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Americans Elect Quietly Upgrades Candidate Status of David Walker, from Outsider to Insider

In the nation’s first corporate-run, privatized, online presidential nomination, it’s easier for some candidates to get on the ballot than others. According to the Americans Elect Rules, if you’re an insider —

Vice President, United States Senator, Member of Congress, Presidential Cabinet Member, Head of a federal agency, Governor, Mayor of any of the largest 100 cities in the United States, Chairman or Chief Executive Officer or President of any corporation or nonprofit corporation or philanthropic organization with 1,000 or more employees, President of a national labor union with 100,000 or more members, military officer who has attained flag rank, Ambassador, and President of an American-based university with more than 4,000 students

— then to get on the Americans Elect presidential nomination ballot you have to convince only 1,000 people in each of 10 states to vote for you on the Americans Elect website (a total of 10,000 people). If on the other hand you’re an outsider — not holding an office described above — then you need to find 5,000 people in each of 10 states to vote for you (a total of 50,000 people).

Yesterday, AE Transparency broke the news that Americans Elect had quietly upgraded the candidate status of David Walker from outsider to insider. David Walker is no ordinary Americans Elect candidate, either. In a possible conflict of interest, he happens to sit on the Americans Elect Board of Advisors, and Americans Elect leaders have sung the praises of David Walker over and over and over again.

To be honest, I didn’t believe AE Transparency’s report — not that I thought the report was a lie, but that there must be some mistake. For Americans Elect to…

  • change the ballot access standard for a single candidate,
  • who happens to be on its Board of Advisors,
  • and has been the recipient of Americans Elect leaders’ open support,
  • three-quarters of the way through the ballot-access voting period

… just sounded too far out, too overtly insiderish, like something you’d read from a dime-store potboiler paperback. But I looked into it. It’s true.

Here’s a screen capture of David Walker’s candidate page on Americans Elect on March 27 2012, taken from the cache of a Bing search (search caches are always useful for backward-looking research):

David Walker Americans Elect candidate page, March 27 2012

And here’s a screen capture of David Walker’s candidate page on Americans Elect on April 8 2012.

As you can see, the standard for David Walker was lowered last week. Along with the changed standard, David Walker’s title has been renamed from “Other” to “Former Head of a Federal Agency” (Walker is a former head of the General Accountability Office).

I’m agnostic on the question of whether David Walker has experience as the head of a “federal agency.” AE Transparency quotes Section 551 of the U.S. Code to establish that, legally speaking, a “federal agency” only refers to an administrative office of the executive branch, and the General Accountability Office that Walker headed up is an office of the Congress. But I can see how one might classify the GAO as a “federal agency” outside of the strictures of legality, since it certainly an agency and is a part of the federal government.

Regardless of that substantive question, it is procedurally curious for Americans Elect to be so quietly making this move particularly on behalf of David Walker. I sincerely don’t understand why would Americans Elect do this. It’s not like there’s been a groundswell of popular support for the Draft Walker movement in the month and a half since a multi-pronged publicity campaign on behalf of Walker was rolled out. As of this morning, Walker is less than 1% of the way to his newly-lowered ballot access threshold of 1,000 votes in each of 10 states — and he has only 28 days to go until the first primary ballot. Unless Walker plans to tap into his funding stream from billionaire Pete Peterson and start paying people to collect votes for him, I don’t see how Walker could possibly take advantage of Americans Elect’s new favorable action.

Add this curiosity to the long list of curiosities regarding Americans Elect. As Americans Elect comes ever-closer to finishing the current ballot-access vote and beginning its primary nomination votes, we can expect such curiosities to accumulate.

Update, 4/10: Kudos to Astute Dent, who notices that David Walker is the only draft candidate in Americans Elect to have the privilege of his own “bio” tab attached to his candidate page.

45 thoughts on “Americans Elect Quietly Upgrades Candidate Status of David Walker, from Outsider to Insider”

  1. AE Transparency says:

    Thanks, Jim. We were, admittedly, a little concerned about our lack of a screenshot of Walker’s old “Other” status prior to his Easter Week Ascension to “Former Head of a Federal Agency” (He is Risen!), but we elected to go with the story anyway, despite our fear that Americans Elect Corporation might go the ‘plausible deniability’ route and just say it ain’t so. It’s great to have this external proof! Really, though, even without it we needn’t have worried: Americans Elect Corporation’s M.O. is, as you know better than anyone else, to simply stonewall inconvenient truths.

