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Evaluating Charlton's Statements of Ownership

Tuesday, February 5, 2013

by John Jackson Miller


The first volume of Two Morrows' American Comic Book Chronicles series releases this week: the 1960-64 edition, written by John Wells and edited by Keith Dallas. (A 1980s edition is due in March.) The series is not affiliated with The Comics Chronicles, but having looked through the copy I've received, I'm happy to endorse the work. The volume provides an in-depth year-by-year look into comic book publishing and fandom. It's a fascinating book. My one regret is they got to publish it first!

Wells brings together a lot of data points about comic-book circulation, including some from this site — enough that the ACBC includes a disclaimer up front about the accuracy of the data included in the postal statements that appeared in the backs of comics. (Click to learn more about Statements of Ownership, Management, and Circulation.) One proviso is certainly apt: as soon as publishers began relying on affidavit returns rather than actual returns of unsold or stripped copies from distributors, they became dependent upon the distributors to report that information in a correct and timely manner.

We know that often, that information was not reported in a timely manner. That is why I have implored readers to never, ever place any weight on the column known as "nearest issue to filing date," which began being reported in the mid-1960s. Since publishers didn't have all the information about returns, the number of returned copies is often lower than the average figure for the year — and the sales, thus, appear higher than the average for the year. I can't tell you how many comments and posts I've read over the years from people who looked at the "closest issue" data and wrongly concluded that a comic book was improving in sales.

It can happen, especially if some big event happened or some famous creator joined a title in the latter part of the year. But the truth usually is the "closest issue" data is simply incomplete, and often by a wide margin.

The 1967 Statement in Heart Throbs #112
As an example, see DC's Heart Throbs #112 statement at right, reporting the title's 1967 sales. The print run on the "nearest issue" was 11,000 copies higher than the average for the year, but the number of returns was nearly 19,000 copies lower than average. The average copy had a sell-through of 50%; the most recent issue had a sell-through of nearly 57%. The returns simply weren't complete yet.

Is the Nearest Issue column more accurate today? Possibly — and at least now, Archie reports which "nearest issue" it's speaking about. The information about print runs, subscription copies, and free copies would certainly be known to the publisher. But especially as we're comparing like against like, I would strongly recommend ignoring the "nearest issue" data — or even reporting it, given how often I have seen it confused online with the average figures. I have what is likely the world's largest database of these figures, and I don't include "nearest issue" material anywhere.

Getting back to the ACBC caution, Wells remarks that affadavit returns represented an "honor system" for distributors to accurately report what comics they hadn't sold — and certainly, that system was often dishonored. The Mile High II collection, for example, consisted of millions of copies that a distributor claimed went unsold — but instead of being destroyed, they went instead went to a warehouse, where years later Chuck Rozanski found them. Many of the bagged comics that weren't packaged by Whitman likely collected some of these unstripped copies, which had been falsely reported as destroyed.

So just as the Statements would have inflated "nearest issue" sales figures because of delayed information, false affidavit returns would have had the effect of over-reporting returns — thus depressing the sales figures the publishers saw. And that effect would have gone on all year, impacting the "average monthly sales." Put another way, the nature of the distribution system made recent comics seem like they were selling better than they were, but depressed sales to some degree throughout the year. How much impact did the latter have? We'll likely never know. But many of those illicit copies really were sold, even after a long wait.

Dick Giordano, by Michael Netzer
Wells also mentions Dick Giordano's caution about the Statements that "at Charlton, they just made them up." Giordano said it in 1998 in Comic Book Artist #1, but his comments about Charlton's practices appeared far earlier. (I think I may have even read it in a 1970s issue of The Buyer's Guide for Comic Fandom, but I'm not sure.) As I've now compiled more than 3,300 Statements with circulation data, I'm in the unusual position of being able to look at everything at once, which permits me to spot some patterns.

The Statements are filings required by federal law — and were, in the early 1960s, notarized; falsifying them is definitely a wrongdoing. At the same time, some perspective is helpful. Publishers only filed the Statements in order to get to mail their subscription copies at Second Class postage rates: they had to prove they were sending magazines to requestors, and not advertising catalogs to people that didn't want them. (In a similar way, consumers today are running into the Postal Service's Media Mail requirements, which have lately barred the shipment of comics on the grounds they contain advertising material.) And some publishers barely made use of their permits at all. Correctly or not, Charlton routinely reported 30 or fewer subscribers for most of its titles; Harvey, often, less than 10. That's not surprising for publishers that rarely ran subscription ads. The only way anyone knew how to subscribe was to read the indicia!

