Amtrak Guest Rewards Program Terms and Conditions
Last updated: December 12, 2019
A. General Membership Guidelines
- Membership is open to all residents of the U.S. and Canada. To become a member ("Member") of the Amtrak Guest Rewards Program (the “Program”), individuals must enroll by visiting Amtrak.com (the "Site") and completing an enrollment form, or by calling 1-800-307-5000. To complete an enrollment, individuals must provide their full name, address, phone number and email address (“Registration Data”). Full name is defined as the given name, middle initial (if any), and surname. You shall be subject to any posted guidelines or rules applicable to these terms and conditions ("T&Cs") posted on this site (subject to routine updates), those obtained by calling 1-800-307-5000, or by writing to Amtrak Guest Rewards, P.O. Box 14368, Philadelphia, PA 19115. Only individuals age 13 and older may enroll via the Internet.
- Members must provide a valid, unique email address upon enrollment. Members may opt in to receive monthly eStatements and offers by email. Only one Program account may be associated with a single email address.
- Members have the option of opting in to receive information and offers via text messaging by updating their profile preferences. Only one Program account may be associated with a single mobile phone number. If there are multiple Members in a household who share a mobile phone number, those Members can choose to receive mobile information and offers associated with only one Program account.
- You agree to (a) provide true, accurate, current and complete Registration Data as prompted by the Program enrollment form, and (b) maintain and promptly update the Registration Data (found in the "My Account" section of the Site) to keep it true, accurate, current and complete. If you provide any Registration Data that is untrue, inaccurate, not current or incomplete, or if Amtrak, in its discretion, suspects that your Registration Data is untrue, inaccurate, not current or incomplete, Amtrak has the right to suspend, terminate, or refuse your current or future use of the Program.
- You agree that creation of a Membership Number, as defined in subsection A6, and/or participation in the Program will represent your acceptance of these T&Cs. Upon our request, you agree to sign a non-electronic version of these T&Cs.
- Members will be provided with a membership number that identifies the individual Member (a “Membership Number”) upon enrollment. The Member should provide the Membership Number when making Amtrak reservations or transacting with Program partners in order to receive points. The Membership Number is unique to each individual Member and is not transferable.
B. Your Conduct
- You agree not to impersonate any person or entity using the Program, and not to upload, post, email, or otherwise transmit any material that contains software viruses, or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment used by the Program.
- You agree not to spam or flood the Site or service, or remove any copyright, trademark, or other proprietary rights notices contained on the Site.
- You also agree not to use any robot, spider, site search/retrieval application, or other manual or automatic device or process to retrieve, index, "data mine," or in any way reproduce or circumvent the navigational structure or presentation of the Site or service or its contents, or otherwise interfere with, or disrupt, the Program or servers or networks connected to the Site, or violate these T&Cs or any requirements, procedures, policies or regulations of the Program, or of any networks connected to it.
- You agree not to intentionally or unintentionally violate any applicable local, state, national or international statutes, regulations, regulatory guidelines and judicial or administrative interpretations, or any rules or requirements established by Amtrak (all of which shall constitute "Applicable Law") in connection with your use of the Program.
C. Rules for Earning Amtrak Guest Rewards Points
- Only one Program account will be allowed per individual. In the event that more than one account number is assigned to the same Member (duplicate accounts), only the applicable point credit, excluding any enrollment bonus in the duplicate account, can be transferred to the original account. Duplicate accounts and/or points earned or purchased not in accordance with Program Terms and Conditions will be canceled upon notification from the Member or at Amtrak's discretion.
- From time to time, potential Members may be offered the opportunity to earn bonus points for enrollment. This bonus may be based on enrollment method or on a source enrollment promotion code that must be provided during the enrollment process. Only one enrollment bonus will be allowed per individual Member.
- A Member may receive points only for his/her own travel and will not receive points for trips purchased by the Member, but not traveled personally by the Member. Points can be accumulated only once for each trip, regardless of the number of seats purchased. Accrued points, reward trips and coupons have no monetary value and do not constitute property of the Member.
- Points will not be awarded for travel on tickets issued as reward travel from Amtrak or on travel purchased through auction/discount portals such as eBay. Points will not be awarded for tickets purchased with an Amtrak Transportation Voucher. If a ticket is partially paid for with a Transportation Voucher, then the portion funded by the Transportation Voucher will not earn points; however, the remaining value of the ticket purchased will earn points.
