This is a mirrored copy of
http://www.essential.org/monitor/mm2001/01april/corp1.html


                           Multinational Monitor
                               Trade Madness!

                     April 2001 · VOLUME 22 · NUMBER 4
                          Subscription info below

    ---------------------------------------------------------------------


                         NAFTA's Investor "Rights"
                             A Corporate Dream,
                            A Citizen Nightmare

                              by Mary Bottari



     The North American Free Trade Agreement (NAFTA) includes an array
     of new corporate investment rights and protections that are
     unprecedented in scope and power. NAFTA allows corporations to sue
     the national government of a NAFTA country in secret arbitration
     tribunals if they feel that a regulation or government decision
     affects their investment in conflict with these new NAFTA rights.
     If a corporation wins, the taxpayers of the "losing" NAFTA nation
     must foot the bill. This extraordinary attack on governments'
     ability to regulate in the public interest is a key element of the
     proposed NAFTA expansion called the Free Trade Area of the
     Americas (FTAA).

     NAFTA's investment chapter (Chapter 11) contains a variety of new
     rights and protections for investors and investments in NAFTA
     countries. Specifically, Article 1110 of NAFTA guarantees foreign
     investors compensation from the NAFTA governments for any direct
     government expropriation (i.e., nationalization) or any other
     action that is "tantamount to" an "indirect expropriation." In
     addition, Article 1102 provides for "national treatment," which
     means that governments must accord to companies of other NAFTA
     countries no less favorable treatment than they give to their own
     companies. Article 1105 contains a "minimum standard of treatment"
     provision, which includes vague prose about fair and equitable
     treatment in accordance with international law.

     If a company believes that a NAFTA government has violated these
     new investor rights and protections, it can initiate a binding
     dispute resolution process for monetary damages before a trade
     tribunal offering none of the basic due process or openness
     guarantees afforded in national courts. These so-called
     "investor-to-state" cases are litigated in the special
     international arbitration bodies of the World Bank and the United
     Nations, which are closed to public participation, observation and
     input. A three-person panel composed of professional arbitrators
     listens to arguments in the case, with powers to award an
     unlimited amount of taxpayer dollars to corporations whose NAFTA
     investor privileges and rights they judge to have been impacted.

     Corporate investors have used these unprecedented NAFTA investment
     protections to challenge national and local laws, governmental
     decisions and even governmental provision of services in all three
     NAFTA countries. To date, companies have filed more than a dozen
     cases, claiming damages of more than US$13 billion [see "The
     Chapter 11 Dossier"].

     "Tantamount to Extortion"
     In the largest Chapter 11 suit yet brought against the United
     States, the Canadian corporation Methanex in 1999 sued the U.S.
     government for $970 million because of a California executive
     order phasing out the sale of a Methanex product. Methanex claims
     that California's phase-out of methyl tertiary butyl ether (MTBE),
     a gasoline additive, violates the company's special investor
     rights granted under NAFTA because the California environmental
     policy limits the corporation's ability to sell MTBE. If a NAFTA
     tribunal decides that California's environmental policy violates
     NAFTA's investor protections, the U.S. government can be held
     liable for the corporation's lost profits from not selling MTBE.

     The case is "a clear threat to California state sovereignty and
     democratic governance," says Martin Wagner of the California-based
     Earthjustice Legal Defense Fund. If Methanex succeeds, California
     will be under pressure to rescind its executive order, to lessen
     the damage award.

     Associated with human neurotoxicological effects, such as
     dizziness, nausea and headaches and found to be an animal
     carcinogen with the potential to cause human cancer, MTBE has been
     found in ground water and drinking wells around California. On
     March 25, 1999, California required the removal of MTBE from
     gasoline sold in the state by December 31, 2002. Governor Gray
     Davis declared that "on balance, there is significant risk to the
     environment from using MTBE in gasoline in California."

     Methanex claims that adding MTBE to gasoline reduces air
     pollution. However, a 1998 University of California at Davis
     (UC-Davis) report, which informed the government action, found
     that "there is no significant additional air quality benefit to
     the use of oxygenates such as MTBE in reformulated gasoline." The
     report found "significant risks and costs associated with water
     contamination due to the use of MTBE." The report noted that "MTBE
     is highly soluble in water and will transfer readily to
     groundwater from gasoline leaking from underground storage tanks,
     pipelines and other components of the gasoline distribution
     system." It also noted that the use of MTBE in motor boat fuel
     results in contamination of surface water. The report concluded
     that "[w]e are placing our limited water resources at risk by
     using MTBE."

