AUTO REPLY

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"The circulation model isn't broken. It's bent a little, but it isn't broke. The parts of the model getting a lot of press, which we too watch, are the parts of circulation where consumers receive the [magazine] without making the financial commitment they make via a traditional year or two-year subscription.

"The magazine publishing industry looks for increasingly creative ways to put magazines into the hands of people. Sometimes, [it's] into the hands of attractive people in ways that our research tells us are pretty effective. But sometimes it's in ways that concern us. In those cases, I and my media team talk directly with the publications, and we come to a meeting of the minds about the total valuation we put on the publication, taking into consideration the different types of circulation they have on their books. That does not mean we automatically discount anything.

"When [magazines] are going to offer up circulation in some of the newer or less traditional methods, I think what they need to do is disclose the details of that circulation very thoroughly, very fully. They need to subject it to audit by ABC, and they need to be prepared to explain to us why we should think that's good circulation. The burden, in my opinion, falls to them to explain why it is attractive. In some cases, they can do a very effective job, in which case we accept it. Sometimes they don't, and we downgrade or reject [it].

"If [magazines] have some circulation that advertisers don't find attractive, and they don't find profitable, and they make a business decision to get rid of it-I am very supportive."

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