- Except as provided in this Section, Members who provide their Membership Number at the time of ticket purchase will earn 2 points for every $1 spent on Amtrak travel. Members will earn an additional 25% point bonus for qualifying Business class travel and an additional 50% point bonus for qualifying Acela First class travel. If a free One-Class Upgrade coupon is applied to a reservation, Member will be eligible for the point bonus associated with the original class of service, not the upgraded service. To receive points for Amtrak travel, the Member must provide his/her Membership Number at the time of making reservations and the passenger name must match the Member name. For travel on Amtrak that occurs prior to a Member's enrollment date, points will be awarded, upon request, only for travel that occurs within 21 days prior to the Member's enrollment date. Members may earn points for one train ticket used on a single train or individual train number on a single day. Additional tickets for the same train or individual train number, on the same day, will not earn points.
- To resolve point discrepancies, Members must contact the Amtrak Guest Rewards Service Center in writing within 60 days following the transaction in question by mail or using the Contact Us form. Members must provide Amtrak with sufficient written documentation of the transactions in question. Written requests must also include the Member's name, Membership Number, address, and daytime telephone number. Submit written requests to: Amtrak Guest Rewards, P.O. Box 14368, Philadelphia, PA 19115. In the case of a dispute regarding points, Amtrak's decision will be final.
- Points will be credited to a Member's account within 3 weeks after the completion of the Member's Amtrak trip. Points for 8000-series Thruway service travel may take up to 90 days to be credited. Members should retain their Amtrak ticket stubs or reservation confirmation until the points for their travel appear in their Program accounts.
- If the Membership Number was not included when the Member made the reservation, retroactive credit may be requested within 120 days of travel. The Member may request retroactive credit online using the Missing Points Request Form. The Member may also request retroactive credit by contacting the Amtrak Guest Rewards Service Center by mail at the addresses in Section C.6 or using the Contact Us form. Points will not be awarded for travel on Amtrak made without a Membership Number using unreserved tickets unless the unreserved ticket has the Member's name on the eTicket or ticket stub. If a Member purchases a ticket for Amtrak travel on board an Amtrak train, the Member may request retroactive credit by contacting the Amtrak Guest Rewards Service Center by mail at the addresses in Section C.6 or by using the Contact Us form.
- Members may have the opportunity to earn points by purchasing products or services from Program partners. Program partners, partner offers and partner locations are subject to change without notice, and Amtrak assumes no responsibility for partner changes or for informing Members of changes. Points earned through transactions with Program Partners will typically be awarded within 6 weeks.
- Additional Exclusions. To earn points for Amtrak travel, the Member must travel on Amtrak using an Amtrak ticket. Members will not earn points for travel on Amtrak using a ticket issued by a carrier other than Amtrak. Members will not earn points for a step-up ticket paid to Amtrak from other carriers for use on an Amtrak train. Neither the originating carrier's pass nor the step-up amount paid to Amtrak is eligible to earn points. Members will not earn points for tickets purchased with discounted group fares. Members will not earn for Amtrak 7000-series Thruway services or the Canadian portion of joint Amtrak/VIA Rail Canada services.
D. Point Expiration
- Subject to these Program Terms and Conditions, points earned under the Program will not expire as long as the Program continues and the Member’s Program account is active. “Active” means that the Member earns and/or redeems Program points using his or her Membership Number within a 24-month period.
- If no Member initiated qualifying activity is recorded or reported within 24 months, your points will expire. You can view all point and travel activity in the "My Transactions" section of My Account on this site.
E. Claiming Rewards
1. Members may redeem points for Amtrak travel rewards at Amtrak.com or by calling the Amtrak Guest Rewards Service Center. To redeem points for travel on Amtrak, a Member must reserve and obtain the ticket prior to the train departure time. Members may not redeem points for Amtrak 7000-series Thruway services or the Canadian portion of joint Amtrak/VIA Rail Canada services.
2. In order to redeem points for items other than Amtrak travel, upgrade coupons or lounge passes, a member’s account must show at least one point-earning transaction from a paid Amtrak ticket.
