HQ 960866

July 15, 1999

CLA‑2 RR:CR:TE 960866 SG

CATEGORY: Classification

TARIFF NO: 6105.10.0010; 6103.42.1020; 6103.42.1050

Port Director

200 East Bay Street

Charleston, South Carolina 29401

RE: Protest No 1601-97-100043; Classification of men's garments;
sleepwear vs. loungewear

Dear Sir:

This is in response to the request for further review of Protest No.
1601-97-100043 timely filed on February 19, 1997, by Host Apparel, Inc.
concerning the proper classification of various styles of men's knit
garments which were imported from Turkey through the Port of Charleston.
The protest involves 3 entries covering 51 styles of knit shirts, shorts
and pants which were classified when entered on August 28, 1996, October
16, 1996, and October 17, 1996, as pants in subheading 6103.42.1020,
Harmonized Tariff Schedule of the United States Annotated (HTSUSA), as
shorts in subheading 6103.42.1050 HTSUSA, and as knit shirts in
subheading 6105.10.0010, HTSUSA. The importer has protested the
classification and claims the proper classification of these garments is
as sleepwear under subheading 6107.91.0030, HTSUSA or as other garments
in subheading 6114.20.0005, HTSUSA.

FACTS:

Twenty-five samples were submitted along with style sheets. Also
submitted was a summary sheet which Customs requested in an effort to
clarify the style numbers of the protested garments. We have used this
summary sheet to identify the styles protested on each entry. Since the
last three digits of the style number refer solely to the color of the
garment, we have omitted these three digits from the style numbers used
herein. In so doing the number of styles we need to specifically address
has been reduced, as the rest will be classified similarly.

The styles involved in the above protest are listed below and are
grouped as shirts, pants or shorts.

2

**SHIRTS:**

\*Style F238 is a men\'s shirt constructed from 100 percent cotton,
waffle knit fabric which measures more than 10 stitches per linear
centimeter counted in both the horizontal and vertical directions. The
garment has a Henley neckline; a three button, partial front opening;
long sleeves with rib knit cuffs; a sweat patch at the rear neckline;
and a hemmed bottom.

\*Style F242 (same as Style F334) is a men\'s shirt constructed from 100
percent cotton, double knit fabric which measures more than 10 stitches
per linear centimeter counted in both the horizontal and vertical
directions. The garment has a Henley neckline; a five button, partial
front opening; long sleeves with rib knit cuffs; and a hemmed bottom.

\* Style F249 - neither a sample nor a sketch were found.

\*Style F250 (same as Style F325) is a men\'s shirt constructed from 100
percent cotton, all-over screen printed jersey knit fabric which
measures more than 10 stitches per linear centimeter counted in both the
horizontal and vertical directions. The garment has a Henley neckline; a
three button, partial front opening; long sleeves with rib knit cuffs; a
sweat patch at the rear neckline; and a hemmed bottom.

\*Style F323 is a men\'s shirt constructed from 100 percent cotton,
all-over screen printed jersey knit fabric which measures more than 10
stitches per linear centimeter counted in both the horizontal and
vertical directions. The garment has a Henley neckline; a three button,
partial front opening; long sleeves with rib knit cuffs; a sweat patch
at the rear neckline; and a hemmed bottom.

\*Style F325 is a men\'s shirt constructed from 100 percent cotton,
all-over screen printed jersey knit fabric which measures more than 10
stitches per linear centimeter counted in both the horizontal and
vertical directions. The garment has a Henley neckline; a three button,
partial front opening; long sleeves with rib knit cuffs; a sweat patch
at the rear neckline; and a hemmed bottom.

\*Style F327 is a men\'s shirt constructed from 100 percent cotton,
jersey knit fabric which measures more than 10 stitches per linear
centimeter counted in both the horizontal and vertical directions. The
garment has a Henley neckline; a three button, partial front opening;
long sleeves with rib knit cuffs; a sweat patch at the rear neckline;
and a hemmed bottom.

\*Style F334 is a men\'s shirt constructed from 100 percent cotton,
double knit fabric which measures more than 10 stitches per linear
centimeter counted in both the horizontal and vertical directions. The
garment has a Henley neckline; a five button, partial front opening;
long sleeves with rib knit cuffs; and a hemmed bottom.

