The Department of Taxation and Finance has issued advice that the sale of patent drawings, prepared as part of patent applications or litigation presentations, and delivered electronically as PDF files, is not subject to sales tax. Advisory Opinion, TSB-A-12(23)S, (N.Y.S. Dep’t of Taxation & Fin. Sept. 20, 2012). The Department distinguished the drawings at issue from patent drawings delivered by mail as paper printouts, which had previously been held to constitute tangible personal property and found subject to sales tax in Advisory Opinion, TSB-A-97(48)S (Dep’t of Taxation & Fin. July 23, 1997), and determined that the sale of drawings delivered “solely electronically” with no tangible format did not constitute sales of tangible personal property, and was therefore not subject to sales tax. This is consistent with New York’s general approach to the sale of other electronically delivered products, such as e-books.