Univ.° 52 113 ^ r, X JL 11. Library UNITED STATES POST OFFICE DEPARTMENT OFFICE OF THE SOLICITOR Oak Street UNCLASSIFIED Restrictions on Transportation of Letters The Private Express Statutes and Interpretations (Fourth Edition) JANUARY 1952 + HON. JESSE M. DONALDSON, Postmaster General UNITED STATES GOVERNMENT PRINTING OFFICE WASHINGTON : 1952 For sale by the Superintendent of Documents, Washington 25, D. C. Price 10 cents FOREWORD This pamphlet is the fourth edition of the compilation of the statutes restricting the transportation of letters and the interpreta¬ tions placed thereon by the Post Office Department. The first three editions were entitled “The Private Express Statutes.” A new title lias been used for this fourth edition in order to describe more accu¬ rately the enlarged contents of the publication. This pamphlet was compiled and edited by Adam G. Wenchel, Chief of the Opinions Section, Office of the Solicitor for the Post Office Department. The Private Express Statutes take their name from Title 18, United States Code, § 1696, and its predecessors which have, since the days of the Articles of Confederation, prohibited the establishment of a “private express for the conveyance of letters or packets.” Title 18, United States Code, § 1696, and the other laws discussed in this pamphlet, known collectively as The Private Express Statutes, were enacted by Congress under the authority of Article I, section 8, of the Constitution and vest in the Post Office Department a monopoly over the transportation of letters for others by regular trips or at stated periods over all post routes. The primary purpose of these laws is to safeguard the revenues of the Government derived from the transportation and delivery of letters for others by prohibiting com¬ petition with the Post Office Department in the carriage of letters by persons seeking to engage in the delivery of letters for compensation. Part I of this pamphlet contains the laws enacted by Congress. Part II discusses the application of these laws and serves to indicate the controlling principles followed by the Department in its consid¬ eration of problems relating to the interpretation and enforcement of these laws. Roy C. Fkank, Solicitor . n 7 TABLE OF CONTENTS Foreword___ Part I. Extracts from the United States Code_ Title 18, United States Code_ § 1693. Carriage of mail generally_____ § 1694. Carriage of matter out of mail over post routes__ § 1695. Carriage of matter out of mail on vessels_ § 1696. Private express for letters and packets_ § 1697. Transportation of persons acting as private express_ § 1698. Prompt delivery of mail from vessel_ § 1699. Certification of delivery from vessel_ Title 39, United States Code__ § 496. Carrying foreign letters_ § 497. Searching vessels for letters_ § 498. Seizing and detaining letters__ § 499. Disposition of seizures___'I_ § 500. Letters carried out of mail_ § 700. Searches authorized___ Part II. Interpretations_,_ A. General Statement___ Sec. 1. In General_ B. Matter Subject to the Monopoly_ Sec. 2. Letters and Packets_:__ Sec. 3. Letters in General__ Sec. 4. Samples of Letters__ (a) Orders_:__ (b) Bills and Statements of Accounts.. _ (c) Reports__ (d) Applications___ Sec. 5. Samples of Matter Not “Letters”___ Sec. 6 Inter-Office Communications__ o Sec. 7. Checks and Drafts_ . Sec. 8. Matter Sent for Auditing or Preparation of Bills_ Sec. 9. Information Known to Addressee_ Sec. 10. Old Correspondence and Other Matter Sent for Filing, Storage, or Destruction__ Sec. 11. Examination Papers____ Sec. 12. Manuscript and News Items_ Sec. 13. Weight and Size_ C. Prohibited Transportation_ Sec. 14. Post Routes_ Sec. 15. Activities Prohibited_ Page in 1 1 1 1 2 2 3 3 3 4 4 4 4 4 5 5 7 7 7 7 7 7 8 8 9 9 9 10 11 12 12 13 13 14 14 14 15 15 16 hi IV TABLE OF CONTENTS Part II. Interpretation — Continued Page D. Permissible Carriage of Letters_ 16 Sec. 16. Delivery by Employees; “Current Business”_ 16 Sec. 17. Relating Exclusively to Accompanying Shipment_ 18 Sec. 18. Private Hands Without Compensation_ 19 Sec. 19. Special Messengers Employed for the Particular Oc¬ casion Only_ 19 Sec. 20. Letters on Which Postage Is Paid_ 20 Sec. 21. Delivery to Post Office_ 21 Sec. 22. After Receipt From the Post Office_ 21 Sec. 23. Receipts for Goods Delivered, and Deliveries in Con¬ junction With Collections_ 22 E. Miscellaneous Problems Related to The Private Express Statutes, Sec. 24. Drop Letters_ 22 Sec. 25. Mailing of Letters of Two or More Persons in One Envelope__ 23 Sec. 26. Restricted Use of Private Letter Boxes_ 24 Sec. 27. Rates of Postage on Mail Matter_ 24 Sec. 28. Reports of Postmasters; Inquiries_ 25 Index_ 2 Part I. EXTRACTS FROM THE UNITED STATES CODE TITLE 18 § 1693. Carriage of mail generally. Whoever, being concerned in carrying the mail, collects, receives, or carries any letter or packet, contrary to law, shall be fined not more than $50 or imprisoned not more than thirty days, or both. Note. —This section is set out as § 91.7, Postal Laws and Regulations of 1948. § 1694. Carriage of matter out of mail over post routes. Whoever, having charge or control of any conveyance operating by land, air, or water, which regularly performs trips at stated periods on any post route, or from one place to another between which the mail is regularly carried, carries, otherwise than in the mail, any letters or packets, except such as relate to some part of the cargo of such convey¬ ance, or to the current business of the carrier, or to some article carried at the same time by the same conveyance, shall, except as otherwise provided by law, be fined not more than $50. Note. —This section is set out as paragraph (a) of § 91.6, Postal Laws and Regulations of 1948. Paragraphs (b) through (f) of that section of the Postal Laws and Regulations (39 CFR 91.6 (b)-(f)) are as follows : “(b) Letters which may he carried hy common carrier outside mails . A rail¬ road or steamboat company or other common carrier may carry outside of the mails letters written and sent by its officers and agents which relate to its business only, without inclosing the same in stamped envelopes. Such letters may be to other of such carriers’ officers and agents, to those of connecting lines, or to anyone else, so long as no other carrier intervenes. “(c) Letters for connecting line. Letters of a company or carrier addressed to officers or agents of a connecting line on business relating to such company or carrier and delivered to an agent of the latter at the point of connection may be carried, and such carriage continued by the connecting company or carrier. “(d) Letters for eating house. Letters written by a railroad company and addressed to the manager of an eating house operated by such company, or written by him and addressed to the company, may be carried. “(e) Letters which cannot he carried outside mails. No company or carrier, or any officer or employee thereof, may carry outside of the mails letters which are neither written by the company or carrier nor addressed to it. - The fact that letters relate to through business over the lines of all companies or carriers transporting the same shall not warrant a company in carrying such letters from one of its connecting lines to another. 1 2 RESTRICTIONS ON TRANSPORTATION OF LETTERS “(f) Right of individual railroads to carry letters outside mails is not extended to system. Where companies or corporations operating railroads are united as a system of railways, the right to carry letters outside of the mail without payment of postage shall remain as an appurtenant of the individual companies or corpora¬ tions composing the system, and shall not by reason of the union into a system become the right of the system.” § 1695. Carriage of matter out of mail on vessels. Whoever carries any letter or packet on board any vessel which car¬ ries the mail, otherwise than in such mail, shall, except as otherwise provided by law, be fined not more than $50 or imprisoned not more than thirty days, or both. Note. —This section is set out as §§ 91.10 and 125.6, Postal Laws and Regulations of 1948. § 1696. Private express for letters and packets. (a) Whoever establishes any private express for the conveyance of letters or packets, or in any manner causes or provides for the convey¬ ance of the same by regular trips or at stated periods over any post route which is or may be established by law, or from any city, town, or place to any other city, town, or place, between which the mail is regularly carried, shall be fined not more than $500 or imprisoned not more than six months, or both. This section shall not prohibit any person from receiving and de¬ livering to the nearest post office, postal car, or other authorized depository for mail matter any mail matter properly stamped. (b) Whoever transmits by private express or other unlawful means, or delivers to any agent thereof, or deposits at any appointed place, for the purpose of being so transmitted any letter or packet, shall be fined not more than $50. (c) This chapter shall not prohibit the conveyance or transmission of letters or packets by private hands without compensation, or by special messenger employed for the particular occasion only. When¬ ever more than twenty-five such letters or packets are conveyed or transmitted by such special messenger, the requirements of section 500 of Title 39 shall be observed as to each piece. Note.— Subsection (a) of this section is set out as paragraph (a) of § 91.1, Postal Laws and Regulations of 1948. Paragraph (b) of § 91.1 (39 CFR 91.1 (b)) is as follows : “(?