Lucie Hilbert, CFA, offers premium services to clients for an additional fee. She offers the premium services only by email to all of her clients. One client, who previously inquired about premium services, does not receive the offer due to a technical problem with the client's email system. One week later Hilbert makes an investment in an IPO on behalf of her clients. The issue is oversubscribed, so she excludes her sister, a regular fee-paying client of Hilbert's firm, to free up shares for other clients. Has Hilbert most likely violated the Standards?