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Mr. Van B. Cook Acting County Attorney Pinellas County 315 Court Street Clearwater, Florida 33516

Dear Mr. Cook:

This is in response to a request by your predecessor for an Attorney General's Opinion on the following question:

IF A PUBLICATION IS ENTERED OR QUALIFIED TO BE ADMITTED AND ENTERED AS SECOND CLASS MATTER AT A POST OFFICE IN THE COUNTY WHERE PUBLISHED, FOR SALE TO THE PUBLIC GENERALLY, AND OTHERWISE MEETS THE QUALIFICATIONS OF CH. 50, F.S., RELATING TO LEGAL AND OFFICIAL ADVERTISEMENTS, DOES IT MEET THE DEFINITION OF "NEWSPAPER" IF IT CONSISTS ENTIRELY OF ADVERTISEMENTS, SUCH AS…