>) Letters delivered to post offices in hulk for mailing. Postmasters may accept for mailing letters delivered to them in bulk by freight, express, mail, or messenger: provided that each of such letters bears the return card of a person or firm located within the delivery limits of their offices: and provided further, that each of such letters is duly directed and properly sealed and bears the proper postage, which should be purchased at the office of mailing.” RESTRICTIONS ON TRANSPORTATION QF LETTERS 3 Subsection (b) of Title 18, U. S. C., § 1696, is set out ns § 91.5, Postal Laws and Regulations of 1948. Subsection (c) is set out as § 91.2, Postal Laws and Regulations of 1948. § 1697. Transportation of persons acting as private express. Whoever, having charge or control of any conveyance operating by land, air, or water, knowingly conveys or knowingly permits the con¬ veyance of any person acting or employed as a private express for the conveyance of letters or packets, and actually in possession of the same for the purpose of conveying them contrary to law, shall be fined not more than $150. Note. —This section is set out as § 91.4, Postal Laws and Regulations of 1948. § 1698. Prompt delivery of mail from vessel. Whoever, having charge or control of any vessel passing between ports or places in the United States, and arriving at any such port or place where there is a post office, fails to deliver to the postmaster or at the post office, within three hours after his arrival, if in the daytime, and if at night, within two hours after the next sunrise, all letters and packages brought by him or within his power or control and not relating to the cargo, addressed to or destined for such port or place, shall be fined not more than $150. For each letter or package so delivered he shall receive two cents unless the same is carried under contract. Note.— This section is set out as § 97.54, Postal Laws and Regulations of 1948. § 1699. Certification of delivery from vessel. No vessel arriving within a port or collection district of the United States shall be allowed to make entry or break bulk until all letters on board are delivered to the nearest post office, and the master or other person having charge or control thereof has signed and sworn to the following declaration before the collector or other proper customs officer: I, A. B., master ____, of the___arriving from _and now lying in the port of __, do solemnly swear (or affirm) that I have to the best of my knowledge and belief delivered to the post office at___every letter and every bag, packet, or parcel of letters on board the said vessel during her last voyage, or in my possession or under my power or control. Whoever, being the master or other person having charge or control of such vessel, breaks bulk before he has delivered such letters, shall be fined not more than $100. Note, —This section is set out as § 125.4, Postal Laws and Regulations of 1948. 4 RESTRICTIONS ON TRANSPORTATION OF LETTERS TITLE 39 § 498. Carrying foreign letters. No vessel departing from the United States for any foreign port shall receive on board or convey any letter or packet originating in the United States which has not been regularly received from the post office at the port of departure, and which does not relate to the cargo of such vessel, except as provided in section 500 of this title; and every collector, or other officer of the port empowered to grant clearances, shall require from the master of such vessel, as a condition of clearance, an oath that he has not received on board, has not under his care or control, and will not receive or convey any letter or packet contrary to the provisions of this section. Note. —This section is set out as § 125.1, Postal Laws and Regulations of 1948. § 497. Searching vessels for letters. Any post-office inspector, when instructed by the Postmaster Gen¬ eral to make examinations and seizures, and the collector or other cus¬ toms officer of any port, without special instructions, shall carefully search all vessels for letters which may be on board or which have been conveyed contrary to law. Note. —This section is set out as § 91.13, Postal Laws and Regulations of 1948. § 498. Seizing and detaining letters. Any post-office inspector, collector, or other customs officer, or United States marshal or his deputy, may at all times seize all letters and bags, packets or parcels, containing letters which are being carried contrary to law on board any vessel or on any post route, and convey the same to the nearest post office, or may, by the direction of the Post¬ master General or Secretary of the Treasury, detain them until two months after the final determination of all suits and proceedings which may, at any time within six months after such seizure, be brought against any person for sending or carrying such letters. Note.— This section is set out as § 91.14, Postal Laws and Regulations of 1948. § 499. Disposition of seizures. Every package or parcel seized by any post-office inspector, collector, or other customs officer, or United States marshal or his deputies, in which any letter is unlawfully concealed, shall be forfeited to the United States, and the same proceedings may be had to enforce the forfeiture as are authorized in respect to goods, wares, and merchan¬ dise forfeited for violation of the revenue laws; and all laws for the benefit and protection of customs officers making seizures for violating revenue laws shall apply to officers making seizures for violating the postal laws. Note. —This section is set out as § 91.15, Postal Laws and Regulations of 1948. RESTRICTIONS ON TRANSPORTATION OF LETTERS 0 § 500. Letters carried out of mail. All letters enclosed in envelopes with embossed postage thereon, or with postage stamp or stamps affixed thereto, by the sender, or with the metered indicia showing that the postage has been prepaid, if the postage thereon is of an amount sufficient to cover the postage that would be chargeable thereon if the same were sent by mail, may be sent, conveyed, and delivered otherwise than by mail, provided such enve¬ lope shall be duly directed and properly sealed, so that the letter cannot be taken therefrom without defacing the envelope, and the date of the letter or of the transmission or receipt thereof shall be written or stamped upon the envelope, and that where stamps are affixed they be canceled with ink by the sender. But the Postmaster General may suspend the operation of this section or any part thereof upon any mail route where the public interest may require such suspension. Note. —This section is set out as § 91.3, Postal Laws and Regulations of 1948. § 700. Searches authorized. The Postmaster General may, by a letter of authorization under his hand, to be filed among the records of his department, empower any post-office inspector or other officer of the Post Office Establishment to make searches for mailable matter transported in violation of law; and the inspector or officer so authorized may open and search any car or vehicle passing, or having lately before passed, from any place at which there is a post office of the United States to any other such place, or any box, package, or packet, being, or having lately before been, in such car or vehicle, or any store or house, other than a dwell¬ ing house, used or occupied by any common carrier or transportation company, in which such box, package, or packet may be contained, whenever such inspector or officer has reason to believe that mailable matter, transported contrary to law, may therein be found. Note.— This section is set out as § 91.12, Postal Laws and Regulations of 1948. N 983091°—52 2 * Digitized by the Internet Archive , in 2019 with funding from University of Illinois Urbana-Champaign Alternates https://archive.org/details/restrictionsontrOOunit % Part II. INTERPRETATIONS A. GENERAL STATEMENT Sec. 1. In General. The intent of The Private Express Statutes 1 is to confer a monopoly, with stated exceptions, on the Post Office Department over the transportation of letters for others. This monopoly was created prior to the adoption of the Constitution and has existed with varying provisions continuously in the United States from that time to the present. 2 The types of matter which are sub¬ ject to the monopoly are discussed in sections 2 through 13 of this pamphlet. The types of transportation which are covered by the statutes are discussed in sections 14 and 15. Exceptions to the monopoly are discussed in sections 16 through 23. Sections 24 through 28 embrace miscellaneous problems related to The Private Express Statutes. 3 B. MATTER SUBJECT TO THE MONOPOLY Sec. 2. Letters and Packets. The Private Express Statutes, by their terms, apply both to letters and to packets. The word “packets” now has only historical significance. “Packet” as used in The Private Express Statutes means either a letter consisting of several sheets of paper or as two or more letters under one cover. As used in The Private Express Statutes, the word “packet” does not include a parcel or bundle of merchandise. For practical purposes, therefore, the Government monopoly may be said to extend only to “letters.” 4 Sec. 3. Letters in General. A “letter” is generally defined as a message in writing 5 6 and may be written in English, in a foreign 1 These and related statutes are found in Title 18, U. S. C., §§ 1693-99 and 1724 ; and in Title 39, U. S. C., §§ 496-500 and 700. 2 United States v. Kochersperger (1860), 26 Fed. Cas. 803 (Cas. No. 15,541), contains an excellent review of the history of postal monopolies. In that case the court said : “No government has ever organized a system of posts without securing to itself, to some extent, a monopoly of the carriage of letters and mailable packets.” 3 The Private Express Statutes are constitutional. United. States v. Hall (1844), 26 Fed. Cas. 75 (Cas. No. 15,281) ; United States v. Thompson (1846), 28 Fed. Cas. 97 (Cas. No. 16,489) ; and Ex parte Jackson (1877), 96 U. S. 727, 734. 4 Divight v. Brewster (1822), 18 Mass. (1 Pick.) 50; United States v. Chaloner (1831), 25 Fed. Cas. 392 (Cas. No. 14,777) ; Chouteau & Valle v. Steamboat St. Anthony (1847), 11 Mo. 226 ; and Williams v. Wells Fargo Express & Co. (1910), 177 Fed. 352, all hold only those packets containing letters to be “packets” as that word is used in these statutes. The legal officers of the Post Office Department have reached the same conclusion. See 5 Op. Asst. Atty. Gen. P. O. D. 77 ; 193 ; 614 ; and 620. 6 United States v. American Dealers Service, Inc. (1943), D. C. S. D. N. Y. (unreported), Civil 21-107. In United States v. Thompson (1846), 28 Fed. Cas. 97, 98 (Cas. No. 16,489), the court said : “The word ‘letter’ had no technical meaning, but must be understood in the sense in which it was generally understood among business men.’ 1 7 8 RESTRICTIONS ON TRANSPORTATION OF LETTERS language, or in a code. To be written it need not be in handwriting but may be written 6 by a system of checking from a list of printed statements, or punching holes, or by point print, or in raised characters used by the blind . 