In 1967, the Minnesota Commissioner of Revenue (defendant) imposed a sales tax on most sales of goods. The Minneapolis Star & Tribune Co. (plaintiff) publishes a morning and evening newspaper in Minneapolis, Minnesota. From 1967 to 1971, it enjoyed an exemption from the sales and use tax provided for Minnesota publications. In 1971, the Minnesota legislature amended its tax scheme to impose a “use tax” on the cost of paper and ink products consumer in production of a publication. The scheme was later amended to exempt the first $100,000 worth of ink and paper consumed in a calendar year. After this exemption was enacted, eleven publishers produced enough paper to incur a tax liability. Minneapolis Star & Tribune Co. (Star Tribune) (plaintiff) was one of the eleven, and paid almost two-thirds of the total revenue raised by the tax. The following year, the Star & Tribune again bore roughly two-thirds of the total receipts from the use tax on ink and paper. The Star & Tribune sued the Minnesota Commissioner of Revenue (defendant) and alleged that the tax improperly burdened its freedom of press. The Minnesota Supreme Court upheld the tax as constitutional. The Star & Tribune appealed to the United States Supreme Court.