V  I  R  G  I  N  I  A:

               IN THE CIRCUIT COURT OF ARLINGTON COUNTY


U.S. NEWS & WORLD REPORT, INC.,      |
                                     |
          Plaintiff,                 |
                                     |
    v.                               |     At Law No. 95-1318
                                     |
RAM AVRAHAMI,                        |
                                     |
          Defendant.                 |

                            RAM AVRAHAMI'S 
                          GROUNDS FOR DEFENSE
                  TO U.S. NEWS & WORLD REPORT, INC.'S
                 AMENDED MOTION FOR DECLARATORY RELIEF

     Responding specifically to the numbered paragraphs of the Amended
Motion for Declaratory Relief filed by U.S. News & World Report, Inc.
("U.S. News"), Plaintiff, Ram Avrahami ("Avrahami"), admits, denies or
avers as follows:
1.   Admitted.
2.   Admitted.
3.   Admitted.
4.   Admitted.
5.   Admitted.
6.   Avrahami lacks knowledge or information sufficient to form a
     belief as to the truth of the allegations of the first sentence of
     Paragraph 6, so the same therefore are denied.  The allegations of
     the second sentence of Paragraph 6 are denied.  
7.   Avrahami lacks knowledge or information sufficient to form a
     belief as to the truth of the allegations of Paragraph 7, so the
     same therefore are denied.
8.   Avrahami lacks knowledge or information sufficient to form a
     belief as to the truth of the allegations of Paragraph 8, so the
     same therefore are denied.
9.   Avrahami lacks knowledge or information sufficient to form a
     belief as to the truth of the allegations of Paragraph 9, so the
     same therefore are denied.
10.  Avrahami admits that he is aware of the existence of the Mail
     Preference Service.  Avrahami lacks knowledge or information
     sufficient to form a belief as to the truth of the remaining
     allegations of Paragraph 10, so the same therefore are denied.
11.  Avrahami admits that he registered his name with the DMA MPS when
     he lived at a previous address and that he did not re-register his
     name when he moved to Arlington, Virginia.  Avrahami lacks
     knowledge or information sufficient to form a belief as to the
     truth of the remaining allegations of Paragraph 11, so the same
     therefore are denied.
12.  Admitted.
13.  Avrahami lacks knowledge or information sufficient to form a
     belief as to the truth of the allegations of Paragraph 13, so the
     same therefore are denied.
14.  Avrahami admits that he has had no contact with Consumer Reports
     regarding the subject matter of this case.  Avrahami lacks
     knowledge or information sufficient to form a belief as to the
     truth of the remaining allegations of Paragraph 14, so the same
     therefore are denied.
15.  Avrahami lacks knowledge or information sufficient to form a
     belief as to the truth of the allegations of Paragraph 15, so the
     same therefore are denied.
16.  Avrahami lacks knowledge or information sufficient to form a
     belief as to the truth of the allegations of Paragraph 16, so the
     same therefore are denied.
17.  Admitted.
18.  Avrahami admits that he accepted U.S. News' offer to subscribe and
     that he intentionally misspelled his name on an order form;
     otherwise, the allegations of Paragraph 18 are denied.
19.  Admitted with the understanding that Avrahani is a misspelling of
     Avrahami, and refers to the same person.
20.  Admitted, except that Avrahami has sued U.S. News to enjoin the
     use of his name.
21.  Admitted.
22.  Avrahami lacks knowledge or information sufficient to form a
     belief as to the truth of the allegations of Paragraph 22, so the
     same therefore are denied.
23.  The allegations of the first sentence of Paragraph 23 are
     admitted.  Avrahami lacks knowledge or information sufficient to
     form a belief as to the truth of the remaining allegations of
     Paragraph 23, so the same therefore are denied. 
24.  Avrahami lacks knowledge or information sufficient to form a
     belief as to the truth of the allegations of Paragraph 24, so the
     same therefore are denied.
25.  Admitted, except Avrahami denies the allegation that he subscribed
     to U.S. News & World Report under a false name (but admits an
     intentional misspelling of his name); further, Avrahami lacks
     knowledge or information to form a belief as to the truth of the
     similarity of the direct mail solicitation, also, alleged in the
     second sentence of Paragraph 25.
26.  Denied.
27.  Denied.
28.  Denied.
29.  Denied.
30.  Denied.
31.  Denied.
32.  All allegations not heretofore specifically admitted are hereby
     denied.

                         Affirmative Defenses

     Avrahami further alleges the following affirmative defenses:

1.   U.S. News' Amended Motion for Declaratory Relief fails to state a
     claim for which relief can be granted.

     WHEREFORE, Plaintiff, Avrahami, asks the Court to dismiss U.S.
News' AMENDED MOTION FOR DECLARATORY RELIEF with prejudice and to award
Avrahami its reasonable attorneys' fees and the costs of this suit.


                              RAM AVRAHAMI
                              By Counsel


BEAN, KINNEY & KORMAN, P.C.
2000 North 14th Street, Suite 100
Arlington, Virginia 22201
(703) 525-4000
(703) 525-2207 (Fax)

By:           /s/
     James Bruce Davis, VSB #13654
     Counsel for Plaintiff