7 A letter may be in a sealed envelope, in an un¬ sealed envelope, or not in an envelope at all . 8 However, a writing is not a letter unless addressed to or intended for some particular person or concern. In addition to communications of a purely per¬ sonal nature, the word “letter” includes any matter conveying live, current information between the sender and the addressee. If the sender expects or intends the addressee to act, rely, or refrain from acting 9 on the information, the information is live and current. While a distinction is observed for other purposes between letters and circulars, the term “letters” under The Private Express Statutes may embrace circulars inasmuch as the term “circular” is defined to be a printed letter which, according to internal evidence, is being sent to several persons in identical terms . 10 A telegraphic message is not a “letter.” * 11 Sec. 4. Samples of Letters. It is obvious that all the forms which letters may take cannot be enumerated in this pamphlet. While sev¬ eral general classes of matter held to fall either within or without the category of “letters” as used in The Private Express Statutes are noted in this and succeeding paragraphs, the listing of samples does not com¬ prise, nor could any similar compilation pretend to comprise, every type of matter which would fall either within or without the scope of these statutes. The suggestion is made that, if there is doubt as to any proposed shipment, a specific ruling be sought from the Solicitor with respect to such matter. (a) Orders . Among merchants an order to a wholesale dealer for merchandise is a common subject of correspondence. It may be doubted whether any other subject can be named on which more letters are written and forwarded in the mails. Orders for merchandise to be filled by the recipient are letters for purposes of The Private Ex¬ press Statutes . 12 Orders are also “letters” when forwarded by a sales- c Printed matter, 6 Op. Sol. P. O. D. 397. 7 Punched tabulating cards, 7 Op. Sol. P. O. D. 622; 8 id. 382 (first opinion); 9 id. No. 474. Code, 9 id. No. 502. Sticker, 9 id. No. 504. 8 A paper folded in the form of a letter, United States v. Bromley (1851), 53 U. S. 87. 9 7 Op. Sol. P. O. D. 496, at 498. i° “The term ‘circular’ is defined to be a printed letter, which, according to internal evidence, is being sent in identical terms to several persons. A circular shall not lose its character as such, when the date and the name of the addressed and of the sender shall be written therein, nor by the correction of mere typographical errors in writing.” Title 39, U. S. C., sec. 236. 8 Op. Sol. P. O. D. 272. “A sealed cicular is, for all purposes affecting the postal offices, a letter.” The Louisiana Lottery Cases (1884), 20 Fed. 625, 629. 11 9 Op. Sol. P. O. D. No. 516. 12 As to orders, see United States v. Bromley, cited supra; 2 Op. Asst. Atty. Gen. P. O. D. 333 ; 8 Op. Sol. P. O. D. 181 ; 8 id. 361 ; 8 id. 391 (second opinion) ; 8 id. 426; and 8 id. 469. ‘‘A bill is a common form of correspondence and constitutes a considerable number of the Tetters’ handled by the postal establishment.” 6 Op. Sol. P. O. D. 373, 380. RESTRICTIONS ON TRANSPORTATION OF LETTERS 9 man or a store to the main office to be filled . 13 Orders include requisi¬ tions from one department of a business house on another department. (b) Bills and Statements of Account. Bills and statements of ac¬ count are “letters” when sent by a business concern or other person selling goods or rendering service to its customers . 14 In addition to store accounts, this class of matter includes premium notices , 15 water bills , 16 and bank statements . 17 Receipts and receipted statements of account are likewise “letters” when sent from a creditor to the debtor .- 8 (c) Reports. Reports are “letters” when sent from the person, of¬ fice, or firm making the report to the person, office, firm, or Govern¬ mental agency to whom the report is made . 19 Examples of such re¬ ports are : Income or other tax returns ; 20 Proofs of loss filed by an insured under an insurance policy ; 21 Reports of insurance agents to their company’s home offices regarding policy lapses or regarding health of an applicant for insurance ; 22 and Monthly and weekly reports of business transactions made to a central office . 23 (d) Applications. An application transmitted from an applicant to the person or Governmental agency to whom it is made is generally a “letter,” since the normal function of an application is to transmit information concerning the applicant upon which the person to whom it is addressed is expected to rely . 24 Examples are: Applications for drivers’ licenses and automobile licenses, and other permits ; 25 Applications for loans ; 26 and Contest entries . 27 13 9 Op. Sol. P. O. D. No. 500. 14 See 5 Op. Asst. Atty. Gen. P. O. D. 162 ; 6 Op. Sol. P. O. D. 453 ; 7 id. 309 ; 8 id. 410 ; and 8 id. 500. 15 Premium notices, 8 Op. Sol. P. O. D. 199. 16 Water bills, 8 Op. Sol. P. O. D. 396 (second opinion). 17 Bank statements, 8 Op. Sol. 188 (second opinion). 18 Receipts, see 3 Op. Asst. Atty. Gen. P. O. D. 359 ; 8 Op. Sol. P. O. D. 199 ; and 8 id. 424. Tax receipts, 8 Op. Sol. P. O. D. 424. An executed pension voucher sent by beneficiary to the United States held to be a letter even though acknowledged before a notary. 3 Op. Asst Atty Gen POD 359 19 Reports, 6 Op. Sol.'P. O. D. 362; 8 id. 216 (first opinion) ; 8 id. 262; and 8 id. 458 (second opinion). 20 Income tax returns, 8 Op. Sol. P. O. D. 467 (first opinion). Same as to cotton ginners’ monthly returns and reports to the Collector of Internal Revenue. 8 Op. Sol. P. O. D. 406 (second opinion). Also tax reports by taxpayer to a state taxing commission, 8 Op. Sol. P. O. D. 409 (first opinion). 21 Proofs of loss, 8 Op. Sol. P. O. D. 462. 22 Insurance agents’ reports, 8 Op. Sol. P. O. D. 462 ; 8 id. 191; and 8 id. 498. 23 Reports of business transactions, 5 Op. Asst. Atty. Gen. P. O. D. 158 ; 6 Op. Sol. P. O. D. 400 (first opinion) ; 8 id. 200 ; 8 id. 454 ; and 8 id. 498. 24 8 Op. Sol. P. O. D. 391 (first opinion) ; and 8 id. 424. However, a formal application to a quasi-judicial tribunal is not a letter. See note 30 on page 10. 25 8 Op. Sol. P. O. D. 391 (first opinion) ; and 9 id. No. 449. 26 8 Op. Sol. P. O. D. 424. 27 9 Op. Sol. P. O. D. No. 467. 10 RESTRICTIONS ON TRANSPORTATION OF LETTERS Sec. 5. Samples of Matter Not “Letters.” This section names various types of matter not considered to be “letters.” Other types of material not considered to be “letters” are discussed in sections G through 11. Exact copies of the items discussed forwarded to the same addressee, without the addition of any other information not ap¬ pearing on the originals, are not considered to be “letters.” 28 One type of papers which are not “letters” is the class termed “com¬ mercial papers.” Matters in this class are valued as evidence of rights of the holder rather than for any information they may carry when shipped from one person to another. This group includes con¬ tracts, stock certificates, promissory notes, bonds and other negotiable securities, insurance policies, title policies, abstracts of title, mort¬ gages, deeds, leases, and articles of incorporation. 29 As to checks and drafts, see section 7. Another class of material which is closely related to commercial papers consists of legal papers and documents. This class of matter is likewise not within the definition of “letters.” It consists of papers and documents intended for use in lawsuits or formal quasi-judicial proceedings, orders of court, and the like. 80 Other official records such as the following are likewise not “letters" : Birth and death certificates, election ballots and tally sheets, lists of registration of voters, and certificates to practice certain professions. 31 Although a letter may be written by use of any of the various types of symbols or characters mentioned in section 3, a message must con¬ sist of a word or a series of words. A picture or other visual repre¬ sentation of a physical thing, actual or projected, would not be a “letter.” Examples are drawings, blueprints, maps, and plat surveys. 32 Other miscellaneous articles which are not “letters” are catalogs (except as stated in section 6), directories, and unaddressed advertis¬ ing handbills or circulars. 33 28 9 Op. Sol. P. O. D. No. 465. Copy of insurance policy, 8 Op. Sol. P. O. D. 191 ; and 8 id. 498. 29 Executed leases, 8 Op. Sol. P. O. D. 197 (second opinion). Contra, G Op. Sol. P. O. D. 373. Insurance policies, 8 Op. Sol. P. O. D. 199 ; 8 id. 424; 8 id. 462 ; and 8 id. 498. Abstracts of title, 8 Op. Sol. P. 0. D. 346 (second opinion) ; and 8 id. 424. Mortgages, 2 Op. Asst. Atty. Gen. P. O. D. 2 (first opinion) ; 7 Op. Sol. P. O. D. 391 ; and 8 id. 424. Deeds, 2 Op. Asst. Atty. Gen. P. O. D 2 (first opinion) ; 7 Op. Sol. P. O. D. 391; and 8 id. 424. Notes, 8 Op. Sol. P. O. D. 424. Contracts, 2 Op. Asst. Atty. Gen. P. O. D. 2 (first opinion) ; and 7 Op. Sol. P. O. D. 391. Evidences of title or debt, 2 Op. Asst. Atty. Gen. P. O. D. 2 (first opinion) ; and 7 Op. Sol. P. O. D. 391. But a contract form used as an offer of a contract is a letter. See 9 Op. Sol. P. O. D. No. 450. 30 Judicial and quasi-judicial records, 9 Op. Sol. P. O. D. No. 481; and 9 id. No. 475. Pleadings, depositions, affidavits, and briefs, 2 Op. Asst. Atty. Gen. P. O. D. 2 (first opin¬ ion) ; 7 Op. Sol. P. O. D. 391 ; and 9 id. No. 481. But an attorney’s opinion on a point of law sent to his client would be a letter. 9 Op. Sol. P. O. D. No. 480. Executions, United States v. Chaloner (1831), 25 Fed. Cas. 392 (Cas. No. 14,777). 31 Ballots, 9 Op. Sol. P. O. D. No. 466. Ginners’ exemption certificates, 8 id. 406. Cer¬ tificates of tax sales, 2 Op. Asst. Atty. Gen. P. O. D. 2 (first opinion). Similarly, school diplomas are considered not to be “letters.” 32 Drawings, 8 Op. Sol. P. O. D. 368 (first opinion). Blueprints, 9 id. No. 455. Maps, 7 id. 622 ; and 8 id. 368. Tracings, 8 id. 368 (first opinion). 