3. Amtrak travel reward trips may be modified or canceled by the Member if applicable based on the fare rules associated with the ticket. Points will not be refunded if the redemption trip is not cancelled prior to the time of departure ("no-show"). All modifications to trips purchased with points are subject to availability and point/monetary penalty. Cancellations of such trips are subject to applicable point penalty. Points cannot be combined with cash for an upgrade in service. If the ticket has been printed (not an eTicket), the unused ticket must be returned to the Amtrak Guest Rewards Service Center at the address set forth in Section C.6 if eligible for refund or exchange. If the ticket has not been printed or is an eTicket, the cancellation may be made by phone with the Amtrak Guest Rewards Service Center or online at Amtrak.com.
4. If a Member needs to exchange tickets due to a disruption in service, Amtrak will book the Member on the next available train at the same level of service if available. If only a lower level of service is available, and the Member agrees to accept that lower level of service, the difference in points will be deposited in the Member's Program account upon request from the Member.
5. Blackout dates may apply to some offers and promotions including One-Class Upgrade coupons and free companion fare coupons. All Amtrak travel rewards are subject to reward seat availability and may not be available on all trains.
6. Member is responsible for maintaining a point balance of zero or greater at all times. Members must have sufficient points posted to their Program accounts to redeem points for the Program Reward of their choice. Points cannot be combined with cash or with another Member's points to obtain a Program Reward. Amtrak reserves the right to limit the quantities of Program Rewards redeemed by a single Member in a given time period.
7. Amtrak is not responsible for any products or services offered by other companies participating in the Program ("Program Merchants"). Program Merchants are solely responsible for the quality and performance of the goods or services supplied. Any rules of the Program Merchants relating to returns and exchanges apply, but no points will be re-credited to a Member's Program account. Use of the Program does not, in any way, indicate that Amtrak recommends or endorses any Program Merchant, regardless of whether the Program Merchant participates in the Program.
8. Amtrak Guest Rewards non-Amtrak travel gift cards will be sent via the U.S. Postal Service and will typically arrive within 2 weeks. If a non-Amtrak travel digital gift card is selected, it will typically be electronically delivered within 3-7 days. Gift cards are not returnable or refundable and cannot be redeemed for cash and cannot be bartered or sold. Gift cards are governed by the specific rules, conditions, blackout dates and expiration dates shown on or associated with each and are subject to change without notice. Amtrak is not responsible for lost, stolen, damaged, misdirected or misplaced gift cards. Unless otherwise noted in the Program materials, Program Rewards do not include incidental charges such as food, beverages, taxes, service or other charges.
9. Members with Amtrak Guest Rewards Select, Select Plus or Select Executive status may redeem their points with participating point transfer partners. Current Amtrak Guest Rewards Select or Select Plus Members may redeem up to 50,000 Amtrak Guest Rewards points per calendar year with participating point transfer partners. Current Amtrak Guest Rewards Select Executive Members are not subject to point limits when redeeming their points with participating point transfer partners.
10. You must be a member of the partner's program in which you are transferring Amtrak Guest Rewards points to and abide by that program's rules and regulations in order to exchange points to their currency.
F. Amtrak Guest Rewards Conditions
- Amtrak may, in its discretion, cancel, modify, restrict, or terminate the Program or any aspects or features of the Program at any time without prior notice. Updated Program rules will be available at Amtrak.com. Any change in the Program will apply to unredeemed points as well as points Members may earn in the future.
- In accumulating points or Program Rewards, Members may not rely upon the continued availability of any Program Reward and Members may not be able to obtain all offered Program Rewards for all destinations or trips. Amtrak and its partners have the right to change, limit, modify, or cancel Program rules, regulations, rewards, and reward levels at any time. That includes, without limitation, increasing the levels or number of points required for a Program Reward, changing Program Rewards, reducing the number of seats available for Program Rewards on Amtrak trains, adding blackout dates, limiting rooms available for a Program Reward at any participating hotel, changing locations served by Amtrak or its partners, changing or canceling the Program Rewards offered by Program Merchants, or changing or canceling partner participation in Amtrak Guest Rewards. Program rules may change due to changes in Program Merchant rewards programs. Redemption of all Program Rewards is subject to availability. In the event that any of these conditions occur, Members may not be able to obtain certain Program Rewards. Amtrak assumes no liability for these changes. Some Amtrak train or bus services, such as special excursions, may be excluded from Program Reward availability at Amtrak's discretion.
