The booklet that I received from Delta, along with the letter stating my penalty, states: "For your reference, a copy of the current Delta SkyMiles Memerbership Guide and Program Rules is enclosed."

On page 36, under Award Transfer: "The sale, purchase, assignment or barter of Delta SkyMiles Award Travel Certificates and Tickets has been held to be illegal."

The manual you linked me to reads differently: No longer is it HELD to be illegal, it IS illegal! But how did Delta come up with this determination? When I last checked, Utah was the only state which barred the selling of miles.

Delta can claim anything they want - some court will have the final say. I find it amusing that Delta can make the assertion that this practice is illegal for ME to engage in, yet THEY can do the same via their different programs (SkyWish, SkyMiles Mileage Purchase Option). They really want me to believe that it's illegal for me to give awards that belong to me away, but they can! Who do they think they're kidding!