33 Catalogs, 8 Op. Sol. P. O. D. 425 (first opinion). Unaddressed handbills or circulars, 8 id. 425 (first opinion). Circulars are considered to be unaddressed even though accom- RESTRICTIONS ON TRANSPORTATION OF LETTERS 11 Sec. 6. Inter-Office Communications. The same rules apply to the determination of whether matters sent between the various branches of a concern are “letters” as apply in other cases. 34 It may be assumed that, in general, any written or printed matter sent between offices of a concern is sent because it conveys to the addressee office live, current information upon which the latter is expected to act, rely, or refrain from acting. 35 The following types of matter which are commonly sent between offices are “letters”: Requisitions which are orders from one department to another department within the same organization. As to orders generally, see section 4. All types of matter forwarded from a branch store to the main office which are used to supply information upon which charges and credits to the branch store or office are made, or which are used to verify the accuracy of items in the accounts between the main office and the branch office or store. 36 Retail price lists, catalogs, bulletins, and notices sent to advise a store or branch office of the price the latter should charge its customers or to advise the latter of discounts, market quotations, and the like. 37 The following are illustrative of some types of material sent between offices of an organization which are not “letters”: Carbon copy of a letter previously sent to the same addressee if it contains no information not in the original. See section 9. Matter sent for filing or storage only and which it is not in¬ tended the recipient will use for its own benefit. See section 10. Matter sent for auditing to determine whether charges and credits are correct when the results of the audit are not used to adjust accounts within the organization, but are merely reported to the sender for the latter’s action. See section 8. Data sent to a central office upon which customers’ bills are prepared if the data is returned to the sender and no part of the information is retained by the central office. See section 8. panied by addressed envelopes in which they are expected to be placed. 9 Op. Sol. P. O. I). No. 472. Trade newspapers and other publications containing specialized news, 9 Op. Sol. I*. O. D. No. 498 ; 9 id. No. 499 ; and 9 id. No. 490. Blank forms, 8 id. 181 : and 8 id. 210 (first opinion). 34 7 Op. Sol. P. O. D. 92 ; 8 id. 128 (second opinion) ; 8 id. 215 ; 8 id. 401 ; 9 id. No. 454 ; and 9 id. No. 500. A letter of instruction between offices, 5 Op. Asst. Atty. Gen. P. O. D. 193. 35 2 Op. Asst. Atty. Gen. P. O. D. 333 ; and 0 Op. Sol. P. O. D. 000. Matter sent to request approval of action, 8 id. 202. Reports, 0 id. 400 (first opinion) ; 8 id. 200; and 8 id. 210 (first opinion). 3 « 7 Op. Sol. P. O. D. 490 at 498 ; 8 id. 181 ; 8 id. 200 ; 8 id. 284 ; 8 id. 341 : 8 id. 451 ; 8 id. 491 (second opinion) ; 8 id. 497 : and 8 id. 505. 37 Price lists, 8 Op. Sol. P. O. D. 181 ; and 8 id. 491 (second opinion). 12 RESTRICTIONS ON TRANSPORTATION OF LETTERS Sec. 7. Checks and Drafts. Bank checks in their ordinary form containing only the names of the drawer, payee, bank upon which drawn, amount of money and date of issue are not “letters” within the meaning of that word as it is used in The Private Express Statutes, and hence may be conveyed by private express without violating said statutes. 38 However, if checks show upon their face or by stubs at¬ tached to them, or by statement sheets accompanying them, such in¬ formation as the weight of milk, quality, price, butter-fat content, the test, deductions for hauling and the like, then both the checks and the statements or settlement sheets are “letters” within the meaning of The Private Express Statutes, and may not be conveyed by third per¬ sons, such as contract haulers, outside of the mails without the payment of postage thereon. 39 Banks may forward all kinds of checks, notes, and drafts deposited with them to other banks for collection or payment outside the mails without the payment of postage. 40 All canceled checks and drafts may also be returned to the drawer outside the mails without the pay¬ ment of postage. 41 In both cases the information placed on the instru¬ ment for the benefit of the payee does not convey a message either to the bank to which forwarded or to the drawer. As to bank statements and letters of instruction accompanying checks, notes, and drafts, see section 17. Sec. 8. Matter Sent for Auditing or Preparation of Bills. When freight bills, invoices, paid bills, sales slips, receipts, records of re¬ ceipts and disbursements, and the like, are forwarded for the sole purpose of having them audited internally on behalf of the sender, they are not “letters.” An audit is for the benefit of the sender when the person or office making the audit merely reports the result to the sender and does not itself take any corrective action or adjust accounts between the sender and addressee or make other use either of the ma¬ terial forwarded or of the results of the audit. 42 Likewise, copies of invoices, sales slips, and public utility meter books and readings, and the like, which are sent by local offices of a company to the central office for the sole purpose of preparing customers’ statements therefrom for the branch offices, and no other use is made or action taken by the cen¬ tral office upon the information contained therein, and no part of the data therein set forth is retained by the central office for its action or for its bookkeeping records, 43 then such items may be forwarded to 38 8 Op. Sol. P. O. D. 436 (second opinion) ; 8 id. 438 ; 9 id. No. 459. 39 8 Op. Sol. P. O. D. 436. Payroll checks, 9 id. No. 458. ( Contra , United States v. American Dealers Service, Inc. (1943), D. C. S. D. N. Y. (unreported), Civil 21-107.) 40 8 Op. Sol. P. O. D. 137. 41 8 Op. Sol. P. O. D. 346 (second opinion). 42 7 Op. Sol. P. O. D. 391 ; 8 id. 341 ; 8 id. 497 ; 9 id. No. 448 ; and 9 id. No. 471. 43 Where “an envelope carrying all accounting data prepared at the central billing point” is forwarded to the branch office but immediately sent back to the central office by mail for use as a permanent accounting record, the information so transmitted is regarded as having been retained by the central office. 9 Op. Sol. P. O. D. No. 495. RESTRICTIONS ON TRANSPORTATION OF LETTERS 13 the central office 44 and returned to the local office 45 by express or other means outside the mails without the payment of postage, and the cus¬ tomers’ statements may also be sent by similar means to the local offices for delivery. 46 The mailing of the bills to the customers by the central office on behalf of the local office would not cause the copies of invoices, sales slips, or meter books to be considered “letters” when sent to the central office. The same principles also apply to the forwarding to and return by an independent bookkeeping firm of similar matter where such firm prepares accounting journals and ledgers for its cus¬ tomers, or to a forwarding for the performance of purely mechanical work such as photostating or for mathematical computation. 47 If the central office takes corrective action, adjusts accounts, or makes use, either in a personal way or to effect the conduct of rela¬ tions between the sending and the central offices, of any information in the material forwarded, either in the material forwarded or the results of the auditing, the billing process, mechanical work, or mathe¬ matical computation, the material sent to the central office is a “letter.” 48 Sec. 9. Information Known to Addressee. As a general matter, once information is in the possession of a person it may be assumed that material containing only the identical information or a portion of it is not sent as a communication or letter when forwarded to that person unless it is sent to verify the previous information. 49 Thus, when original letters are sent by mail and the necessary action is taken upon the same by the recipient, then duplicate copies may be sent to the same addressee outside the mails without the payment of postage. 50 It is not necessary that the form be identical so long as the informa¬ tion is, in fact, the same. 51 Of course, any material information upon which the addressee may act, rely, or refrain from acting, not contained in the original, would make the copy an individual letter to the addressee. Sec. 10. Old Correspondence and Other Matter Sent for Filing, Storage, or Destruction. Old correspondence, records, and any other type of matter sent from one office to another for filing, storage, or destruction are not “letters” since, under those circumstances, there is 44 8 Op. Sol. P. O. D. 410 ; 8 id. 447 ; 8 id. 618 ; and 9 id. No. 496. 45 8 Op. Sol. P. O. D. 410 ; and 8 id. 447. 40 8 Op. Sol. P. O. D. 447. 47 9 Op. Sol. P. O. D. No. 513 ; and 9 id. No. 517. 48 Use not confined to auditing, 7 Op. Sol. P. O. D. 496 ; 8 id. 200 ; 8 id. 497 ; and 9 id. No. 510. Also, generally, see 8 Op. Sol. P. O. D. 410 : 8 id. 447 : 8 id. 500 ; and 9 id. No. 496. 49 9 Op. Sol. P. O. D. No. 465. As to matter sent for verification of accounts, etc., see sections 6 and 8. 50 8 Op. Sol. P. O. D. 148 ; 8 id. 451 ; and 8 id. 461. But a carbon copy would be a “letter” when sent to one other than the addressee. 6 Op. Sol. P. O. D. 606 ; and 8 id. 215. 61 8 Op. Sol. P. O. D. 148 ; 8 id. 199 ; and 8 id. 216 (first opinion). But where the same information is sent in two or more forms at the same time, that portion of the material from which the addressee is expected to obtain the information.for his own use will be regarded as the “letter,” although it purports to be a copy rather than the original. 9 Op. Sol. P. O. D. No. 503. 14 RESTRICTIONS ON TRANSPORTATION OF LETTERS no purpose of communicating any intelligence to the addressee. 62 However, if matter is sent for the purpose of establishing a file of material from which it is intended the addressee may at some future time take information on which it will then act, rely, or refrain from acting, the matter so sent will be considered as a “letter.” 