- Earnings of points and redemption of Program Rewards may be subject to income or other taxes. Members are responsible for taxes, if any, due on points or Program Rewards.
- If, in their sole discretion, Amtrak or its partners suspect fraud, misrepresentation, abuse, or violation of applicable rules involving points or Program Rewards use, Amtrak and its partners have the right to take appropriate administrative and/or legal action, including the cancellation of accumulated points and Program Rewards, and termination of Program participation.
- If Amtrak and/or any Program partner or Program Merchant improperly denies a Member point credit, Program Rewards, or some other benefit, the Member's exclusive remedy shall be the issuance of the improperly denied credit, Program Reward or benefit, if available, or such other comparable benefit as determined by Amtrak, which shall have no additional liability whatsoever.
- The Program is subject to all applicable laws and regulations and the redemption of Amtrak rewards is void where prohibited by law. The sale or barter of any Program Reward or other reward offered through the Program, other than by Amtrak, is expressly prohibited.
- Amtrak reserves the right to make promotional offers selectively available to Members, based on travel activity, geographic location, Program participation, or other factors.
- Accrued points are not transferable in the event of Member death or divorce. All points are subject to all other Program rules. Once points have expired in accordance with the Program rules, they will not be reinstated.
- Each Member shall be responsible for advising Amtrak of any changes of name, address, email, or any other profile information.
- Except as otherwise provided, the Program is only open to individual participants and not corporations or businesses. Pooling of points or using another individual's account is considered fraudulent and may result in the loss of all points.
- AMTRAK MAKES NO WARRANTIES OR REPRESENTATION EITHER EXPRESSED OR IMPLIED, AND EXPRESSLY DISCLAIMS ANY AND ALL LIABILITY AND DAMAGES (INCLUDING DIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL, OR PUNITIVE DAMAGES) WITH RESPECT TO TYPE, QUALITY, OR FITNESS OF GOODS OR SERVICES PROVIDED THROUGH THIS PROGRAM.
- Amtrak is not responsible for requests or correspondence lost or delayed in the mail. Amtrak also reserves the right to correct errant Program point values represented on statements or the Site. Amtrak reserves the right to adjust Point values at its sole discretion.
- Each Member is responsible for remaining knowledgeable as to the Program terms and conditions and as to the number of points in his or her account. Neither Amtrak nor Program Merchants will be liable for any of the following: incorrect or inaccurate transcription of entry information; problems related to any of the equipment or programming associated with or utilized by the Member; any human error; any interruption, deletion, omission, defect, or line failure of any telephone network or electronic transmission; problems relating to computer equipment, software, or inability to access the Site; any other technical or non-technical error or malfunction; lost, late, stolen, illegible, incomplete, garbled, misdirected, mutilated, or postage due mail, or other mail for whatever reason.
- Notices to Members may be made via either email or regular mail to any address in a Member's account profile or other information that such Member has provided to Amtrak in connection with the Program. Members also may be notified of changes to these T&Cs or other matters on Amtrak.com.
- All terms and conditions are subject to change. Amtrak reserves the right to alter or cancel the Program at any time.
- All interpretations of Program terms and conditions shall be at the sole discretion of Amtrak.
- These T&Cs and the relationship between Members and the Program shall be governed by the laws of the District of Columbia without regard to its conflict of law provisions. Each Member agrees to submit to the personal and exclusive jurisdiction of the federal courts located within the District of Columbia.
- The failure of Amtrak to exercise or enforce any right or provision of these T&Cs shall not constitute a waiver of such right or provision.
- Each Member represents that such Member is of sufficient legal age to use the Program and to create binding legal obligations for any liability such Member may incur as a result of such Member's use of the Program.