     On the basis of the UC-Davis findings, California moved to ban
     MTBE. Methanex's response was to drag the California policy into
     NAFTA Chapter 11 litigation, demanding MTBE be allowed or $970
     million be paid.

     In its amended claim, Methanex alleges that the California ban
     discriminates against MTBE in favor of ethanol, a similar U.S.
     product, and is therefore a violation of NAFTA's national
     treatment rules. As evidence, Methanex cites the executive order
     which requires the California Energy Commission to look into
     development of a California ethanol facility. Methanex alleges
     that Archer Daniels Midland (ADM), a principal producer of ethanol
     in the United States, influenced the governor's decision with
     $210,000 in campaign contributions, arguing that the ban stands in
     violation of NAFTA's fair and equitable treatment rules. Finally,
     Methanex claims that the ban was not the "least trade restrictive"
     method to fix the water contamination problem, and thus violates
     NAFTA requirements that companies be treated fairly and "in
     accordance with international law." The relevant laws cited by
     Methanex are the rules of the World Trade Organization, which
     require countries to use the least trade restrictive means to
     achieve environmental and public health goals.

     "These cases are tantamount to extortion," says Martin Wagner.
     "This is a situation in which someone is causing a harm and then
     making the assertion that they will stop that harm only upon
     payment of a fee. In the California case, Methanex is selling a
     chemical and saying to the U.S. government, 'If you want us to
     stop, you have to pay us.' This is even more appalling when you
     consider that the victims of this extortion are the people of
     California, who don't want their drinking water contaminated by
     MTBE."

     The California case has drawn comparisons to the 1998 case brought
     against Canada by the U.S.-based Ethyl Corporation [see "Another
     NAFTA Nightmare," Multinational Monitor, October 1996]. In that
     case, Ethyl sued Canada for $250 million after Canada banned the
     gasoline additive methylcyclopentadienyl manganese tricarbonyl
     (MMT) because of health risks. The state of California had banned
     MMT and the U.S. Environmental Protection Agency (EPA) was working
     on a similar regulation. Ethyl claimed the Canadian ban violated
     NAFTA because it "expropriated" future profits and damaged Ethyl's
     reputation. After learning that the NAFTA tribunal was likely to
     rule against its position, the Canadian government revoked the
     ban, paid Ethyl $13 million for lost profits to date, and, as part
     of a settlement with Ethyl, agreed to issue a public statement
     declaring that there was no evidence that MMT posed health or
     environmental risks.

     Methanex brought its NAFTA case to the United Nations Commission
     for International Trade and Law (UNCITRAL), the arbitration regime
     of the United Nations. The case is now pending. Under UNCITRAL
     rules, not only are the citizens of California shut out of this
     proceeding, but so are the governor and the attorney general of
     California, the state whose policy is in question. California
     officials must rely on the Office of the U.S. Trade Representative
     (USTR) to defend the interests of California residents in this
     closed tribunal.

     Deliver This
     In a case that seeks to push the limits of Chapter 11, the
     U.S.-based United Parcel Service (UPS) is pursuing a NAFTA Chapter
     11 case against Canada for $100 million, arguing that the fact of
     the Canadian postal service's involvement in the courier business
     infringes upon the profitability of UPS operations in Canada.

     In this case, the first NAFTA investor-to-state case against a
     public service, UPS is attempting to stretch the NAFTA Chapter 11
     provisions in an entirely new direction. Canada Post is a "Crown
     corporation" owned by the people of Canada. Canada Post has not
     received direct taxpayer support for about a decade and has been
     paying income tax since 1994.

     UPS claims that by integrating the delivery of letter, package and
     courier services, Canada Post has cross-subsidized its courier
     business in breach of NAFTA rules. For example, UPS argues that
     permitting consumers to drop off courier packages in Canada Post
     letter mail postal boxes unfairly advantages Canada Post as
     against other courier services. Other alleged forms of
     cross-subsidization include:

        * Using letter carriers to pick up courier packages from the
          mail boxes and "transport them in vehicles that form part of
          the infrastructure of the Canada Post monopoly."
        * Sorting courier packages at "Canada Post's letter mail
          monopoly sorting facilities across Canada."
        * Transporting courier packages on airplanes and trucks
          chartered by the mail service.
        * Selling courier services at post offices.
        * "Precluding franchisees at Canada Post retail outlets from
          selling of any courier product other than Canada Post's."
        * Permitting courier consumers to use postal stamp meters on
          courier packages.
        * "Having the regulatory definition of 'letter' changed from
          450 grams to 500 grams in order to expand its letter mail
          monopoly."

