Second Class

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602 S. Gay Street
2nd Floor
Knoxville, TN 37902

The statement by Frank Cagle in the May 5, 2011 issue of the Metro Pulse concerning the requirements to obtain a second-class postal mailing permit is not entirely accurate. [“You’re on Notice,” Frank Talk] I used to be the publisher/owner of a weekly newspaper and the 50 percent of circulation requirement can be met by not only paid subscribers but also by people who have requested a free subscription. The following is a verbatim quote from the regulations:

“A second-class mailing permit requires that 50 percent of the circulation file be made up of paid or requestor copies. As long as the issue analyzed meets these final criteria and after all non-qualifying circulation is filtered out, the publication qualifies for a second-class mailing permit.”

Joe McCulley


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