    It is, we think, a measure of the ever-increasing panic in the AECorp penthouse that they would try playing a dorky little game like this. Strictly amateur-hour. Peter Ackerman is watching in horror as his millions circle the drain, and boy is he p*ssed! His new tee-shirt: “I Bought Myself My Own Political Party And All I Got Was Friggin Buddy Roemer”

    There’s a deeper lesson here, as well, regarding the fundamental flaw in the strategy of relying upon Web-based plots to fiendishly manipulate and co-opt disaffected young voters. Unfortunately for the scum-bags who think this is the wave of the future, The Web Never Forgets. These guys have left trails of dog-droppings decades long across the web, which are so easy to step in (as we do, repeatedly, in our ongoing Profiles In Courage series) that it hardly seems sporting. The web is the last place one should try pulling political shenanigans, not the first.

    What a bunch of Einsteins.

    1. AE Transparency says:

      The other deep lesson here, we think, is the sagacity of our motto here at AE Transparency: “In ‘Digital Democracy’, The Hand That Rocks The Server Rigs The Vote!”

      Digital democracy can work…but not when it is owned and operated by a shadowy, ultra-partisan billionaire.

    2. Ralph says:

      It’s hard to tell if it’s panic. My ongoing theory is that Americans Elect is just making things up as they go along. They’ve been playing dorky little games like this since they were Unity 08. It seems to me like they think they can tweak the system without telling anyone, change the rules in the middle of the game, and otherwise just play around with no accountability. Americans Elect is interesting to me because it’s a window into the kind of thinking that REALLY runs America–a few people can do whatever they want and call it democracy. I think what Jim and some other people are doing is creating a very interesting document of exactly how a bunch of the clowns who rule us and pretend to be promoting democracy do it.

  2. Ron rambles says:

    I don’t think you can dismiss AE2012 just yet. Maybe they plan to run Olympia Snowe.. Peel off enough women votes to hand a close state like Ohio to Romney? Or draft Jeb Bush or Christy Todd Whitman .. they only need to win the south to deny Obama 50% of electoral college. election would go to the house Obama loses. Ackerman, Soros.. teamed up with the Bush neocons . hedge funds/ Rothschilds/ Rockefellers.. these dudes have something cooked up.. also, ask yourself why is the New York times American Elects Pom-Pom squad?

    1. Jim says:

      Actually, Gail Collins of the New York Times ripped AE a new one recently.

  3. John Lumea says:

    Maybe Americans Elect is cruising for another Thomas Friedman mention. I notice that, although Friedman has continued to harp away on his belief that what the country needs now is Centrism, sweet Centrism — including in his recent column on David Walker — he has explicitly name-checked Americans Elect in the Times only the once, last July (“Make Way for the Radical Center”). Since then, he’s been making more oblique references to the need for a “Third Party” — which he insists on capitalizing.

    A side note on the imminence of the first ballot…

    Is it just me, or has the “first ballot clock” on the Americans Elect home page been ticking down faster than one day per day?

  4. Richard Winger says:

    Irregular Times deserves great praise for this excellent investigative reporting.

    1. Jim says:

      Thanks, Richard, but in this case the credit goes to AE Transparency.

  5. John Lumea says:

    If there’s a push for David Walker at Americans Elect, I guess Mark McKinnon didn’t get the memo. Here’s his tweet from last Tuesday:

    Since money is at the root of our political problems, how about Buddy Roemer for Prez at Americans Elect. Lawrence Lessig as VP. Firepower!

  6. William J. Kelleher, Ph.D. says:

    Come on, you guys! You are trying to make a big pile of dung out of one rabbit poop. AE has always had its standards for rating candidates out there for the public to see. If a guy or gal has relevant government or organizational experience, he/she gets into the acceptable candidate category, and only needs 10,000 support clicks to be considered in the May 8 vote. Moving Walker from the tougher (50,000) category to the easier one does not constitute “a sneaky, under-handed, shell game move by the elitist dictatorship.” It’s just a technical correction under existing rules.