     "UPS is entitled to receive the best treatment available in Canada
     with respect to the treatment of its investment," UPS argues in
     its claim. "This treatment would include having equal access to
     the postal distribution system provided" to the postal service's
     courier operations. Failure to provide such equal treatment, UPS
     alleges, violates the national treatment obligations of Chapter
     11.

     In a cable by the U.S. Embassy in Ottawa that Public Citizen
     obtained under a Freedom of Information Act request, UPS Canada
     Legal and Public Affairs Vice President Allan Kaufman was
     characterized as "very confident the Government of Canada stood to
     lose its fourth and largest Chapter 11 challenge with the UPS
     case," and Kaufman signaled that the corporation would be open to
     settlement.

     Former Canadian Foreign Minister Don Mazankowski responded to
     these arguments in a February 2001 column in the Globe & Mail. He
     argued that Canada treated UPS with an even hand by allowing UPS
     access to the market on the same terms as any Canadian
     corporation, that UPS is not subject to any additional taxes or
     duties and that the company is governed by the same laws as any
     Canadian corporation.

     "The UPS claim is unique. Unlike the other NAFTA-based foreign
     investor claims which have sought to recoup investments, UPS is
     using NAFTA Chapter 11 provisions in a strategic offensive to
     secure a greater share of the Canadian market," asserts Canadian
     trade attorney Steve Shrybman. "UPS is arguing that because Canada
     Post provides public mail services, it shouldn't also be providing
     integrated parcel and courier services. In an era when monopoly
     and commercial service delivery is commingled, few public services
     including health care and education would be immune from similar
     corporate challenges."

     This case is also proceeding under UNCITRAL rules and the Canadian
     Union of Postal Workers and other interested parties are
     attempting to intervene.

     The Fast Track to Expanded Chapter 11
     The "expropriations" that have been challenged under Chapter 11
     are nothing like the government seizure of property that is
     generally conveyed by the term. Instead, corporations have used
     the provision to challenge or seek compensation for what are
     called "regulatory takings" in the United States - regulations
     which supposedly take away the entire value of a property. While a
     conservative legal movement has worked for two decades to espouse
     the theory of regulatory takings, with some success, regulatory
     takings suits continue to face significant judicial hurdles in
     U.S. courts. The Chapter 11 cases take this "regulatory takings"
     logic to a new extreme.

     While these expansive investor rights currently are included only
     in NAFTA, plans are underway to incorporate similar provisions in
     the FTAA. FTAA is a proposed NAFTA expansion to all 34 countries
     of the Western Hemisphere (but for Cuba). The Bush administration
     has signaled that it wants the controversial fast-track trade
     negotiating authority in order to negotiate the FTAA. Once
     Congress delegates its trade negotiating authority to the
     president via fast track, it limits its own role to a single
     up-or-down vote on trade agreements' implementing legislation,
     which cannot be amended.

     There is no guarantee the Bush administration will succeed in its
     effort to win fast track, or in its attempts to impose investment
     provisions in the FTAA.

     Canada, which has been badly burned in a series of Chapter 11
     cases, is no longer a believer. Canadian Trade Minister Pierre
     Pettigrew has declared that Canada will not sign FTAA if
     investor-to-state enforcement of broad regulatory takings rights
     are included, and Canada has called for a review of Chapter 11
     within NAFTA.

     Whether Canada will hold to these positions, and whether it can
     organize other countries to join it amidst the complex FTAA
     negotiations in which the United States is the dominant player,
     remains to be seen. In the meantime, environmentalists, public
     health groups, California residents and many others concerned
     about the broad regulatory takings provisions will continue to
     press for their removal from NAFTA and their exclusion from the
     FTAA.

     Mary Bottari is director of Global Trade Watch's Harmonization
     Project.



