Note 10 - Contingencies	3 Months Ended
Mar. 31, 2020
Notes to Financial Statements
Commitments and Contingencies Disclosure [Text Block]	10. Contingencies In the ordinary course of business, the Company is subject to loss contingencies that cover a range of matters. An estimated loss from a loss contingency, such as a legal proceeding or claim, is accrued if it is probable that a liability has been incurred and the amount of the loss can be reasonably estimated. In determining whether a loss should be accrued, the Company evaluates, among other factors, the degree of probability and the ability to reasonably estimate the amount of any such loss. On October 26, 2018, the Company received a subpoena from the New York Attorney General’s Office (“NY AG”) regarding compliance with New York Executive Law § 63 ( 12 ) and New York General Business Law § 349 , as they relate to the collection, use, or disclosure of information from or about consumers or individuals, as such information was submitted to the Federal Communication Commission (“FCC”) in connection with the FCC’s rulemaking proceeding captioned “Restoring Internet Freedom,” WC Docket No. 17 - 108. On December 13, 2018, the Company received a subpoena from the United States Department of Justice (“DOJ”) regarding the same issue. On March 12, 2020, the Company received a subpoena from the Office of the Attorney General of the District of Columbia ("DC AG") regarding the same issue. The Company has been fully cooperating with the NY AG, the DOJ, and the DC AG and is responding to the subpoenas. At this time, it is not possible to predict the ultimate outcome of any of these matters or the significance, if any, to the Company’s business, results of operations or financial position. As such, the Company is unable to make a meaningful estimate of the amount or range of loss, if any, that could result from an unfavorable outcome. On June 27, 2019, as a part of two sales and use tax audits covering the period from December 1, 2010 to November 30, 2019, the New York State Department of Taxation and Finance (the “Tax Department”) issued a letter stating its position that revenue derived from certain of the Company’s customer acquisition and list management services are subject to sales tax, as a result of being deemed information services. The Company disputed the Tax Department's position on several grounds and responded to the Tax Department outlining its position. On January 14 and 15, 2020, the Tax Department issued Statements of Proposed Audit Adjustment totaling $8.2 million, including $2.0 million of interest. The Company formally disagreed with the amount of the Proposed Audit Adjustment and met with Tax Department on March 4, 2020. During that meeting, the Company informed the Tax Department that a majority of the Proposed Audit Adjustment was attributable to revenue derived from transfers which were either excluded resales or sourced outside of New York, and renewed its challenge as to the taxability of its customer acquisition revenue. Since that time, the Company has received revised assessments for amounts less than the previous assessments; however, such assessments are open for further discussion and refinement. Based on the foregoing, the Company continues to believe that it is probable that a sales tax liability may result from this matter, and continues to estimate the range of any such liability to be between $0.7 million and $3.7 million. The Company has accrued a liability associated with these sales and use tax audits at the low end of this range. On January 28, 2020, the Company received a Civil Investigative Demand (“CID”) from the Federal Trade Commission (“FTC”) regarding compliance with the Federal Trade Commission Act, 15 U.S.C. §45 or the Telemarketing Sales Rule, 16 C.F.R. Part 310, as they relate to the advertising, marketing, promotion, offering for sale, or sale of rewards and other products, the transmission of commercial text messages, and/or consumer privacy or data security. The Company has been fully cooperating with the FTC and is responding to the CID. At this time, it is not possible to predict the ultimate outcome of this matter or the significance, if any, to the Company’s business, results of operations or financial position.

10.

Contingencies

In the ordinary course of business, the Company is subject to loss contingencies that cover a range of matters. An estimated loss from a loss contingency, such as a legal proceeding or claim, is accrued if it is probable that a liability has been incurred and the amount of the loss can be reasonably estimated. In determining whether a loss should be accrued, the Company evaluates, among other factors, the degree of probability and the ability to reasonably estimate the amount of any such loss.

October 26, 2018,

the Company received a subpoena from the New York Attorney General’s Office (“NY AG”) regarding compliance with New York Executive Law §

(

) and New York General Business Law §

349

as they relate to the collection, use, or disclosure of information from or about consumers or individuals, as such information was submitted to the Federal Communication Commission (“FCC”) in connection with the FCC’s rulemaking proceeding captioned “Restoring Internet Freedom,” WC Docket

No.

108.

December 13, 2018,

the Company received a subpoena from the United States Department of Justice (“DOJ”) regarding the same issue. On

March 12, 2020,

the Company received a subpoena from the Office of the Attorney General of the District of Columbia ("DC AG") regarding the same issue. The Company has been fully cooperating with the NY AG, the DOJ, and the DC AG and is responding to the subpoenas. At this time, it is

not

possible to predict the ultimate outcome of any of these matters or the significance, if any, to the Company’s business, results of operations or financial position. As such, the Company is unable to make a meaningful estimate of the amount or range of loss, if any, that could result from an unfavorable outcome.

June 27, 2019,

as a part of

two

sales and use tax audits covering the period from

December 1, 2010

November 30, 2019,

the New York State Department of Taxation and Finance (the “Tax Department”) issued a letter stating its position that revenue derived from certain of the Company’s customer acquisition and list management services are subject to sales tax, as a result of being deemed information services. The Company disputed the Tax Department's position on several grounds and responded to the Tax Department outlining its position. On

January 14

and

15,

2020,

the Tax Department issued Statements of Proposed Audit Adjustment totaling

$8.2

million, including

$2.0

million of interest. The Company formally disagreed with the amount of the Proposed Audit Adjustment and met with Tax Department on

March 4, 2020.

During that meeting, the Company informed the Tax Department that a majority of the Proposed Audit Adjustment was attributable to revenue derived from transfers which were either excluded resales or sourced outside of New York, and renewed its challenge as to the taxability of its customer acquisition revenue. Since that time, the Company has received revised assessments for amounts less than the previous assessments; however, such assessments are open for further discussion and refinement. Based on the foregoing, the Company continues to believe that it is probable that a sales tax liability

may

result from this matter, and continues to estimate the range of any such liability to be between

$0.7

million and

$3.7

million. The Company has accrued a liability associated with these sales and use tax audits at the low end of this range.

January 28, 2020,

the Company received a Civil Investigative Demand (“CID”) from the Federal Trade Commission (“FTC”) regarding compliance with the Federal Trade Commission Act,

U.S.C.

§45

or the Telemarketing Sales Rule,

C.F.R. Part

310,

as they relate to the advertising, marketing, promotion, offering for sale, or sale of rewards and other products, the transmission of commercial text messages, and/or consumer privacy or data security. The Company has been fully cooperating with the FTC and is responding to the CID. At this time, it is

not

possible to predict the ultimate outcome of this matter or the significance, if any, to the Company’s business, results of operations or financial position.