    The move doesn’t change the main problem AE is currently facing. That is, none of its would-be candidates is anywhere near meeting the requirements. As of now, AE could have 50 ballots with no names or only fill-in subs. How they solve this problem may say more about how democratic the organization is than the Walker adjustment. Until then, your joy at this “gotcha” is unjustified.

    1. Bill says:

      Fascinating how the ne’er-do-wells of politics have worked so hard to make “gotcha” a dirty word. You shuffle downstairs in the middle of the night to find a burglar bagging up your electronics and holler “Gotcha!” and he replies “Oh, there you go with your finger-pointing again….”

    2. John Lumea says:

      William —

      Let’s assume, for a moment, that Walker should have fallen under the 1,000-click rule all along — and not the more arduous 5,000-click rule.

      if Americans Elect is serious about engaging and empowering its delegates with the information they need to draft and build support for whomever they wish — if that delegate freedom and power is where the true integrity of this process lies — then isn’t Americans Elect obligated to inform delegates about the “upgrade” — or, for that matter, the “downgrade” — of Walker or any other draft or declared Americans Elect candidate?

      Where is the official email blast about this?

      Why do delegates have to learn about these changes from Jim Cook or AE Transparency or other intrepid citizens?

      Jim put the word “Quietly” in the headline — and he is absolutely right to have done do, for the Americans Elect corporation repeatedly has done this sort of thing on the down low. There would be no need for a site called “AE Transparency,” if Americans Elect was acting — and communicating — transparently.

      This unnecessary and trust-squandering intrigue falls in the same category as recent efforts by the Americans Elect corporation to suppress delegate votes about delegate challenges to Board decisions, by suppressing the ability of delegates to learn that any challenges even existed.

      Democracy requires the free flow of information — not its sequestering.

  7. Tes Stone says:

    I am quietly looking into AE as a possible addition to the political stew now brewing. Please note my phrase “possible addition to.” I have no intentions of participating in a roving internet-based third party which cannot possibly win in 2012 and will only draw votes from the current candidates, puny though they be. I am, however interested in drastically overhauling our current pathetic two-party system and creating something to last past the next election cycle. I am, therefore, put off by your fulminating about the “REAL MONEY” behind Americans Elect. I have no idea about the “hidden agenda” of this group…but then neither do you. A little less anger would go a long way towards my being able to investigate this group before it’s blasted off the planet by the ilk of IrregularTimes. On behalf of those of us who can walk and chew gum without you…give it a rest.

    1. William J. Kelleher, Ph.D. says:

      Right on, Tes! AE could be the jewel of democratic reform for the US – if all the gotcha guys would only say someting positive. As one of the great mass of the ne’er-do-wells in politics, my motto is “Death to the Two-Party System!” That’s why I support AE. Because the PROCESS of candidate selection and nomination is open and transparent, it doesn’t matter to me who pays the bills.

      1. John Lumea says:

        But it’s not at all clear what Americans Elect means by “reform.”

      2. Jim Cook says:

        If only people would stop complaining and get in line…

        … are not words compatible with meaningful democratic reform.

      3. John Lumea says:

        William: You are, of course, right that — in principle — there is no reason why the two basic structural premises of Americans Elect — a Web-based nominating process and a (promised) 50-state ballot line — could not be used for good.

        One problem is that the Americans Elect corporation, its directors and its advisors have totally mucked it up with their ideological pretensions.

    2. Jim Cook says:

      If the Americans Elect organization, funded by millionaires and billionaires and blessed with prime promotion spots on all the news networks, cannot survive someone writing something on a website (something true, mind you), then that says something about the organization, Tes. Oh, pity the poor 501c4 corporation with a $30 million budget. Some guy is asking questions and saying things!

      On “REAL MONEY” — nobody wrote about “REAL MONEY” in this article before you brought it up. And maybe I’m not self-aware, but I thought this article was reasonably circumspect and fair, not about “anger” (Stone) or “joy” (Kelleher).

    3. Ralph says:

      If you really think people who are concerned about the effect secret money from junk bond billionaires is having on American politics should “give it a rest,” that’s your opinion. But you’re WAY out of touch with most Americans, who have absolutely had it, and will not “give it a rest” until it stops.

  8. Astute Dent says:

    What nobody has mentioned here is the fact that the guy has a bio page in both screenshots. No other draft candidate has a bio page.

    And did anyone actually read that glowing bio? “CEO of three government agencies”? “Trilateral Commission”? “George W. Romney Award”?