                          The Chapter 11 Dossier:
               Corporations Exercise Their Investor "Rights"

        Corporations have filed more than a dozen cases under
        NAFTA's Chapter 11 investment provisions, which enable
        corporations to sue governments for infringements of their
        "investor rights." Since they are conducted in confidential
        arbitral processes, inaccessible to public scrutiny and
        participation (in contrast to open proceedings in domestic
        courts), information on ongoing cases is sketchy. Available
        information on 15 of the cases is summarized below.

        Suits against Canada

        Ethyl Corporation
        In this first investor-state case, Ethyl Corporation of the
        United States sued the Canadian government for $250 million
        and obtained, in 1998, a settlement of $13 million for the
        Canadian ban on the gasoline additive, MMT, a nerve toxin
        [see "Another NAFTA Nightmare," Multinational Monitor,
        October 1996]. The ban was reversed.

        S.D. Myers
        In October 1998, U.S.-based S.D. Myers Inc., which treats
        transformers containing toxic PCBs, filed a claim for $30
        million for losses it claims to have incurred during a
        one-and-one-half-year ban (1995 to 1997) on the export of
        PCB wastes from Canada. The Canadian federal government
        states that Canada is bound by international conventions
        that stipulate that PCBs must be destroyed in an
        environmentally sound manner, and that U.S. standards for
        PCB disposal are not as high as Canada's. The wastes were
        destroyed in a Canadian facility in Alberta, and the export
        ban was revoked in 1997. The U.S. government also controls
        cross-border movement of PCBs. In November 2000, the
        arbitral tribunal found that the ban did contravene the
        investment chapter regarding national treatment and minimum
        standards of treatment of foreign investors, and it is now
        determining whether S.D. Myers suffered damages. In the
        meantime, the Canadian government has applied to the
        (domestic) Federal Court to have the tribunal's partial
        award set aside, arguing that the case concerned
        cross-border trade, not a Canadian investment, and that the
        award conflicts with a well-established Canadian policy
        requiring disposal of PCBs and PCB wastes in Canada to
        comply with the Basel Convention on the Control of
        Transboundary Movements of Hazardous Wastes and Their
        Disposal.

        Sun Belt Water Inc.
        This California-based company is suing Canada for the
        decision of the provincial government of British Columbia to
        refuse consent for the company to export bulk water from BC.
        The government subsequently enacted the Water Protection
        Act, which bans bulk water exports and inter-basin
        diversions by domestic and foreign investors alike. In a
        colorful claim which alleges a decade of "smelly" actions by
        successive BC governments, Sun Belt Water expounds on the
        growing world-wide demand for water, assumes that water
        export must be a positive benefit (ignoring environmental
        and conservation requirements) and makes extreme claims of
        improprieties by the BC government and BC courts. In a BC
        court action, Sun Belt did not achieve its desired result.
        It is therefore using NAFTA Chapter 11 to seek damages of
        "between" $1 billion and $10.5 billion. Besides using the
        investment chapter for very dubious business practices, the
        case raises the fundamental issues of the uses of the
        investment chapter to evade the result of an action in a
        domestic court, and to challenge a non-discriminatory policy
        and legislation by a subnational (provincial) government.

        Pope and Talbot
        The US-based lumber company Pope and Talbot has sued Canada,
        claiming approximately $510 million for alleged breaches of
        the NAFTA investment chapter related to changes in the
        profitability of its timber export business in Canada.
        Softwood lumber exports from Canada to the United States
        have been a source of contention and repeated trade disputes
        for decades. Forest products are among the most important
        exports from Canada, representing billions of dollars in
        export earnings, and over 90 percent of these products are
        exported to the United States. In 1996, in yet another
        attempt to resolve the ongoing timber wars, the Canadian and
        U.S. federal governments signed the Canada-US Softwood
        Lumber Agreement, governing exports of softwood lumber from
        four Canadian provinces, British Columbia, Alberta, Ontario
        and Quebec. The agreement, which will expire at the end of
        March 2001, establishes quotas for exports for each
        province, and requires producers to provide certain
        information regarding exports and pay an export levy if
        their exports exceed their particular quota. In arriving at
        such export agreements, the Canadian government consults
        extensively with industry.

        Pope and Talbot claimed that Canada has breached the NAFTA
        investment requirements regarding national treatment,
        most-favored nation treatment, minimum standard of treatment
        and performance requirements. The company's lawyers are
        critical of the Canadian government for its public release
        of the Notice of Intent to Submit a Claim, calling the
        release a "serious breach of international procedure."

