United States Postal Service(TM)

In the Matter of the 			)  October 13, 1998
Complainant Against			)
					)
WINNERS LIST COMMISSION			)
					)
	at				)
					)
8726 Barnard Street			)
PO Box 95041 Stn South Del Ctr		)
Vancouver BC V6P 6W8			)
CANADA					)  P. S. Docket No. FOR 98-340

APPEARANCE FOR RESPONDENT:		Amada Corry
					P.O. Box 94668 Stn. Main
					7680 River Road
					Richmond, BC V6Y 4A4 Canada

APPEARANCE FOR COMPLAINANT:		Janessa Grady, Esq.
					Consumer Protection Law
					United States Postal Service
					475 L'Enfant Plaza, SW, Room 6333
					Washington,  DC  20260-1127

POSTAL SERVICE DECISION

On July 14, 1998, Tentative Decision and Order No. 98-82 was issued, which concluded that in accordance with 39 C.F.R. §952.7(), the orders authorized by 39 U.S.C. §3005(a) should be issued against Respondent. Accompanying the Tentative Decision and Order was a "Notice of Tentative Decision and Order" which advised Respondent that unless it presented good cause for dismissing the Complaint within 45 days of the date of the Tentative Decision, the Tentative Decision and Order would become final. On August 21, 1998, Respondent filed a timely reply in which it contends that it does not sell lottery tickets, but instead, it offers for sale lists of lucky number.

Respondent has not shown good cause for dismissing the Complaint. Although Respondent states that its solicitation is an offer to purchase list of lucky numbers, the language of the solicitation does not convey that message to the addressee. Respondent's mailing must be considered as a whole and its meaning determined in the light of its probable impact on the mind of the ordinary reader.1/ The language and format of the solicitation clearly create the impression that the fee to be remitted entitles the recipient to participate in a lottery enterprise.2/

Moreover, even though Respondent may not actually offer the addressee the opportunity to purchase a lottery ticket, its sale of numbers to be used in a lottery evidences Respondent's intimate involvement in a scheme for the distribution of money by lottery, and thus under the plain meaning of 39 U.S.C. §3005, Respondent is "engaged in conducting a lottery, gift enterprise, or scheme for the distribution of money . . .by lottery, chance, or drawing of any kind. . . ."3/

Accordingly, pursuant to 39 C.F.R. §952.7(b), Tentative Decision and Order No. 98-82 is now the Final Decision and Order of the Postal Service.

					James A. Cohen
					Judicial Officer

1 Donald v. Read Magazine, Inc., 333 U.S. 178, 188 (1948); Peak Laboratories, Inc. v. United States Postal Service, 556 F.2d 1387, 1389 (5th Cir. 1977); Charles Smith, P.S. Docket No. 36/129 (P.S.D. Dec. 9, 1993) AT 7. 39 U.S.C. §3005 is intended to protect not only the sophisticated and wary reader but also the gullible, naive, and less critical reader. Lee Deboub, P.S. Docket No. 19/185 (P.S.D. July 10, 1986) at 9.
2 Fulfillment and Processing Center, P.S. Docket No. FOR 96-202 (P.S.D. Aug. 30, 1996 at 2; I.A.C., P.S. Docket No. FOR 96-192 (P.S.D. Aug, 1996) at 2; BLC Services, Inc. d/b/a Registry Bureau, P.S. Docket No. FOR 96-95 (Final Decision and Order May 17, 1996) at 2.
3 Fulfillment and Processing Center, P.S. Docket No. FOR 99-202 (P.S.D. Aug. 30, 1996( at 3; I.A.C., P.S. Docket No. FOR 96-192 (P.S.D. Aug. 30, 1996) at 3.