    The lights are on at Irregular Times but is anyone home?

    1. Jim Cook says:

      Thanks for the mention of this fact. You’re absolutely right and I hadn’t noticed that difference. It’s an important enough difference that I’ll add a note (with credit, of course) to this post.

      I am, in fact, not home, although I left my lights on at home to repel burglars. I am on vacation in the Aegean sea islands with my retinue of attendants, deep sea diving for relics… I wish.

      1. Joshua says:

        Under AE rules, all the draft candidates are supposed to have bios (see Pre-Election Convention Rule 3.2.3). But it’s probably not a coincidence that an AE advisor would be the first draft candidate to benefit from that rule.

  9. Yerf Ace says:

    Cook lets the crackpot side come out and play again I see.

    Oh me garsh…. some internet party type organization follows it’s own rules and qualifies this comptroller guy the way it initially should have. Trumpet it from the rooftops! Communists/Al Queda/Corporatists/Wingnut Bugaboo of the day are coming!

    1. Bill says:

      You can lead a horse to water….

  10. William J. Kelleher, Ph.D. says:

    OK, so here comes this handful of rich guys bearing gifts for our political system. They can see the two-party system is ruining our political system, just the way the Founding Fathers said it would. (See chapter two of Internet Voting Now for tons of quotes, and analysis of our Const’s founding intentions re parties.) Contrary to the self-interest of their class, the rich guys pitch-in $30M to set up a system that will enable the common ordinary middle class Jane and Joe to select and nominate presidential candidates, which candidates can appear before the voters FOR FREE, and therefore win the nomination w/o any political debts. Knowing that some of these gift givers will encounter severe economic retaliation if their names are discovered by the political agents of their class, some of them want to remain anonymous. But their anonymity has no effect on the process they are presenting us as a gift, because that process is fully transparent. So, what are we lovers of democracy and freedom through self-government doing with this rare opportunity to start a revolution and destroy the oppressive and exploitative two-party system? Why, of course, we are acting like know-it-all skeptics and shrewd dudes and proclaiming wisely “it’s too good to be true, therefore it ain’t true, its a rich guy’s trick!” My how clever we are! We are bad-mouthing and mocking our best chance ever of destroying our nation’s number one enemy — the two-party system. Alternatively, we could grasp this gift and make it work the way its supposed to. We could be using our online connections and resources to push this process to its limits by organizing and energizing participants. We could form such a powerful voting block that we could demand the ouster of undemocratic AE officials and elites. The bylaws allow delegates to change rules, and exercise complete control over candidate selection and nomination. The rich guys will have to tolerate delegate power, or else waste their $30M by any dictatorial interference. But we the people chose to lose.

    1. Jim Cook says:

      Mr. Kelleher,

      That would be a nice, hearty polemic of yours except for the facts that Americans Elect has already squelched two votes and has spent months tinkering with the rules to make it democratic choices by delegates less democratic. If Americans Elect really were democratic, I’d be all for it. But it’s not, and that difference makes your exhortations that we must stop questioning kind of beside the point.

      1. William J. Kelleher, Ph.D. says:

        Its not democratic? How can you make that declaration before the system has been fully tried? You and John and others (like Rick Hasen) could be serving the aim of revolution against the two-party system AND the aim of criticizing undemocratic moves from the inside. If the process doesn’t have full participation from middle class folks, then we will never know if it was democratic. You can chose to rally your readers to participate and continue to be as critical as hell. But by being only critical, you are discouraging the very participation the process needs to prove itself. So, come on, bro – lets unite and fight for some real reform while we have this opportunity (because we won’t have it for long).

        1. Jim Cook says:

          It’s not democratic. I can make that declaration because I know from firsthand experience that Americans Elect has refused to let its delegates know that its first two delegate votes even existed, even when a request to do so was sent directly to Americans Elect leaders. That’s not democratic. You’re an aware Americans Elect delegate, Dr. Kelleher. Can you tell me what those first two delegate votes were? Can you tell me when they happened? Can you tell me what they were about? I’m guessing not — because Americans Elect refused to tell its delegates the votes even existed. That’s not democratic.