        Pope and Talbot's operations are located in British
        Columbia. During the period of the softwood memorandum, BC's
        share of total softwood exports has declined relative to
        total Canadian softwood exports; Pope and Talbot argue that
        this decline is related to the agreement, and amounts to a
        breach of the NAFTA chapter. (Others point to the loss of
        BC's traditional markets in Asia, related to the Asian
        economic crisis.)

        In an interim award, the tribunal rejected the claim that
        expropriation had occurred, but decided to continue hearings
        on claims relating to national treatment and minimum
        standards of treatment.

        This case is an important indication of how far-reaching the
        impacts of the NAFTA investment chapter are and of how
        broadly multiple governmental powers and decisions may be
        challenged by an individual corporation for a huge
        compensatory claim.

        United Parcel Service
        UPS has filed a notice of intent to sue Canada for $100
        million, alleging that Canada favors the public postal
        service, Canada Post, regarding provision of courier
        services [see "NAFTA's Investor "Rights""].

        Ketcham Investments
        and Tysam Investments
        U.S.-based Ketcham Investments and Tysam Investments jointly
        own West Fraser Mills, a timber company. Ketcham and Tysam
        allege in a December 2000 notice of intent to file a claim
        that their timber quota under the U.S.-Canada Softwood
        Lumber Agreement was arbitrarily cut, denying them rights
        afforded Canadian companies. They are seeking C$10 million
        in damages.

        Suits Against the United States

        Loewen
        The B.C-based Loewen Group is suing for compensation arising
        from alleged discrimination, denial of minimum standard of
        treatment and expropriation, claiming that a $500 million
        Mississippi state court verdict against it amounts to a
        breach of NAFTA. The verdict came in a suit brought against
        Loewen by a Mississippi company, O'Keefe, alleging
        fraudulent practices and other anti-competitive practices.
        Loewen was denied an appeal of the court decision due to a
        state law which requires an appellant to post 125 percent of
        the damage award ($625 million in this case) which Loewen
        could not post. (Loewen eventually settled the claim for
        $175 million.)

        The company seeks to recover $775 million in damages,
        interest and legal expenses through this investor-state
        claim and alleges that the Mississippi decision against it
        was based on anti-Canadian bias. A tribunal has agreed to
        hear the case.

        This case demonstrates, as does Sun Belt, the use by a
        corporation of the NAFTA Investment chapter to essentially
        reverse the results of domestic court proceedings, and to
        circumvent the course of normal commercial civil litigation.
        Having lost to a competitor in the courts, it claims
        compensation from the U.S. federal government.

        Methanex Corp.
        In June 1999, this Vancouver-based company announced that it
        will sue the U.S. government for $970 million due to a
        California order to phase out use of the chemical MTBE
        (methyl tertiary butyl) a methanol-based gas additive, by
        late 2002 [see "NAFTA's Investor "Rights""].

        Mondev
        In September 1999, Mondev International Ltd., a
        Montreal-based real estate development firm, filed a claim
        against the U.S. government for $16 million. The case arises
        from the refusal of the city of Boston to permit it to
        expand a mall into a vacant lot in the 1980s although Mondev
        had a contract with the city. Mondev successfully sued the
        city and its redevelopment authority for $16 million, but
        the court decision was reversed on appeal due to state law
        protecting the redevelopment authority from liability.
        Mondev seeks to recover the damages through the NAFTA
        Chapter 11 investor-state route.

        ADF Group
        ADF, a Canadian fabricator of structural steel for complex
        structures, is suing the United States, seeking $90 million
        in compensation. ADF entered into a contract with Shirley
        Contracting Corporation to provide materials for
        construction of a Virginia highway interchange. ADF sought
        to fabricate products in Canada, using U.S.-made steel. U.S.
        federal government authorities held that this arrangement
        ran afoul of a "Buy America" requirement. ADF proceeded to
        attempt to fulfill the contract using its U.S. facilities
        and subcontracting to other U.S. facilities. It alleges the
        Buy America rules violate Chapter 11 requirements for
        national treatment and for bans on performance requirements.

        Suits Against Mexico

        Metalclad
        This case involves a claim by U.S.-based Metalclad, a
        waste-disposal company, that the Mexican state of San Luis
        Potosi breached Chapter 11 of NAFTA in refusing permission
        for a waste disposal facility.