53 Sec. 11. Examination Papers. The answer papers of an examina¬ tion given to test the knowledge or intelligence of students or other groups are often sent to a central scoring agency, which scores and returns the papers or reports the grades to the school or institution administering the examination. Such examination papers forwarded under those circumstances for scoring are not regarded as “letters” provided the scoring agency does not make use of the scores or other information derived from the papers. 54 Examinaton papers with scores marked on them would normally be considered “letters” when returned to the school or person who previously transmitted them for scoring, or when forwarded to a third person who may be expected to take action based on the results of the examination. When, after such examination papers are scored, the papers are to be forwarded or the scores recorded to a third person, the papers are “letters” while they are transmitted for scoring. The same is true when the central scoring agency is to make other use of the papers or scores derived from them, such as to determine the relative standing of all persons taking the same examination at various places. Under these circumstances the central scoring agency has a direct interest in the oiDinion of the examinee as to the correct answers to the ques¬ tions posed. Sec. 12. Manuscript and News Items. Such manuscript as is in¬ tended for publication when not accompanied by any matter in the nature of personal correspondence, and mere news matter prepared by the correspondents of the press for the columns of their publica¬ tions, are not “letters.” Likewise, news matter to be used for the pur¬ pose of radio broadcasting is not a “letter.” 55 Sec. 13. Weight and Size. By their terms The Private Express Statutes make no distinction between items of various weights. A single letter would not, except in the most unusual circumstance, exceed the weight limit for mail matter. Even though a letter may exceed the weight limit, it is nevertheless a letter for purposes of The 52 7 Op. Sol. P. O. D. 391; and 7 id. 499. For filing, 6 id. 606; 7 id. 349 (second opin¬ ion) : 8 id. 200 ; and 8 id. 466. B3 Use for “stastistical” purposes field not to make matter a “letter.” 8 Op. Sol. P. O. D. 200. License stubs field not to fie “letters,” even though the filing office furnishes infor¬ mation contained on the stubs to members of the public upon specific request. 9 Op. Sol. P. O. D. No. 489 ; and 9 id. No. 492. 34 9 Op. Sol. P. O. D. No. 468. 65 8 Op. Sol. P. O. D. 469 ; 8 id. 489 (first opinion) ; and 9 id. No. 497. RESTRICTIONS ON TRANSPORTATION OF LETTERS 15 Private Express Statutes and is subject to the postal monopoly un¬ less it is physically impossible to break the letter down into several shipments. 56 C. PROHIBITED TRANSPORTATION Sec. 14. Post Routes. The term “post routes” as used in The Pri¬ vate Express Statutes means all routes on which mails of the United States are carried, and includes post roads as defined in Title 39, United States Code, section 481 (sec. 90.1 (a), Postal Laws and Reg¬ ulations of 1948). That section is as follows: “§ 481. What are post roads. “The following are established post roads: “All the waters of the United States, during the time the mail is carried thereon. “All railroads or parts of railroads and all air routes which are now or hereafter may be in operation. “All canals, during the time the mail is carried thereon. “All plank roads, during the time the mail is carried thereon. “The road on which the mail is carried to supply any courthouse which may be without a mail, and the road on which the mail is carried under contract made by the Postmaster General for extending the line of posts to supply mails to post offices not on any established route, during the time such mail is carried thereon. “All letter-carrier routes established in any city or town for the collection and delivery of mail matters.” In addition, Title 39, U. S. C., section 482 (sec. 90.1 (b), Postal Laws and Regulations of 1948), provides: “All public roads and highways while kept up and maintained as such are post routes.” When mail is delivered to the offices within a building, the corridors of the building are post routes. It should be noted that the pro¬ hibition applies not only to the transportation of letters over post routes, but also their transportation between towns or other places between which the mails are regularly carried; thus such transpor¬ tation is covered by The Private Express Statutes whether it occurs over a post route or over a parallel route. The streets of a town for which regular delivery service has not been established are not post routes, and letters originating there may be delivered in that 53 Cf. 6 Op. Sol. P. O. D. 461, holding a postal card which was nonmailable except under cover to be subject to The Private Express Statutes since “in any event such cards are acceptable in the mails when under cover.” See, also, 9 Op. Sol. P. 0. D. No. 491 as to lottery matter. 16 RESTRICTIONS ON TRANSPORTATION OF LETTERS town over such streets by any method without the payment of postage. 57 Sec. 15. Activities Prohibited. Title 18, U. S. C., section 1096, prohibits the establishment of a private express for the conveyance of letters and prohibits as well any provision for their conveyance by regular trips or at stated periods. This section is directed at the establishment of any business which has for one of its purposes the carriage of letters over a particular route 58 and the establishment of any system for the regular carriage of letters for others. 59 Title 18, U. S. C., section 1694, prohibits, with stated exceptions, the carrying of letters aboard any vehicle, plane, vessel, or other conveyance which engages in regular trips over post roads. The regularity need not be in the movement of the particular vehicle or other conveyance. It is sufficient if there are regular trips and on the occasion in question the regular trip is performed by the vehicle or other conveyance carrying the letter. If a carrier operates regular trips over a, post route using different vehicles on different trips, the prohibition applies even though it is not known in advance which of the various vehicles will be used on a particular day. “Regularity' 5 as used in the statute is not confined to an absolutely fixed schedule, but includes situations in which trips are made with sufficient fre¬ quency that third persons have reason to believe letters delivered to the carrier will reach their destination within an appointed time. 60 D. PERMISSIBLE CARRIAGE OF LETTERS Sec. 16. Delivery by Employees; “Current Business.” Title 18, U. S. C., section 1694, exempts letters which relate to “the current busi¬ ness of the carrier.” Such letters are letters written by or addressed 67 In United States v. Easson (1883), 18 Fed. 590; Blackham v. Gresham (1883), 10 Fed. 609; and United States v. American Dealers Service, Inc. (1943), D. C. S. D. N. Y. (unreported), Civil 21-107. the post routes involved in the violations of The Private Express Statutes were city streets. To the same effect see 3 Op. Asst. Atty. Gen. P. O. D. 137. Corridors of a building in which mail is delivered are post routes. 6 Op. Sol. P. O. D. 373 at 381. Streets of towns without mail delivery are not post routes. 14 Op. Atty. Gen. 152 at 153 ; and 8 Op. Sol. P. O. D. 484. The Private Express Statutes apply to air¬ mail routes wholly or partly within the United States. 9 Op. Sol. P. O. D. No. 482 ; and 9 id. No. 484. 68 “* * * if Thompson had established an express, of which one of the purposes was the carrying of letters over such a route, he was guilty of a violation of the law, and was liable to a penalty for each letter proved to have been so carried. It was not necessary, in order to constitute the offence, that the carrying of letters should be the sole business of the express; * * United States v. Thompson (1846), 28 Fed. Cas. 97, at 98 (Cas. No. 16,489). 69 A group of merchants may not establish a joint agency for the delivery of their advertising letters. 8 Op. Sol. P. O. D. 173. An independent service for the delivery of bills is prohibited by these statutes. 7 Op. Sol. P. O. D. 309. A contract trucking service may not lawfully permit an employee of a customer to ride a truck on one of its regular runs for the purpose of conveying letters for his employer. 8 Op. Sol. P. O. D. 434. 60 “To constitute regularity it is not essential that the minute or hour of the departures of the messengers should be always the same. Provision for a delivery daily, once, twice, or thrice, as the case may be, over the streets of the city, wherever wanted, is a provision for a delivery by regular trips and at stated periods;’’ United States v. Easson (1883), 18 Fed. 590, 592. “As near the first of the month as practical” is within the term “stated periods.” 6 Op. Sol. P. O. D. 461. The operation of a pneumatic tube system violates The Private Express Statutes under a method of operation by which letters are dispatched whenever they are tendered rather than on a definite schedule. 3 Op. Asst. Atty. Gen. P. O. D. 137. RESTRICTIONS ON TRANSPORTATION OF LETTERS 17 to officers or employees of the carrier on the business of the carrier; that is, sent by or addressed to officers of the carrier in their capacities as such officers or employees. 61 Since a letter, to be within this ex¬ emption, must be sent by an officer or employee in his capacity as such, letters forwarded on union business by such officers or members of a union or an employees’ association to other officers or members of that organization would not be within this exemption even though the senders and the addressees are also employees of the carrier. 62 Any business of the carrier is deemed to be its current business when it comes up in such a way as to call for a current communication. 63 Except in the special situation discussed in section 23, this exemption does not apply to letters forwarded by a party not an officer or em¬ ployee of the carrier to another person also not an officer or employee of the carrier, even though the contents of the letters concern the carrier. 64 Thus a city, county, or public utility company, or any other private individual or firm may use its regular salaried employees to deliver or receive its own letters. 