Facts: Lottery Commission issues a letter to licensees saying that 8-liners are illegal gambling devices and will be enforced as such 2. Legal Issue: Brinkley says that the Commission's interpretation and policy of enforcement is a rule that is invalid because it was not adopted pursuant to the APA rule-making provisions 3. Ruling: Letter and policy is not a rule, at least not until it is enforced by Commission 4. Reasoning: It only applies to internal management of the agency (how its staff is to look at something and conduct investigations) until it actually is applied to a particular person