3

\*Style F351 is a men\'s shirt constructed from 100 percent cotton,
jersey knit fabric which measures more than 10 stitches per linear
centimeter counted in both the horizontal and vertical directions. The
garment has a Henley neckline; a three button, partial front opening;
long sleeves with rib knit cuffs; a sweat patch at the rear neckline;
and a hemmed bottom.

\*Style F352 is a men\'s shirt constructed from 100 percent cotton,
all-over screen printed jersey knit fabric which measures more than 10
stitches per linear centimeter counted in both the horizontal and
vertical directions. The garment has a Henley neckline; a three button,
partial front opening; long sleeves with rib knit cuffs; a sweat patch
at the rear neckline; and a hemmed bottom.

\* Style F363 is a men\'s shirt constructed from 100 percent cotton,
waffle knit fabric which has more than 10 stitches per linear centimeter
counted in both the horizontal and vertical directions. The garment has
a Henley neckline; a three button, partial front opening; long sleeves
with rib knit cuffs; a sweat patch at the rear neckline; and a hemmed
bottom.

\*Style F368 is a men\'s shirt constructed from 100 percent cotton,
waffle knit fabric which measures more than 10 stitches per linear
centimeter counted in both the horizontal and vertical directions. The
garment has a mock turtleneck neckline; a partial front, zippered
opening; long sleeves with rib knit cuffs; a sweat patch at the rear
neckline; and a hemmed bottom.

**PANTS:**

\*Style F227 (same as Style F358) is a men\'s pair of pants constructed
from 100 percent cotton, waffle knit fabric. The garment has no fly and
features a covered elastic waistband with an outside drawstring; side
seam pockets; and covered elastic at the ankles.

\*Style F245 (same as Style F309) is a men\'s pair of pants constructed
from 100 percent cotton, double knit fabric. The garment has no fly and
features a covered elastic waistband with an outside drawstring; side
seam pockets; and covered elastic at the ankles.

\*Style F247 (same as Style F309) is a men\'s pair of pants constructed
from 100 percent cotton, jersey knit fabric. The garment has no fly and
features a covered elastic waistband with an outside drawstring; side
seam pockets; and covered elastic at the ankles.

\* Style F248 is a men\'s pair of pants constructed from 100 percent
cotton, all-over screen printed, jersey knit fabric. The garment has no
fly and features a covered elastic waist­band with an outside drawstring;
side seam pockets; and covered elastic at the ankles.

\*Style F309 is a men\'s pair of pants constructed from 100 percent
cotton, jersey knit fabric. The garment has no fly and features a
covered elastic waistband with an outside drawstring; side seam pockets;
and covered elastic at the ankles.

4

\*Style F328 is a men\'s pair of pants constructed from 100 percent
cotton, all-over screen printed, jersey knit fabric. The garment has no
fly and features a covered elastic waistband with an outside drawstring;
side seam pockets; and covered elastic at the ankles.

\*Style F349 is a men\'s pair of pants constructed from 100 percent
cotton, all-over screen printed, jersey knit fabric. The garment has no
fly and features a covered elastic waistband with an outside drawstring;
side seam pockets; and covered elastic at the ankles.

\*Style F358 is a men\'s pair of pants constructed from 100 percent
cotton, waffle knit fabric. The garment has no fly and features a
covered elastic waistband with an outside drawstring; side seam pockets;
and covered elastic at the ankles.

\* Style F381 is a men\'s pair of pants constructed from 100 percent
cotton, all-over screen printed, jersey knit fabric. The garment has no
fly and features a covered elastic waist­band with an outside drawstring;
side seam pockets; and covered elastic at the ankles.

\*Style FTO4399 (same as Style F328 in tall sizes) is a men\'s pair of
pants constructed from 100 percent cotton, all-over screen printed,
jersey knit fabric. The garment has no fly and features a covered
elastic waistband with an outside drawstring; side seam pockets; and
covered elastic at the ankles.

\*Style FXO4399 (same as Style F328 in large sizes) is a men\'s pair of
pants constructed from 100 percent cotton, all-over screen printed,
jersey knit fabric. The garment has no fly and features a covered
elastic waistband with an outside drawstring; side seam pockets; and
covered elastic at the ankles.

**SHORTS:**

\*Style F239 (same as Style F360) is a pair of men\'s shorts constructed
from 100 percent cotton, waffle knit fabric. The garment has no fly and
features a covered elastic waistband with an outside drawstring; a rear
patch pocket; and hemmed leg openings.