65 Moreover, a regular salaried em¬ ployee may be hired to act exclusively as a messenger to carry his employer’s letters between offices, but the use of an independent con¬ tractor who makes regular trips between any two points on a post route is not permissible, 66 In general, if the person is an employee, he will share in all of the privileges enjoyed by other regular employees such as annual leave privileges and workmen’s compensation insurance. Accordingly, a carrier may convey its own letters to another carrier or company to the point of connection with the latter, and the addressee carrier or company may then carry them to any point on its lines. 67 However, the ownership of one carrier by another does not entitle either to carry letters not sent by or addressed to it outside the mails for the other without the payment of postage. 68 The different units of a railroad system or other system of carriers as long as they are separate, independent operating units are, with respect to The Private Express Statutes, “third parties” to each other and, consequently, are GX 28 Op. Atty. Gen. 537 ; 4 Op. Asst. Atty. Gen. P. O. D. 300 ; 7 Op. Sol. P. O. D. 499 ; and 9 Op. Sol. P. O. D. No. 485. Paid bills forwarded by the person receiving payment in order to advise the creditor that payment has been received are letters of the forwarder rather than the debtor. 9 Op. Sol. P. O. D. No. 514. 62 29 Op. Atty. Gen. 418 ; 6 Op. Sol. P. O. I). 372 ; and 6 id. 397. 63 28 Op. Atty Gen. 537. 64 “It thus appears that the purpose of Congress in introducing this clause was to permit a carrier to transport free outside the mails its own messages within the terms of the opin¬ ion of Attorney General Harmon, and it was not the intention of Congress to revolutionize the then existing law and practice by permitting free transportation of letters and packets belonging to railroads or persons other than the carrier even though such letters or packets might ‘relate to the current business of the carrier.’ ” 28 Op. Attv. Gen. 537, at 541. 05 6 Op. Sol. P. O. D. 293 ; G id. 301 ; 7 id. 309 ; 8 id. 151 ; and 8 id. 491 (second opinion). Letters addressed to employer, 9 Op. Sol. P. O. D. No. 514. 6(5 G Op. Sol. P. O. D. 512 ; 9 id. No. 451 ; 9 id. No. 452 ; and 9 id. No. 459. 67 21 Op. Atty. Gen. 394. Letters in custody of an express company and carried in express company railroad car are transported by the express company rather than the railroad company operating the train. 9 Op. Sol. P. O. I). No. 509. See, also, 3 Op. Asst. Atty. Gen. P. O. D. 146. 65 United States v. Southern Pacific (1928), 29 F. (2d) 433 ; 6 Op. Sol. P. O. D. 325 ; and G id. 3G2. 18 RESTRICTIONS ON TRANSPORTATION OF LETTERS not considered a single carrier for the purpose of this exemption. 69 An association of railroads may not transmit its letters outside the mails over its members’ roads because those letters do not belong to the carrier concerned, but to a separate entity, the association. 70 Where, however, two concerns are engaged in the joint operation of a business, that is, they share directly the revenues and expenses of the enterprise and the enterprise is operated by joint employees, either of the concerns may carry the letters of that enterprise. 71 However, if the revenues and expenses are not shared between the two concerns, letters on the business of the enterprise would not be considered the let¬ ters of the concern not sharing in the revenues and expenses. 72 Where one railway company or other carrier leases the property of another, either at an annual rental or under a profit-sharing arrange¬ ment, the trains or other vehicles operated by the lessee may carry the lessee’s letters but not those of the lessor. Nor may the lessor carry on other lines operated by it the letters of the lessee. 73 Sec. 17. Relating Exclusively to Accompanying Shipment. Title 18, U. S. C., section 1694, permits a carrier to transport letters which relate exclusively to some part of the cargo of the same conveyance or to some article carried at the same time by the same conveyance. This exemption permits a carrier to convey, without the payment of postage, letters such as invoices, bills of lading, shippers’ bills, way bills, freight bills, and the like, when they accompany shipments to which they exclusively relate. 74 Live, current information in a letter extraneous to the shipment it accompanies takes it out of the exemption for letters which relate to some article carried at the same time. 75 It was the intention of Congress in framing the statute to allow a letter to be sent accom¬ panying any article of property, provided it relates merely to the article of property sent and does not concern any other subject. 76 For example, a letter of transmittal containing instructions relative to delivery of drafts and checks, the return of unpaid items, and the 69 28 Op. Atty. Gen. 537. 70 28 Op. Atty. Gen. 537 ; 6 Op. Sol. P. O. D. 641 ; and 8 id. 485 (second opinion). How¬ ever, where the service of two companies is so pooled that trains are jointly operated by both roads, letters of either company may be conveyed in sncb trains. 7 Op. Sol. P. O. D. 651 ; and 7 id. 652. 71 United States v. Erie Railroad Co. (1915), 235 U. S. 513. 72 7 Op. Sol. P. O. D. 360. 73 1 Op. Asst. Atty. Gen. P. O. D. 910 ; and 2 id. 415. 74 Invoice, 8 Op. Sol. P. O. D. 346 (second opinion). Bills of lading and freight bills, 8 id. 203 (second opinion). 75 United States v. United States Express Co. (1869), 28 Fed. Cas. 352 (Cas. No. 16,602) ; and 8 Op. Sol. P. O. D. 188 (second opinion). 7G 2 Op. Asst. Atty. Gen. P. O. D. 700. The following have been held to relate exclu¬ sively to the shipment: “This package is shipped paid due to the small amount of the C. O. D.” 9 Op. Sol. P. O. D. No. 479. List of names of persons in a picture, 9 id. No. 506. The following have been held not to relate exclusively : “Invoice to be mailed within five days,” 9 Op. Sol. P. O. D. No. 479. With samples of oil, a letter describing the oil and the vehicle in which it was used, 9 Op. Sol. P. O. D. No. 488. An invoice marked to inform recipient about another shipment, 9 Op. Sol. P. O. D. No. 505. With a sample of oil for analysis, information regarding the vehicle in which the sample was used, 9 Op. Sol. P. O. D. No. 488. RESTRICTIONS ON TRANSPORTATION OF LETTERS 19 action to be taken relative to protest, is not a permissible enclosure with checks and drafts sent between banks for collection. 77 Likewise, a bank statement showing deposits and depositor’s balance does not relate exclusively to the canceled checks it accompanies and therefore is not a permissible enclosure. 78 However, a statement may be sent accompanying money and securities if it really constitutes an invoice of the money and securities it accompanies. 79 Sec. 18. Private Hands Without Compensation. Title 18, U. S. C., section 1696, exempts the transmission of letters by private hands without compensation. A person or firm engaged in transportation of goods or persons for hire cannot be considered “private hands without compensation”; 80 and the phrase quoted denotes transporta¬ tion of a letter which does not take place in the course of business of the person or firm carrying the letter. 81 Sec. 19. Special Messengers Employed for the Particular Occa¬ sion Only. Title 18, U. S. C., section 1696, permits the use of a special messenger employed for the particular occasion only to transmit letters when not more than 25 letters are involved. A special mes¬ senger is a person who, at the request of either the sender or the addressee of the letter, picks up the letter from the sender’s home or place of business and carries it to the addressee’s home or place of business. The transmission is considered to be by special messenger for the particular occasion only, even though the request for the serv¬ ice is made to the messenger’s regular employer and the particular messenger is selected by that employer rather than the sender or the addressee. 82 On the other hand, a practice whereby letters are picked up by one messenger and taken to a central office for delivery by an¬ other would preclude both the messenger picking up the letter and the messenger delivering the letter to the addressee from being con¬ sidered a “special messenger.” 83 The words “for the particular oc- 77 8 Op. Sol. P. O. D. 438 ; 8 id. 487 (second opinion) ; and 9 id. No. 487. 78 8 Op. Sol. P. O. D. 188 (second opinion). 79 Chouteau <£• Valle v. Steamboat St. Anthony (1847), 11 Mo. 226; Dwight v. Brewster (1822), 18 Mass. (1 Pick.) 50 ; 8 Op. Sol. P. O. D. 188 (second opinion) ; and 9 id. No. 487. 80 In United States v. Thompson (1846), 28 Fed. Cas. 97, at 98 (Cas. No. 16,489), the court ruled this exemption “did not authorize the defendant to establish an express for the carrying of letters in connection with, or as a part of his business of a merchandise express, although no charge was made for letters as such.” In 21 Op. Atty Gen. 394, 401, that officer held that neither common carriers “nor their employees, while engaged in their business, can be considered as ‘private hands’ under this section.” See, also, 9 Op. Sol. P. O. D. No. 459. 81 In 8 Op. Sol. P. O. D. 436 (second opinion) it was held that inasmuch as contract haulers of milk would not carry statements from the cream,ery to the farmers unless they were paid for hauling the milk, the haulers would not be regarded as hauling statements “without compensation.” To the same effect see, also, 8 Op. Sol. P. O. D. 185 ; 8 id. 201 ; and 8 id. 434. The same holding is applicable even though State law prohibits any difference in compensation between cases in which orders (letters) are carried and those cases in which they are not. 8 Op. Sol. P. O. D. 355. 82 “* * * ‘He summoned a messenger from the American District Company, and sent the messenger on his own particular errand.’ That is an example of the conveyance of letters by ‘special messenger employed for the particular occasion only.’ ” United States v. Easson (1883), 18 Fed. 590, at 591. 83 The collection of letters in a central office and the delivery of them where deliveries are made daily over the streets wherever such letters are directed, constitutes a business for a delivery by regular trips and at stated intervals. United States v. Easson, supra ; and 6 Op. Sol. P. O. D. 373, at 379. 