          I HAVE NEVER been a Democrat or a Republican.
          I AM an Americans Elect delegate.
          I HAVE BEEN actively participating the Americans Elect system.
          As an active delegate, I AM criticizing undemocratic moves from the inside.
          And I HAVE been around the bush enough times to know that when someone is asking me to “Unite,” that usually means “Shut up and get in line.” You’ve been honest enough to make that explicit.

        2. Ralph says:

          Yeah, but see–being critical IS participating. Well, that goes for a democracy, anyway. This “stop grousing” nonsense is really getting on my nerves. If too much scrutiny is really the problem, let’s just rejoice in the corporate media’s coverage of the Democrats and Republicans. The Libertarians, Greens, Socialists, etc. have been banging their heads against ballot and media access aspects of the dupoply for decades. Now a few secretive rich guys come and buy their way around those obstacles with junk bond cash, and it’s the ONLY HOPE for a third party? Come on, bro!

    2. Bill says:

      Please pass the Kool-Aid, Dr. Kelleher.

      1. William J. Kelleher, Ph.D. says:

        Hey Bill, do you like the two-party system? Were you taught in school by some of my fellow political scientists that the two-party system is the apex of democracy? Did you drink THAT Kool-Aid? Any independent thinking American has got to see that the two-party system is killing our country. AE gives us a chance to rise up and crush the enemy. So come on, bro – join me!

        1. Bill says:

          Bro: like Jim Cook, I too am an Americans Elect delegate, fighting to make it what it’s not: legit. As it’s currently constituted, funded, and operated, AE doesn’t “give us a chance to rise up and crush the enemy.” Instead it gives us a chance to JOIN the enemy. AE is proving itself to be far worse than the two traditional parties: it actively rigs votes, it is owned and operated by a shady cabal of oligarchs, its rules are blatantly — almost proudly — anti-democratic. And it’s a con. I can understand your aversion to the duopolistic two-party system, but I can’t understand why you would think — in the face of all the diligently documented evidence to the contrary — is the solution. Americans Elect is just a fresh-faced new part of the old problem. So instead of the Donkey and the Elephant, we now have the Donkey, the Elephant, and the Wolf In Sheep’s Clothing. So join US, bro. Stop being so credulous and start holding AECorp’s feet to the fire. The enemy of your enemy can still be your enemy, too.

  11. Tes Stone says:

    Look guys– I don’t want to start WWIII here, as apparently easy as it is to do so on the blogosphere. All I’m saying is that I was able to do the research myself and follow the money. And, I’m no genius. I am currently concerned about the business profiles of the Board and sit on two committees whose soul purpose is to check up on such groups. But NOBODY at AE has tried to steal my soul, and, if they did, I’d tell them where to go. But, quite frankly I don’t like a future where the bank accounts of public figures determine whether we “trust” them, or not, any more than I followed the silliness of “don’t trust anybody over 30”, in the 60s. This is exactly the class warfare that people of REAL goodwill are warning against. When I was active in the 60s, I would have been delighted with the moneyed support of somebody with like interest. That might have kept me from the numerous scars I collected at the Oakland Induction Center. What IS important is that we keep our Eyes on the Prize, not dissolve into petty squabbling. As a crabby old ex-activist, I find the current discourse of so-called activists to be short-sighted and thin-skinned. And, quite frankly, I expect most to give up and take their marbles home, if things aren’t exactly where they want them and when they want them. I’d hoped that Irregular Times bloggers would be brighter and more balanced than those of most of the blogosphere…but I guess not.

    1. William J. Kelleher, Ph.D. says:

      I was in Oakland at that time, too. And Berkeley, and Knob Hill for LBJ. And BA/MA SFState under Hayakawa. I’ve still got the spirit

  12. Joshua says:

    It would have been better if AE had posted a list of “Decisions of the Candidate Certification Committee” to indicate that the committee had determined that Walker did count as the head of a federal agency.

    However, the fact that they made that decision doesn’t bother me at all. I had previously e-mailed AE to request corrections to the insider/outsider classifications of certain candidates, Walker being among them. Another one I had written to them about was Rocky Anderson — although he had once been listed as an insider, he was not mayor of one of the 100 largest cities in the U.S. and so he was reclassified as an outsider. Yet another one I wrote to AE about was Joe Scarborough — he’s still listed as an outsider even though he was formerly a member of Congress. Clearly, Scarborough ought to be upgraded, but it would be preferable if AE announced in the Board Documents section who was being upgraded or downgraded and why.