So there's little doubt the survival of its Second Class permit was of marginal concern to Charlton. And it should also be said that during Giordano's tenure there — which ended when he went to DC in April 1968 — many publishers didn't really understand what the government wanted to see. Publishers were required to report their Average Monthly Sales beginning in 1960, but that hit some road bumps:

• For 1963 and 1964, DC ran Statements without sales figures — except for a handful of titles: Aquaman, Atom, Sea Devils, and Young Romance. I haven't got the slightest idea why those four titles ran data. For 1965, DC ran a set of Statements without figures in the April-May 1966 issues, but someone must have complained, because a corrected set ran in its August 1966 issues.

Magnifying glass time: Just Married #19
Harvey also did not report sales in many of its Statements, from 1963 to 1970 — although they did appear in some titles. Richie Rich ran figure-less statements; Sad Sack had numbers in its main title but not in its ancillary titles' Statements. Again, I suspect they had so few subscribers that no one cared to get it right or to complain.

• The Dell titles that transitioned to Gold Key reported only their subscription sales for 1962, not their total sales. Dell got it right in the titles it kept. I assume the transition led to a miscommunication.

• And many, many Charlton Statements are simply illegible, particularly in the early part of the 1960s. The 1960 figure in Masked Raider #29 is just an ink smudge on my physical copy. John Lustig managed to help decipher the First Kiss statements by looking at the actual plates. In later years, when more categories were being reported, you can sometimes use arithmetic to decipher the numbers, but in these early years, that's not an option. (Charlton isn't the worst offender, by the way — well into the 1970s, Fawcett was running its Dennis the Menace forms reduced to two inches wide, taking the place of a single comic book panel. Yeesh!)

Dennis #161: A truly buried Statement!
So in the 1960s, publishers were still feeling their way through with this new mandate. But while I have no reason to doubt Giordano's memories about Charlton, I am reluctant to apply it to other publishers, or to Charlton after Giordano's time there. And I find myself wondering about some other years.

Again, seeing all the data at once, across time, leads to some impressions. Charlton's reported sales were wildly lower than anyone else's in the 1960s; I have now collected 22 Charlton Statements for 1960, for example, and all range from a high of 133,000 copies to a low of 92,000 copies. That puts the whole line beneath all but one of the 96 other titles I have found 1960 data for. (My old 1960 page is here; yes, my long-delayed update will almost triple the known list.) Charlton's distribution penetration was known to be much worse than its competitors, but certainly, at a glance, these figures seem very low.

But, in 1959, Charlton claimed to its advertisers sales of 5 million copies every two months; we read that in the N.W. Ayer guide from 1960. And here's the rub. The 22 known 1960 Statements add up to 2.6 million copies every 2 months; and there are another 20 more Charlton titles I suspect Statements exist in. So if they were making numbers up in the Postal Statements in 1960, they all still added up to the sum Charlton was claiming to its advertisers — a figure which was embarrassingly low. That lends at least the 1960 figures a little credence, to my thinking.

The 1967 Statement from Cheyenne Kid #67
My guess is Giordano was referring more to the mid-1960s, when as executive editor he was placing the publisher's Statements in titles; I don't have any similar overall figures from Charlton in that period to check them against. There are some seemingly random shifts in Charlton titles — major moves both up and down in the same genre in 1967, for example — which would be right when Giordano was there. Teen-Age Love was reported as Charlton's best-seller in the year with 152,000 copies of each issue sold on average — beating out sister romance titles by as much as 40,000 copies. The title dropped more than 20% in reported sales in 1968, then picked it all right back up in 1969. I haven't canned the data through something that would spot randomness yet, but I'm inclined to believe this is when Giordano was speaking of.

At a glance, at least, the 1970s Charlton data seems more settled, tending to move up and down — mostly down — at a pace that's more in line with the rest of the market. It'll take some more research to know for sure. But publishers were used to filing the forms by then, and we tend to find fewer mistakes in the forms as time went on (math errors, wrong Statements being run). And I have seen enough internal data from the 1980s and later from major publishers that tracks with the Statement data to believe that they are, in general, reliable — with the trendlines across time, even within the subcategories, tending to be less herky-jerky.

So I second the ACBC's caution regarding Statements to a degree — and particularly, regarding Charlton during the mid- and late-1960s. But I also remain confident that the bulk of what was reported — including some of the data from Charlton — is based on facts known to the publishers at the time, allowing that some of those facts were incompletely known. There's enough uniformity in data compiled and filed by multiple different representatives of companies over the years that Occam's Razor comes into play. They're much more likely to be based on something rather than nothing. Giordano's statement is an important piece of the historical puzzle, but I'm not really finding the practice he describes was endemic to the business.

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