- Claims of Copyright Infringement. The Digital Millennium Copyright Act of 1998 (the "DMCA") provides recourse for copyright owners who believe that material appearing on the Internet infringes their rights under U.S. copyright law. If you believe in good faith that materials hosted by Amtrak or one of its subsidiaries infringe your copyright, you (or your agent) may send Amtrak a notice requesting that the material be removed, or access to it blocked. If you believe in good faith that a notice of copyright infringement has been wrongly filed against you, the DMCA permits you to send Amtrak a counter-notice. Notices and counter-notices to Amtrak must meet the then-current statutory requirements imposed by the DMCA. Notices and counter-notices with respect to the Site should be sent to:
Amtrak Law Department
Copyright DMCA Complaint
1 Massachusetts Avenue, NW
Washington, DC 20001
- We suggest that you consult your legal advisor before filing a notice or counter-notice. Also, please be aware that there can be penalties for false claims under the DMCA.
- Links to Other Websites. The Site may contain links to other Internet websites or resources. Amtrak neither controls nor endorses such other websites, nor has Amtrak reviewed or approved any content that appears on such other websites. You acknowledge and agree that Amtrak shall not be held responsible for the legality, accuracy, or inappropriate nature of any content, advertising, products, services or information located on or through any other websites, nor for any loss or damages caused or alleged to have been caused by the use of, or reliance on, any such content.
- Indemnification. You agree to indemnify, defend and hold Amtrak, its officers, directors, employees, agents and representatives harmless from and against any and all claims, damages, losses, costs (including reasonable attorneys' fees), or other expenses that arise directly or indirectly out of or from (a) your breach of this Agreement; (b) any allegation that any materials that you submit to Amtrak or transmit to the Site infringe or otherwise violate the copyright, trademark, trade secret or other intellectual property or other rights of any third party; and/or (c) your activities in connection with the Site or any services related to the Site.
- Disclaimers. THE SITE, THE MATERIALS ON THE SITE, AND ANY PRODUCT OR SERVICE OBTAINED OR ACCESSED THROUGH THE SITE ARE PROVIDED "AS IS" AND WITHOUT REPRESENTATIONS OR WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, AMTRAK, ITS OFFICERS, DIRECTORS, EMPLOYEES, AFFILIATES, SUPPLIERS, ADVERTISERS, AND AGENTS DISCLAIM ALL WARRANTIES, EXPRESS, IMPLIED OR STATUTORY, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF TITLE, NON–INFRINGEMENT, MERCHANTABILITY, AND FITNESS FOR A PARTICULAR PURPOSE, AND ALL WARRANTIES RELATING TO THE ADEQUACY, ACCURACY OR COMPLETENESS OF ANY INFORMATION ON THE SITE AS IT RELATES TO THE PROGRAM. Applicable law may not allow the exclusion of implied warranties, so the above exclusions may not apply to you. AMTRAK AND ITS AFFILIATES, SUPPLIERS, AGENTS AND SPONSORS DO NOT WARRANT THAT YOUR USE OF THE SITE WILL BE UNINTERRUPTED, ERROR–FREE, OR SECURE, THAT DEFECTS WILL BE CORRECTED, OR THAT THE SITE OR THE SERVER(S) ON WHICH THE SITE IS HOSTED ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. YOU ACKNOWLEDGE THAT YOU ARE RESPONSIBLE FOR OBTAINING AND MAINTAINING ALL TELEPHONE, COMPUTER HARDWARE, AND OTHER EQUIPMENT NEEDED TO ACCESS AND USE THE SITE, AND ALL CHARGES RELATED THERETO. YOU ASSUME TOTAL RESPONSIBILITY AND RISK FOR YOUR USE OF THE SITE AND YOUR RELIANCE THEREON.
- Aspects of the Amtrak Guest Rewards Program are covered by one or more of the following patents: U.S. Patent No. 5,774,870; U.S. Patent No. 6,009,412; and U.S. Patent No. 6,578,012
G. Select, Select Plus, Select Executive Membership
- Select, Select Plus, or Select Executive membership status is an extension of the Amtrak Guest Rewards Program. All terms and conditions for the standard Amtrak Guest Rewards Program apply to Select, Select Plus and Select Executive membership.
- Select membership is automatically achieved by earning 5,000 Amtrak Guest Rewards Tier Qualifying Points (TQPs) during a calendar year. Select Plus membership is automatically achieved by earning 10,000 Amtrak Guest Rewards TQPs during a calendar year. Select Executive membership is automatically achieved by earning 20,000 Amtrak Guest Rewards TQPs during a calendar year. TQPs are the base points you earn for traveling on Amtrak using your membership number and through special promotions. Amtrak may offer the ability to earn TQPs through non-travel promotions. Each member may earn a maximum of 4,000 TQPs by non-travel means per year.