    1. Jim Cook says:

      It would be especially better, considering that Americans Elect delegates have the right according to the Rules and Bylaws to challenge any decision of any Americans Elect committee. If Americans Elect doesn’t inform delegates of the decisions of its committees, then there’s really no way for delegates to exercise their rights. It’s another example of Vogon democracy.

      I agree with you more broadly, Joshua, that not everything Americans Elect does is necessarily bad. But Americans Elect and its predecessor Unity08 do seem to have a knack for behaving curiously.

  13. Stephen Kent Gray says:

    2012 will be a complex election.

    Donkey: Democratic Party
    Eagle: Constitution Party
    Elephant: Republican Party
    Flower: Green Party
    Porcupine: Libertarian Party
    Wolf in Sheep’s Clothing: Americans Elect

    Bill, I used your analysis of AE to create a mascot for them.

    I guess it will depend on the state you live in.

    1. William J. Kelleher, Ph.D. says:

      Stephen – I have removed your misinformation from Wikipedia. You violate the rules requiring posting information that is true. As a professional political scientist, I can tell you that AE does not fit the profession’s commonly accepted definition of a “party.” It does not advance any candidate, nor promote any platform of policies. It does not pay for the media promotion for or against any candidate or policy.
      If you persist, I will ask to have you banned from posting anything on Wikipedia.

      William J. Kelleher, Ph.D.
      “DrWJK” on Wikipedia

      1. Peregrin Wood says:

        William, I think that one of the most basic criteria for any reasonable political scientist’s definition of a political party would have to include that an organization calls itself a “political party”. Americans Elect has done this, repeatedly. I think it’s pretty dishonest of you, Ph.D. or no, to ignore that fact, which has been pointed out here quite clearly.

      2. Jim Cook says:


        OK, first of all, you do know that the PhD thing is over the top and advertises insecurity, right? Just saying.

        Second, you’re engaging in false accusation when you threaten Stephen Kent Gray. You haven’t checked your facts. Americans Elect is officially registered in multiple states as a political party, which is kind of a pretty formal indication that it is a political party. See here. See here. See here. See here. And so on.

        Hey, I just noticed Peregrin Wood said all this too. Well, apparently, for you it needs to be said twice. Professional political scientists are supposed to look up crap before they accuse other people of being liars.

      3. Ralph says:

        Stephen, if you get kicked off Wikipedia for calling an organization that calls itself a political party a political party, you will forever be remembered as the guy who exposed Wikipedia as a corporate shill and a completely unreliable source of information. I’d say go for it.

      4. John Lumea says:

        William —

        Americans Elect “does not advance any candidate”?!!


        Latest example: In violation of both the spirit and the letter of the explicit neutrality policy of Americans Elect (Section 10 of the corporate Rules and Sections 4.12 and 6.1 of the By-Laws)…

        Americans Elect advisory board member Lawrence Lessig appears — campaigning with declared Americans Elect candidate Buddy Roemer — in this video, which is featured on Roemer’s official campaign YouTube channel.

        Look who owns the channel. Do you wish to argue that this does not “advance any candidate”?

        1. John Lumea says:

          In case you missed it, the video is…

          On. Roemer’s. Official. Campaign. YouTube. Channel.

  14. Bill says:

    To celebrate Americans Elect Corporation’s very recent success in winning ballot access in North Carolina, today I filed a complaint with the Executive Director of the
    North Carolina State Board of Elections, regarding this and other balloting irregularities I have witnessed at Americans Elect. As I wrote in the opening of that (rather lengthy, I’m afraid) letter:
    “It is certainly not my intent to make a frivolous report. I believe that with the advent of (and likely future increase in) online primary voting these issues are material and important to clarify now. Is there, for example, any fundamental difference between a candidate standing outside a conventional polling station offering free beer and sandwiches in exchange for votes, and a candidate tweeting offers of “swag” in exchange for votes during the conduct of an online primary ballot? Is the unannounced alteration of an electronic ballot in mid-vote any different than the purposeful defacing of paper ballots? Is it fraudulent to move one individual candidate’s goal-posts in mid-ballot, without comment? I think you’ll agree these are important and interesting questions to get to the bottom of.”

    1. Bill says:

      P.S.: I’d be happy to share the text of my letter with any individuals who would like to file similar complaints in their own states.

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