tax sale after he was alerted by one of the occupants. Though the Commissioner argued that even those additional steps were burdensome, the Court countered that it had instead undertaken "the burden and expense of purchasing a newspaper advertisement, conducting an auction, and then negotiating a private sale of the property." The Court considered the assertion of burden further undermined by the requirement in Arkansas that notice to homestead owners be accomplished by personal service if certified mail is returned, and the fact that Arkansas transfers the cost of notice to the taxpayer or the tax sale purchaser, The Commissioner offered no estimate of how many notice letters are returned, and the Court believed that nothing supported the dissent's assertion that the Commissioner must physically locate "tens of thousands of properties every year." The Court also disagreed with the U.S. Solicitor General's argument that requiring further effort when the government learns that notice was unsuccessful would cause the government to favor methods "that do not generate additional information," such as relying entirely on regular mail instead of certified mail. The Court considered this unlikely because the government is always being asked to prove that notice is sent and received, and the documentation that certified mail provides gives the State protection against false claims that notice was never received. The Court noted that this protection "comes at a price—the State also learns when notice has not been received," information that under the circumstances of this case, the State cannot simply ignore. The Commissioner also argued that further measures were not required because Jones had a legal obligation to keep his address updated, that he was on inquiry notice after failing to receive a tax bill and pay his property taxes, and that he was obliged to ensure that the occupants of his property would alert him if it were in jeopardy. Though acknowledging that Jones should have been more diligent regarding his property, the Court rejected that any of those conditions could amount to a forfeiture of his due process right to receive adequate notice. The method of certified mail furthermore made it impossible for the occupant to notify Jones, because only Jones could have signed for the letter. The Court clarified that it was not its responsibility to dictate what form of service that the government should adopt, or to attempt to redraft a State's notice statute. Instead, "[t]he State