- Select, Select Plus and Select Executive benefits and qualification requirements may change from year to year. Select/Select Plus/Select Executive benefits are subject to availability.
- In order to receive Select/Select Plus/Select Executive benefits, the Select/Select Plus/Select Executive Member is responsible for providing his/her Amtrak Guest Rewards Select/Select Plus/Select Executive membership card or membership number when required.
- Tier Bonus Points: Select Members will earn an additional 25% on base Amtrak travel points awarded. Select Plus Members will earn an additional 50% on base Amtrak travel points awarded. Select Executive Members will earn an additional 100% on base Amtrak travel points awarded. For example, for every four points earned, one extra point will be awarded for Select, two extra points will be awarded for Select Plus, and four extra points will be awarded for Select Executive. Bonus points apply only to points earned directly through Amtrak travel and will not be awarded on points earned through Program partners, points purchased through Program partner rewards or Amtrak bonus points.
- Members can belong to only one membership level at any given time; Members cannot be Select, Select Plus and Select Executive, or any combination, at the same time, and can earn either the Select, the Select Plus or the Select Executive point bonus on travel, based on tier qualification, but not multiple bonuses.
- All partner offers are subject to the partner's own terms and conditions.
- Amtrak and its partners reserve the right to change, modify or terminate the Select, Select Plus or Select Executive membership tier or any of its benefits at any time, with or without notice.
H. Buy/Gift Points
- You may purchase points for yourself or purchase points to give to another Amtrak Guest Rewards Member. These points are referred to as “Buy/Gift Points.” Buy/Gift Points are sold by Points.com.
- To purchase points, you must have your Amtrak Guest Rewards member number, the recipient's Amtrak Guest Rewards member number (if applicable), and a valid credit card accepted by Points.com.
- Buy/Gift Points can be purchased in increments of 500 points, and each Member may buy or receive up to a total of 30,000 points in a calendar year. Select Executive Members are not subject to limits on the number of points they may buy or give.
- Buy/Gift Points will typically be posted to your account or the account of the recipient the same day as purchased, however please allow up to 72 hours for transactions to complete.
- Buy/Gift Points do not count toward Select, Select Plus or Select Executive status for the purchaser or the recipient.
- Buy/Gift Points purchases are sold in U.S. Dollars. In the event that payment for Buy/Gift Points is not received, Amtrak reserves the right to cancel such points.
- Payments for Buy/Gift Points are not refundable and not exchangeable.
- The purchase of points and gifts of points are final.
- Any points transferred through this agreement may not be conveyed to persons engaged in the sale, direct or indirect of points or arranging for the sale of such points.
- Purchases from Points.com may be subject to additional terms and conditions between you as the purchaser and Points.com. Such terms and conditions, if any, will be displayed on the Points.com website at the time of purchase. Amtrak is not a party to any such terms and conditions.
I. Share Points
- You may transfer points from your account to the account of another Amtrak Guest Rewards Member. These points are referred to as “Share Points”.
- To share points, you must have your Amtrak Guest Rewards member number and the recipient's Amtrak Guest Rewards member number.
- Points can be shared in increments of 1,000 points. You may not share more than 100,000 points total in a calendar year. Select Executive Members are not subject to limits on the number of points they may share.
- Share Points are typically posted to the recipient's Amtrak Guest Rewards account the same day, however please allow up to 72 hours for points to appear in the recipient’s account.
- Share Points do not count toward Select, Select Plus or Select Executive status for the recipient.
- You will be charged $0.01 USD per point transferred. GST/HST and/or other applicable taxes apply to residents in Canada. Amtrak retains the right to transfer points back to the original account if the payment is not received.
- Payments for Share Points are not refundable and not exchangeable.
- All Share Points transactions are final. Once a transaction is complete and payment is received, the points will not be re-deposited to the original account under any circumstance.
- Any points transferred through this agreement may not be conveyed to persons engaged in the sale, direct or indirect of points or arranging for the sale of such points.
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