\*Style F244 (same as Style F333) is a pair of men\'s shorts constructed
from 100 percent cotton, double knit fabric. The garment has no fly and
features a covered elastic waistband with an outside drawstring; a rear
patch pocket; and hemmed leg openings.

\*Style F320 is a pair of men\'s shorts constructed from 100 percent
cotton, all-over screen printed, jersey knit fabric. The garment has no
fly and features a covered elastic waistband with an outside drawstring;
a rear patch pocket; and hemmed leg openings.

5

\*Style F321 (same as Style F320) is a pair of men\'s shorts constructed
from 100 percent cotton, all-over screen printed, jersey knit fabric.
The garment has no fly and features a covered elastic waistband with an
outside drawstring; a rear patch pocket; and hemmed leg openings.

\*Style F350 is a pair of men\'s shorts constructed from 100 percent
cotton, all-over screen printed, jersey knit fabric. The garment has no
fly and features a covered elastic waistband with an outside drawstring;
a rear patch pocket; and hemmed leg openings.

\* Style F360 is a pair of men\'s shorts constructed from 100 percent
cotton, waffle knit fabric. The garment has no fly and features a
covered elastic waistband with an outside drawstring; a rear patch
pocket; and hemmed leg openings.

The pants were classified in subheading 6103.42.1020, HTSUSA, dutiable
at the rate of 16.9 percent ad valorem and subject to textile category
347. The shorts were classified in subheading 6103.42.1050, HTSUSA,
dutiable at the rate of 16.9 percent ad valorem and subject to textile
category 347. The shirts were classified in subheading 6105.10.0010,
HTSUSA, dutiable at the rate of 20.7 percent ad valorem and subject to
textile category 338.

The importer is of the opinion that the merchandise should be properly
classified in subheading 6107.91.0030, dutiable at 9.2 percent ad
valorem and subject to textile category 351.

ISSUE:

Whether the subject merchandise is properly classifiable as sleepwear
under Heading 6107, HTSUS, or as outerwear garments under heading 6103,
HTSUS and 6105, HTSUS, as appropriate?

LAW AND ANALYSIS:

Classification of goods under the HTSUS is governed by the General Rules
of Interpretation (GRI\'s). GRI 1 provides that classification shall be
determined according to the

terms of the headings and any relative section or chapter notes.
Merchandise that cannot be

classified in accordance with GRI 1 is to be classified in accordance
with subsequent GRI\'s taken in order.

Heading 6107, HTSUS, provides for, *inter alia*, men's nightshirts,
pajamas and similar articles. Customs has consistently ruled that
pajamas are generally two‑piece garments worn for sleeping. One‑piece
garments are not classifiable as pajamas. Sleep shorts and sleep pants
used for sleeping fall into a residual provision within heading 6107,
HTSUS, for similar articles.

If it is determined that the subject bottoms and tops are classifiable
as outerwear or

loungewear, the applicable heading for the bottoms is heading 6103,
HTSUS, which provides for,

6

*inter alia*, men's trousers and shorts; and, for the tops, heading
6105, HTSUS, which provides for men's shirts.

In determining the classification of garments submitted to be sleepwear,
Customs usually considers the factors discussed in two court cases that
addressed sleepwear. In [Mast Industries,]{.underline}

[Inc. v. United States]{.underline}, 9 CIT 549, 552 (1985), aff'd 786
F.2d 144 (CAFC, 1986), the Court of

International Trade considered the classification of a garment claimed
to be sleepwear. The court cited several lexicographic sources, among
them [Webster's Third New International Dictionary]{.underline} which
defined "nightclothes" as "garments to be worn to bed." In
[Mast]{.underline}, the court determined that the garment at issue
therein was designed, manufactured, and used as nightwear and therefore
was classifiable as nightwear. Similarly, in [St. Eve International,
Inc. v. United States]{.underline}, 11 CIT

224 (1987), the court ruled the garments at issue therein were
manufactured, marketed and

advertised as nightwear and were chiefly used as nightwear. Finally, in
[Inner Secrets/Secretly Yours, Inc. v. United States]{.underline}, 885
F. Supp. 248 (1995), the court was faced with the issue of

whether women's boxer‑style shorts were classifiable as "outerwear"
under heading 6204,

HTSUS, or as "underwear" under heading 6208, HTSUS. The court stated the
following, in pertinent part:

\[P\]laintiff's preferred classification is supported by evidence that
the boxers in issue were designed to be worn as underwear and that such
use is practical. In addition, plaintiff showed that the intimate
apparel industry perceives and merchandises the boxers as underwear.
While not dispositive, the manner in which plaintiff's garments are
merchandised sheds light on what the industry perceives the merchandise
to be.\*\*\*

Further, evidence was provided that plaintiff's merchandise is marketed
as underwear.