20 RESTRICTIONS ON TRANSPORTATION OF LETTERS casion only” restrict the permission granted under this section to isolated instances of using a messenger service in which there is no regularity in use by the sender or addressee of the particular messenger or the organization by which he is employed. 84 A messenger or a carrier operating regularly between fixed points is not a “special messenger.” 85 Sec. 20. Letters on Which Postage Is Paid. Letters may be carried by an individual, express company, or any other person 86 outside the mails to any point within or without the United States, 87 provided appropriate postage is paid and certain other conditions contained in Title 39, U. S. C., section 500, are followed. The conditions con¬ tained in that section are: (a) Each letter must be placed in a separate sealed Government stamped envelope or other sealed envelope bearing adhesive postage stamps or a postage meter indicia. 88 (b) The amount of postage indicated by the stamp or meter indicia must be the same as would have been required had the letter been sent through the mails. If the letter is carried by air, the postage must be in the same amount as would have been required had the letter been sent air mail, 89 and if directed to a foreign country the appropriate international rate must be paid. 90 Since matter in sealed envelopes is classified as first-class mail, and since letters carried pursuant to this section must be in sealed envelopes, the proper rate of postage is the first-class (or air-mail) rate. 91 However, the amount of postage need not include registry or insurance fees even if the letter is privately insured. 92 (c) If adhesive postage stamps are used, they must be canceled with ink by the sender. (d) The sender must write the date of the letter on the envelope, or the person carrying it must write on the envelope the date he received the letter. (e) The name and address of the person for whom the letter is intended must be written on the envelope. Letters which the sender is entitled to send through the mails with¬ out a charge for postage may be sent in a similar manner outside the w 8 Op. Sol. P. O. D. 185. 85 United States v. Thompson (1846), 28 Fed. Cas. 97 (Cas. No. 16,489) ; and 21 Op. Atty. Gen. 894. See also 4 Op. Atty. Gen. 159 ; 3 Op. Asst. Atty. Gen. P. O. D. 146 ; and 8 Op. Sol. P. O. D. 410. 89 Express company, 1 Op. Asst. Atty. Gen. P. O. D. 474. Mail-carrying vessels, 1 id. 511. Private carrier, 7 Op. Sol. P. O. D. 131. 87 Directed to foreign destinations, 1 Op. Asst. Atty. Gen. P. O. D. 981 ; and 9 Op. Sol. P. O. D. No. 483. 88 The sender, not the addressee, must place the letter in an envelope, 8 Op. Sol. P. O. D. 361. Each letter must be in a separate envelope, 8 id. 391 (second opinion) ; 8 id. 392 ; and 8 id. 426. But if a salesman sends orders to his home office for filling, orders of several customers would be only one letter. 9 Op. Sol. P. O. D. No. 501. 89 8 Op. Sol. P. O. D. 358 ; and 8 id. 487. 90 9 Op. Sol. P. O. D. No. 483. 91 9 Op. Sol. P. O. D. No. 477. 92 Cf. 9 Op. Sol. P. O. D. No. 476. RESTRICTIONS ON TRANSPORTATION OF LETTERS 21 mails without the payment of postage. 93 Examples of such letters are letters of Congressmen upon official business, 94 official mail of other Government officers, 95 and mail of certain diplomatic and consular officers of other Nations. 90 However, if the free mailing privilege does not extend to air mail, then such letters must bear the appropriate air-mail postage if sent by air express. 97 The requirements of Title 39, U. S. C., section 500, are regarded as being met if a Government stamped postal card is used, even though the card is not enclosed in an envelope, provided it is properly dated and addressed as prescribed above. 98 In all other cases there must be exact compliance with the conditions prescribed in this section. 99 Sec. 21. Delivery to Post Office. Under Title 18, U. S. C., section 1696, it is permissible to establish a service for collecting letters from firms or individuals for delivery to a post office. Such letters, how¬ ever, must bear the proper postage for transmission through the mails from the point of origin * 1 and, if they are carried to the post office by air, they must bear postage at the air-mail rate. 2 As to “drop letters,” see section 24. Sec. 22. After Receipt From the Post Office. In a similar manner The Private Express Statutes permit the establishment of a service of collecting for the addressees letters received at the post office, pro¬ vided the letters remain unopened. 3 Letters received through the mails at one office of a firm may be forwarded by surface means outside the mails without the payment of additional postage so long as they remain unopened. Likewise, letters addressed to one firm in care of another, such as in the case of letters addressed to a program sponsor or advertiser in care of a radio station, and delivered through the mails to the firm in whose care addressed, may be forwarded by surface means outside the mails to the firm for whom they are intended provided the letters remain unopened. 4 If, in any of the cases mentioned above, the letters are forwarded by air express or air freight, sufficient additional postage must be placed on each piece of mail to bring the total postage on that piece 93 Cf. 9 Op. Sol. P. O. D. No. 478. 94 39 U. S. C. 327; § 37.4 (a), Postal Laws and Regulations of 1948. 95 39 U. S. C. 321 ; § 37.9 (a), Postal Laws and Regulations of 1948. 9(5 39 U. S. C. 336 ; § 37.8 (a), Postal Laws and Regulations of 1948. Also letters carried free by the postal service pursuant to treaty or other international agreements, 9 Op. Sol. P. O. D. No. 463. 97 9 Op. Sol. P. O. D. No. 463. 98 9 Op. Sol. P. O. D. No. 508. 09 7 Op. Sol. P. O. D. 131. 1 2 Op. Asst. Atty. Gen. P. O. D. 790 ; 2 id. 820 ; 3 id. 66 ; 5 id. 536 ; 7 Op. Sol. P. O. D. 660 ; and 8 id. 426. 2 Each letter in a bundle shipped by air express for later deposit in the mails must bear individual postage at the air-mail rate. 9 Op. Sol. P. O. D. No. 469. To the same effect, 8 id. 358. However, advertising letters or cards may be shipped by air express away from the point of destination for depositing in the mails without the payment of air-mail postage. 9 Op. Sol. P. O. D. No. 507. 3 2 Op. Asst. Atty. Gen. P. O. D. 790 ; and 9 Op. Sol. P. O. D. No. 494. 4 8 Op. Sol. P. O. D. 432. 22 RESTRICTIONS ON TRANSPORTATION OF LETTERS * up to the air-mail rate. Moreover, if the letters are opened before they are forwarded, the forwarding of the opened letters would be considered a new shipment of the matter, and such forwarding will be regarded as the transmission of letters if they are forwarded for the purpose of conveying to the ultimate addressee live, current in¬ formation upon which he may act, rely, or refrain from acting. Sec. 23. Receipts for Goods Delivered and Deliveries in Conjunc¬ tion With Collections. The conveyance by a carrier of receipts for goods delivered by it when carried for its own protection is not re¬ garded as transportation for another. In that circumstance the car¬ rier conveys the receipts on its own behalf. 5 Similarly, persons actually engaged in collecting accounts for others may carry statements of accounts which are to be collected. The purpose of the transportation of the statement is not to get the infor¬ mation on the statement into the hands of the debtor, but to establish the authority of the collector to receive payment and to furnish a receipt to the debtor upon payment. 6 See section 4 as to receipts and statements of account transmitted for other purposes. E. MISCELLANEOUS PROBLEMS RELATED TO THE PRIVATE EXPRESS STATUTES Sec. 24. Drop Letters. Section 1 (b) of Public Law 233, 82d Con¬ gress (65 Stat. 672), provides in part: “* * * the rate of postage on mail matter of the first class when mailed for local delivery at post offices where free delivery by carrier is not established and when the matter is not collected or delivered by rural or star route carriers, shall be 2 cents for each ounce or fraction thereof.” Section 34.8 (c), Postal Laws and Regulations of 1948, provides: “Letters, bills, statements, etc., prepared at a central office of a concern rendering service at some other place, presented for local delivery at the post office of such latter place, shall be accepted at the 2-cent or 3-cent drop letter rate, whichever is applicable for local matter at the particular post office. The stamps used in the payment of postage on such matter or others in lieu thereof should be purchased at the post office where the matter is deposited for mailing.” “Note : A drop letter is one addressed for delivery from the office at which it is posted.” 5 United States v. Thompson (1840), 28 Fed. Cas. 97 (Cas. No. 16,489) ; and 9 Op. Sol. I*. O. D. No. 462. 9 Op. Sol. P. O. D. No. 449. RESTRICTIONS ON TRANSPORTATION OF LETTERS 23 In addition to the foregoing restrictions on the use of the 2-cent drop-letter rate, the use of that rate of postage is, in effect, also restricted by The Private Express Statutes. Except when forwarded to the person, firm, or office for whom they have been prepared in order that the latter may mail the same on its own behalf, letters forwarded from one town to another for ultimate mailing are “letters” for pur¬ poses of The Private Express Statutes. 7 The transmission of such letters is subject to the same prohibitions which are applicable to the forwarding of other letters. 8 Sec. 25. Mailing of Letters of Two or More Persons in One En¬ velope. It is not permissible for two or more persons or firms to establish a system or plan to reduce the amount of postage they pay, by assorting, grouping, and mailing in one envelope their bills, state¬ ments of account, or other letters to be forwarded to one customer. It is likewise objectionable for a person acting as the agent of two or more persons or firms to assort, group, and mail in one envelope the bills, statements of account, or other letters of these concerns to a mutual customer. Such a system would be a private express inasmuch as it would perform the function of an express, i. e., the consolidation of several small shipments into a larger single shipment. Moreover, the mailing service would assume the character of a rival post office contrary to the intention of Congress in establishing a postal monopoly. 