 Portland, OR 97208-9998
Atlanta, GA 30304-9998 Pittsburgh, PA 15290-9998
Chicago, IL 60607-9998 Colubmia, SC 29292-9998
Indianapolis, IN 46206-9998 Nashville, TN 37229-9998
Cedar Rapids, IA 52401-9998 Dallas, TX 75260-9998
Lexington, KY 40511-9998 Richmond, VA 23232-9998
Baton Rouge, LA 70821-9998 Seattle, WA 98109
Baltimore, MD 21233-9998 Milwaukee, WI 53203-9998
Dearborn, MI 48120-9998