While advertisements also are not dispositive as to correct
classification under the

HTSUS, they are probative of the way that the importer viewed the
merchandise

and of the market the importer was trying to reach.

Furthermore, we bring your attention to [International Home Textile,
Inc]{.underline}., Slip Op. 97-31, March 18, 1997, which classified
garments similar to those at issue here as loungewear in heading 6103,
HTSUS. The court therein stated:

Based upon a careful examination of the loungewear as well as the
testimony of the various witnesses, the court finds that the loungewear
items at issue do not share that essential character of privateness or
private activity. As the parties have already stipulated, the loungewear
is used primarily for lounging and not for sleeping. The court

finds no basis in the exhibits, the witness testimony, or the
loungewear's construction and design to find that it is inappropriate,
at a minimum, for the loungewear to be worn at

informal social occasions in and around the home, and for other
individual, non‑private activities in and around the house e.g.,
watching movies at home with guests, barbequing

at a backyard gathering, doing outside home and yard maintenance work,
washing the car,

walking the dog, and the like\....

7

In past rulings, Customs has stated that the crucial factor in the
classification of a garment

is the garment itself. As the court pointed out in [Mast,]{.underline}
\"the merchandise itself may be strong

evidence of use.\" [Mast]{.underline} at 552, citing [United States v.
Bruce Duncan Co.]{.underline}, 50 CCPA 43, 46,

C.A.D. 817 (1963). However, when presented with a garment which is
somewhat ambiguous and not clearly recognizable as sleepwear or
underwear or outerwear, Customs will consider other factors such as
environment of sale, advertising and marketing, recognition in the trade
of virtually identical merchandise, and documentation incidental to the
purchase and sale of the merchandise, such as purchase orders, invoices,
and other internal documentation. It should be noted that Customs
considers these factors in totality and no single factor is
determinative of classification as each of these factors viewed alone
may be flawed. For instance, Customs recognizes that internal
documentation and descriptions on invoices may be self‑serving as was
noted by the court in [Regaliti, Inc. v. United States,]{.underline} 16
C.I.T. 407 (May 21, 1992). We have long acknowledged that intimate
apparel/sleepwear departments often sell a variety of merchandise
besides intimate apparel, including garments intended to be worn as
outerwear. See HQ 955341 of May 12, 1994.

Counsel indicates that the importer, Host Apparel, Inc., is a
sleeepwear/underwear company and that Host's garments are sold
throughout the country to underwear and sleepwear departments, and not
to sportswear departments or specialty shops. Counsel argues the
garments are sold and used as sleepwear and loungewear, i.e., for use in
the privacy of one's home. It is Host's position that the garments are
of a thin, cotton, clinging, jersey fabric and are not outerwear.

Customs does not find the fact that the garments at issue here are sold
by Host Apparel to underwear and sleepwear departments of particular
significance. What we do find of importance is the garments themselves
and the manner in which the garments will be presented to the public.

In HQ 960432 dated August 22, 1997, we stated:

> \*\*\*With respect to the bottoms that will feature no fly and side
> seam pockets, it is the opinion of this office that bottoms with the
> combination of those two features are not indicative of a sleepwear
> bottom but a multi-purpose garment that may (and probably will) be
> worn for purposes other than sleeping. These bottoms can easily make
> the transition from inside the home (a private setting) to outside the
> home ( and a more social environment). The lack of fly makes them
> suitable for modesty purposes and the presence of pockets makes them
> suitable for modesty purposes and the presence of pockets makes them a
> comfortable and useful outerwear garment to carry keys, money,
> identification and similar small objects. Additionally, even for those
> garments that lack both the fly and the side seam pockets, we find the
> absence of the fly on these bottoms indicative of a multi- purpose
> garment.