9 As indicated in section 4, applications for automobile, drivers’, and other licenses are “letters” when forwarded for the purpose of securing a license. The application of each individual or company constitutes a separate letter. Applications of various persons may not be grouped and mailed in one package by a person who acts as the agent or repre¬ sentative of the different individual applicants, and who receives compensation therefor, unless the package is endorsed on the outside to show the number of persons whose separate applications are en¬ closed and sufficient stamps are affixed to the package to cover the post¬ age at the rate of 3 cents each on the applications of each person, so that the postal service will receive the same revenue as it would have received if the applications of each person were mailed separately. 10 However, agents of the licensing authority who are authorized to receive applications on behalf of that authority may forward the various applications received by them to any other office in bulk at the rate of 3 cents an ounce applied to the entire shipment. In such a 7 3 Op. Asst. Atty. Gen. P. O. D. 66 ; 5 id. 536 ; and 9 id. No. 464. 8 See sections 14 and 15 as to prohibited carriage of letters ; and sections 16 to 23 as to exceptions from the prohibitions when the full rate of postage is paid. 8 8 Op. Sol. P. O. D. 180. 10 8 Op. Sol. P. O. D. 391 (first opinion). Automobile licenses, 9 Op. Sol. P. O. D. No. 512. Hunting and fishing licenses, applications for gas refunds, and tax returns, 9 Op. Sol. P. O. D. No. 515. 24 RESTRICTIONS ON TRANSPORTATION OF LETTERS case the applications are not forwarded on behalf of the several appli¬ cants, but on behalf of the forwarder. 11 No two firms which are distinct entities may send their letters in one envelope even though they are affiliated or jointly owned. 12 Sec. 26. Restricted Use of Private Letter Boxes. Every private letter box or other receptacle intended or used for the receipt or delivery of mail matter on any city-delivery route, rural delivery, or other mail route, shall be used exclusively for the reception of matter regularly in the mails and may not be used by other persons for the delivery of messages or other mailable matter such as state¬ ments of accounts, circulars, sale bills, or other like matter 13 without the payment of lawful postage. 14 However, a letter slot in a door is not a “box or other receptacle” and the prohibition does not apply to such slots. Sec. 27. Rates of Postage on Mail Matter. The determination of whether a particular type of matter is a “letter” for purposes of The Private Express Statutes has no bearing on the determination of whether the same matter is first-, second-, third-, or fourth- (parcel post) class matter when it is carried by the postal service. The classi¬ fication of matter in the mails is governed by statutes 15 entirely dif¬ ferent from The Private Express Statutes. Completely different principles apply to the determination of the proper classifications, and separate regulations and instructions have been issued with re¬ spect to the determination of the proper classification of matter sent through the mails. 16 It follows that some matters which are not “letters” for purposes of The Private Express Statutes may be en¬ titled to transmission through the mails at the rate of postage ap¬ plicable to third- or fourth-class matter, while other such “letters” must bear postage at the first-class rate. The same is true of matters which are not “letters” for purposes of The Private Express Statutes. 17 Inquiries to the Department concerning the proper classification of, or rate of postage applicable to, matter carried in the mails should be directed to the Assistant Postmaster General, Bureau of Finance. 11 9 Oi>. Sol. P. O. D. No. 515 ; and 9 id. No. 512. 32 8 Op. Sol. P. O. D. 410 ; and 9 id. No. 453. However, where two companies actually operate as one with the same offices, officers, and employees, they would not be regarded as separate entities. 9 Op. Sol. P. O. D. No. 486. 13 The prohibition applies to unstamped advertising matter whether such matter is placed in a spring holder attached to the letter box or placed on top, behind, or inside the box, 8 Op. Sol. P. O. D. 404 (second opinion). 33 “Whoever knowingly and willfully deposits any mailable matter such as statements of accounts, circulars, sale bills, or other like matter, on which no postage has been paid, in any letter box established, approved, or accepted by the Postmaster General for the receipt or delivery of mail matter on any mail route with intent to avoid payment of lawful postage thereon, shall for each such offense be fined not more than $300.” Title 18, U. S. C., sec. 1725 (39 CFR 50.23 (f) ; sec. 50.23 (f), Postal Laws and Regulations of 1948). 35 Title 39, U. S. C., sections 221-240, 247, 249, and 250. 30 39 CFR, Part 34 (Part 34, Postal Laws and Regulations of 1948). See also chapter headed “Domestic Mail Matter” in U. S. Official Postal Guide, Part I. 37 8 Op. Sol. P. O. D. 272. RESTRICTIONS ON TRANSPORTATION OF LETTERS 25 As to inquiries concerning The Private Express Statutes, see section 28 . Sec. 28. Reports of Postmasters; Inquiries. Inquiries of mem¬ bers of the public to the Department regarding The Private Express Statutes should be directed to the Solicitor. Whenever a postmaster or other officer of the Postal Service re¬ ceives information or has good reason to believe that letters are illegally brought to or sent from any city, town, landing, station, or place, whether by steamboat, railroad, private carrier for hire, or any other mode of conveyance, or in any way in violation of law, he shall immediately report such violation to the proper inspector in charge with all the facts concerning it in his possession. If in doubt whether matter comes within the classification of letters or whether it may be lawfully transported and delivered other than by the Post Office Department unless postage is affixed, samples, or a complete de¬ scription of the matter, should be submitted to the Solicitor for a ruling. 18 15 39 CFR 91.11 (sec. 91.11, Postal Laws and Regulations of 1948). > v r. VH • • J'l» i ; - t . v« ‘ - - INDEX (Numbers refer to pages) Accounting journal, 13 Advertising circulars, 10 handbills, 10 Air express, 21 Air routes, 15 Applications, 9, 23 Articles of incorporation, 10 Attorney’s opinion, 10, note 30 Auditing, 11, 12 Automobile license applications, 9, 23 Ballots, 10 Bank statements, 9, 19 Bill collectors, 22 Bills, 9 Bills of lading, 18 Birth certificates, 10 Blueprints, 10 Bonds, 10 Bulletins, 11 Cancellation of postage, 20 Cancelled checks, 12 Catalogs, 10, 11 Checks, 12 Circular, 8, 10 Certificates: birth and death, 10 to practice, 10 Cities without letter-carrier service, 15 Classification of mail, 24 Commercial papers, 10 Communications, between offices, 11 Congressional letters, 21 Consolidation of letters, 23 Consular mail, 21 Contest entries, 9 Contract haulers, 19, note 81 Contracts, 10 Conveyances, 16 Copies, 11 Copies of letters, 13 Current business, 16 Data for preparation of bills, 11, 12 “Dead” correspondence, 13 Death certificates, 10 Deeds, 10 Deliveries and collections, 22 Delivery of letters to post office, 21 Destruction, matter sent for, 13 Diplomas, 10, note 31 Diplomatic mail, 21 Directories, 10 Discount notices, 11 Drafts, 12 Drawings, 10 Drivers’ license applications, 9, 23 Drop letters, 22 Election ballots, 10 Employees, 16 Entries, contest, 9 Evidences of title or debt, 10, note 29 Examination papers, 14 Filing, matter sent for, 13 Filing and storage, 11, 13 First-class matter, 24 Fourth-class matter, 24 Free mailing, 21 Freight bills, 18 Government officers’ letters, 21 Grouping letters, 23 Handbills, 10 Highways, 15 Income tax returns, 9 Incorporation, articles of, 10 Independent carriers, 17 Information known to addressee, 13 Instructions, 11, note 34 Insurance: agents’ reports, 9 policies, 10 Inter-office communications, 11 Invoice copies, 12 Invoices, 18 Joint employees, 16 Joint mailing, 23 Joint operation, 16 Judicial records, 10, note 30 Leased railway line, 18 Leases, 10 Legal papers, 10 Letter boxes, 24 Letter carrier routes, 15 Letter carrier service, absent, 15 Letter of Transmittal, 18 Letters, 7, 8 Letters, delivery to post office, 23 Letter slots, 24 License applications, 23 License stubs, 14, note 53 27 Lists of registration of voters, 10 Loan applications, 9 Mail receptacles, 24 Manuscripts, 14 Maps, 10 Market quotations, 11 Mathematical computations, 13 Mechanical processing, 13 Meter books, 12 Metered postage, 20 Meter readings, 12 Milk checks, 12 Mortgages, 10 Negotiable securities, 10 News items, 14 Newspapers, 10, note 33 Notices, 11 Notices, premium, 9 Official mail, 21 Official records, 10 Old correspondence, 13 Opinion, attorney’s, 10, note 30 Orders, 8 Orders of court, 10 Packets, 7 Payment of postage, 20 Permit applications, 9, 23 Photostating, 13 Pictures, 10 Plane, 16 Plat surveys, 10 Postage, 20 Postage meter indicia, 20 Postage paid, 20, 21 Postal cards, 21 Post roads, 15 Post routes, 15 Premium notices, 9 Preparation of bills, 12 Price lists, 11 Private express, 16 Private hands, 19 Promissory notes, 10 Proofs of loss, 9, note 21 Publications, 10, note 33 Public roads, 15 Public utility meter books, 12 Quasi-judicial records, 10, note 30 Railroads, 17 Receipt of letters from post office, 21 Receipts, 9, 22 Registration of voters’ lists, 10 * Regularity, 16 Regular trips, 16 Relating to accompanying shipment, 18 Reports, 9 Reports of business transactions, 9 Requisitions, 8 Returns, income and other taxes, 9 Sales slips, 12 Second-class matter, 24 Separate postage, 23 Shippers’ bills, 18 Size of letters, 24 Special messengers, 19 Stated periods, 16 Statements: accompanying check, 12 of account, 9 “Statistical purposes,” 14, note 53 Stock certificates, 10 Storage, 13 Streets, 15 Tabulating cards, 8, note 7 Tally sheets, 10 Tax returns, 9 Test (Examination) papers, 14 Third-class matter, 24 Title policies, 10 Towns without letter-carrier service, 15 Tracings, 10, note 32 Trade newspapers and publications, 10, note 33 Transmittal letter, 18 Transportation for hire, 19 Unaddressed advertising, 10 Vehicles, 16 Vessel, 16 Voters’ lists, 10 Water bills, 9 Water routes, 15 Waybills, 18 Weight of letters, 22 Without compensation, 19 o 28