Camps Newfound/Owatonna, Inc. (camp) (plaintiff) is a Maine nonprofit corporation that operates a summer camp. The camp has not been profitable in recent years. Maine allows a tax exemption for nonprofit institutions incorporated in the state. However, nonprofit institutions that primarily benefit nonresidents only qualify for a limited tax benefit, if they do not charge more than $30 per person for their services. Ninety-five percent of the camp’s attendees are nonresidents of Maine. Since the camp charges $400 per week for its summer camp, it is not entitled to any tax exemption in Maine. The camp challenges Maine’s tax exemption on grounds that it discriminates against nonresidents in violation of the dormant Commerce Clause.