In a ruling by the Virginia Tax Commissioner, it was stated that the industrial manufacturing exemption does not apply to imaging activities. A company whose primary business activity was to image paper documents and microfiche into source documents via CDs and tapes was subject to tax on their purchase of machinery, tools, supplies and power used in the process. The ruling stated that the imaging process does not result in the creation of a new product and is only changing the form of the material, not content. The conversion of data was considered “fabrication” under Virginia law and was taxable as such. (Virginia Ruling of Commissioner, P.D. 05-2, January 19, 2005)