        The governor deemed the plant an environmental hazard to
        surrounding communities, and ordered it closed down on the
        basis of a geological audit performed by environmental
        impact analysts at the University of San Luis Potosi. The
        study had found that the facility is located on an alluvial
        stream and therefore would contaminate the local water
        supply. Eventually, the governor declared the site part of a
        600,000 acre ecological zone.

        Metalclad sought compensation of some $90 million for
        expropriation and for violations of national treatment, most
        favored nation treatment and prohibitions on performance
        requirements. This figure is larger than the combined annual
        income of every family in the county where Metalclad's
        facility is located.

        In August 2000, a tribunal found that Mexico had breached
        the Investment chapter and awarded Metalclad $16.7 million,
        the amount it had spent in the matter. In this case,
        Metalclad proceeded to begin construction of the facility
        without having local approvals, claiming that it had
        assurances from the Mexican federal government. The case
        raises important questions about whether governments retain
        the authority to enact environmental controls on foreign
        investors and about the powers of local governments.

        The Mexican government has appealed the award to the Supreme
        Court of British Columbia, since hearings of the case were
        held in British Columbia, and the Canadian government and
        government of Quebec have intervened.

        Waste Management Inc.
        This case involves a claim filed in 1998 against the Mexican
        government for $60 million by Waste Management, Inc. It
        concerns an exclusive 15-year concession to its subsidiary
        to provide solid waste management to Acapulco. The company
        claims that it was guaranteed payment by the state of
        Guerrero and the Mexican federal development bank, Banobras,
        and that the obligations have not been met, constituting
        actions tantamount to expropriation.

        Desona/Azinian
        U.S.-based DESONA and its individual investors, Robert
        Zinian et. al. filed this claim for over $14 million and
        costs in 1997 against the Government of Mexico. The claim
        related to a waste management business in Mexico. Desona
        claimed that a long series of unfair and conflicting
        decisions and actions by local authorities contributed to
        its losses, and culminated in the forcible removal of its
        managers from its waste collection and landfill business in
        Naucalpan, a suburb of Mexico City on four days notice.

        The case was dismissed by the arbitral panel in November
        1999, in a scathing decision critical of the company's
        actions and record of dishonesty. However, since the case
        turned on the finding of invalidity of the contract on which
        the claim was based, it does not assist governments and
        citizens regarding the problem of the impact of Chapter 11
        claims on legislative actions.

        Cemsa/Feldman
        This is the first NAFTA investor-state suit involving a tax
        issue. U.S. investor Feldman, sole owner of the corporation
        CEMSA, filed a claim against the Mexican government in May
        1999 for $50 million, alleging that his company was wrongly
        denied excise tax rebates and export rights for its
        cigarette exporting business. Again, allegations of numerous
        irregular actions by Mexican authorities are made, including
        that CEMSA was required to provide invoices from its vendors
        which stated the amount of tax included in the purchase
        price. However, CEMSA claims that the tax authorities did
        not require that manufacturers provide this information, so
        that CEMSA could not comply with the requirement.

        Adams
        This case involves a dispute over title to and use of land
        on which U.S. investors had built vacation homes. A group of
        Mexican landowners won a claim in Mexican courts that the
        disputed land had been illegitimately taken from them by the
        Mexican government, which later authorized its use by the
        U.S. investors. The Mexican Supreme Court ordered the land
        returned to the landowners, and Mexican authorities did
        subsequently return the land, including the vacation homes
        on it. The U.S. investors are seeking $75 million in
        compensation under Chapter 11.

                                               -Michelle Swenarchuk

----------------------------------------------------------------------------

Subscription Information

Annual Subscription Prices:

   * Personal --$25
   * Non-Profit institutions -- $30
   * Business institutions -- $40

Foreign subscriptions:

   * Canada and Mexico -- add $10 to cover first class mail
   * All other countries -- add $15 for airmail

Single copy price

   * $3.00

Send a check or money order to:

Multinational Monitor
PO Box 19405
Washington, DC 20036

Or, if paying by Visa or Mastercard, please include:

   * Card type (Visa or Mastercardh
   * Account number
   * Valid cardholder's signature
   * Card's expiration date

Distributors and bookstores, contact the MM office at (202) 387-8030.
(All funds in U.S. dollars)