In the instant case, a physical examination of the bottoms at issue
reveals several features which make them suitable for modesty purposes.
The pants have side seam pockets and elastic at

8

the ankle; the shorts have rear patch pockets hemmed leg bottoms; and
both the shorts and pants have no fly openings. Additionally, even if
the bottoms were to lack both the fly and the side seam pockets, the
absence of the fly on the bottoms is not a useful feature on sleepwear,
but on loungewear or a multipurpose garment it serves to ensure modesty.
This, as well as the other features listed above are not indicative of
sleepwear, but of multi‑purpose garments that may (and probably will) be
principally worn for the type of non-private activities named in
[International Home Textiles, Inc.]{.underline}

Examination finds that the garments bear the distinctive blue and white
"Bottoms Out" brand name label in the inside rear waistband. In the
[Daily News Record]{.underline} of March 26, 1996, Host apparel was
featured in an article on the sleepwear/loungewear trade. In the
article, Host's house brands were said to include "\...Bottoms Out for
boxers and loungewear,\...". The article pointed

out that the company foresaw "loungewear growing from 10 percent to the
mid to upper teens by 1998. One key growth vehicle is the Bottoms Out
brand." The article quoted Host's president as saying "We've had an
explosive growth in boxers and loungewear". In the [Daily News
Record]{.underline} of August 28, 1995, an article on the expanding
loungewear trade states that these "\...products can be worn for play,
sleep, or just hanging around." A review of the twelve style sheets
submitted by the importer reveals none of the garments is identified as
sleepwear. Rather, through nautical (Newport), retro (Twenties
Flashback), and various other themes (Cabin Fever, Mixed Company), the
impression is that the garments are designed for multi-purpose use
whether it is sleeping, lounging, exercising, or casual at-home wear.

Although the garments may be worn to bed for sleeping, it is our opinion
that their principal use is for "home comfort" and lounging. These
garments can easily make the transition from inside the home (in a
private setting) to outside the home (and a more social environment). In
[Hampco Apparel, Inc. v. United States,]{.underline} 12 CIT 92 (1988),
the Court of International Trade stated: "The fact that a garment could
have a fugitive use or uses does not take it out of the classification
of its original and primary use. The primary design, construction, and
function of an article will be determinative of classification, whether
or not there is an incidental or subordinate function."

Style F248 has a size and price hang tag which identifies the garment as
a lounge pant. In [Mast,]{.underline} 92 C.I.T. 549, at 551, the court
pointed out that the expert witnesses in that case agreed

\"that most consumers purchase and use a garment in the manner in which
it is marketed.\" The tag is a factor to be considered in determining
how this garment is marketed and likely to be used by purchasers, though
it is not determinative in and of itself.

We also note the manufacturers invoices identify the garments as Henley
shirts, lounge pants or jam shorts.

9

In addition, all the samples submitted are made of fabric heavy enough
for outdoor use even in cool weather.

In our view, these garments are clearly being presented as loungewear
garments for wear other than for the primary purpose of wearing to bed
for sleeping. They are presented as multi‑purpose garments and, in fact,
nothing provided suggests the garments are designed or intended for wear
while sleeping. Thus, Customs does not agree that these garments are
presented to consumers as sleepwear garments; they are held out as
casual loungewear for all day wear if desired.

The importer has provided no advertising showing these garments as
sleepwear, nor are the garments identified anywhere on the invoices as
sleepwear. The garments are more likely to give the ultimate consumer
the idea that they are items of general apparel, rather than sleepwear.

The Customs National Import Specialist for this merchandise provided us
with numerous advertising materials which demonstrate that the trend
today for the type of garments in question is for mix and match
loungewear as shown by the following sampling of the articles we
received. For example, in a number of *J.C. Penny* Catalogs, garments
are advertised as cotton and polyester thermal knit loungewear
consisting of a Henley style top trimmed with plaid flannel, long pants
with no fly and jam shorts with plaid flannel trim on the waistband.
These garments are almost identical in styling and fabric to Sample F358
and Sample F360. The garments are sold and priced separately to be used
as mix and match loungewear coordinates. A September 1996 *Kohl's*
advertisement featured a Henley style top and a pair of pants with plaid
trim on the shirt placket and waistband advertised as loungewear. The
advertising copy reads "Ideal casual wear to get comfy in!" Pajamas were
advertised separately. In an August 1996 *Target* advertisement, a
Henley top or V‑notch Tee, shorts and pants are advertised as mix and
match loungewear coordinates. A summer 1996 *Marshall Field*
advertisement shows college logo loungewear, including a thermal knit
boxer with exposed elastic waistband and thermal knit Henley style
shirt, sold as loungewear separates.

