In an Advisory Opinion, TSB-A-15(20)S (N.Y.S. Dep’t of Taxation & Fin., May 26, 2015), the New York State Department of Taxation and Finance has ruled that a Drop Ship Master (“DSM”) service provided to major retailers in the Internet retail industry is the provision of a nontaxable service and not the provision of taxable “telephony and telegraphy.” The DSM service involved connecting e-commerce retailers, called “Merchants,” with third-party manufacturers and distributors, called “Suppliers,” who fulfill Merchants’ customer orders. While the DSM service included receiving, processing, translating, and relaying order and inventory-related data between the parties, the primary value of the service was found to be the processing of the messages. The Department distinguished the result from that in Matter of Easylink Servs, Intl., Inc. v. New York State Tax Appeals Trib., 101 A.D.3d 1180 (3rd Dep’t 2012), concluding that in Easylink the primary function of the service at issue was the transmission of messages, while the primary function of the DSM service was the data processing aspect.