An articles on the underwear/loungewear trade in the *Daily News
Record*, of October 14, 1994, noted the trend towards
underwear/loungewear as activewear and gymwear. The article states that:

Manufacturers that are adopting a sportswear-driven approach to
underwear and loungewear are expected to ring up big business for spring
'95, as versatile briefs, boxers, T-shirts, lounge tops and longer,
looser lounge pants fuel the furnishings field\...underwear and
loungewear can double as activewear/gymwear\...Knit bottoms are now
being worn externally\...because they offer much more versatility and
have a dual purpose\...Loungewear is not just homewear anymore.

In discussing how loungewear is promoted and displayed at the retail
level, the article continued:

10

The loungewear area is made up of coordinated separates\...The whole
concept is towards coordinated separates that are\...sold as separates
to give the consumer the option to mix and match. Lounge pieces and
coordinated separates have a much more diverse usage factor.

An article supplied by the NIS from the *Daily News Record*, dated
August 28, 1995, on loungewear reads:

Loungewear is changing the way men dress at home, after work and on the
weekends. Here SLOUCHERS by HAMPTON INDUSTRIES' version of what to wear
after‑hours ‑ a natural and navy striped cotton pique cross‑tie lounge
shirt and natural cotton pique lounge shorts.

Based on our examination of the garments supplied, we find that they are
loungewear, i.e., loose, casual clothes that are worn in the home for
comfort. Their fabric, construction and design are suitable for the type
of nonprivate activities named in [International Home Textile,
Inc]{.underline}. Finally, although the garments may be worn to bed for
sleeping, in our opinion their principal use is for "home comfort" and
lounging.

Taking into consideration all of the information before us, especially
the garments themselves and the marketing and advertising, Customs
believes these garments are properly

classified as loungewear garments, not as sleepwear.

HOLDING:

The knit pants with no fly opening, side seam pockets, and elastic
hemmed leg bottoms are classified in subheading 6103.42.1020, HTSUSA,
which provides for "Men's or boys' suits, ensembles, suit-type jackets,
blazers, trousers, bib and brace overalls, breeches and shorts (other

than swimwear): Trousers, bib and brace overalls, breeches and shorts:
Of cotton: Trousers, breeches, and shorts: Trousers and breeches:
Men's." The applicable 1996 general column one rate of duty is 16.9
percent ad valorem and the textile quota category is 347.

The jams are classified as men's knit cotton shorts in subheading
6103.42.1050, HTSUSA, which provides for "Men's or boys' suits,
ensembles, suit-type jackets, blazers, trousers, bib and brace overalls,
breeches and shorts (other than swimwear): Trousers, bib and

brace overalls, breeches and shorts: Of cotton: Trousers, breeches and
shorts: Shorts: Men's." The applicable 1996 general column one rate of
duty is 16.9 percent ad valorem and the textile quota category is 347.

The Henley shirts with button plackets ( Styles F238, F242, F249, F250,
F323, F325, F327, F334, F351, F352, and F363) and the shirt with the
zippered neck opening (Style F368) are classified under subheading
6105.10.0010, HTSUSA, which provides for "Men's or boys' shirts,

11

knitted or crocheted: Of cotton: Men's." The 1996 general column one
duty rate is 20.7 percent ad valorem. The textile quota category is 338.

The protest under consideration should be DENIED.

In accordance with Section 3A (11) (b) of Customs Directive 0993550‑065,
dated August 4, 1993, Subject: Revised Protest Directive, you are to
mail this decision, together with the Customs Form 19, to the protestant
no later than 60 days from the date of this letter. Any reliquidation of
the entry in accordance with the decision must be accomplished prior to
mailing the decision.

Sixty days from the date of the decision, the Office of Regulations and
Rulings will make this decision available to Customs personnel, the
public on the Customs Home page on the World Wide Web at
www.customs.ustreas.gov, by means of the Freedom of Information Act and
other methods of public distribution.

Sincerely,

John Durant, Director

Commercial Rulings Division