Office of the Inspector General
Federal Election Commission
999 Tenth Street, N.W.
Washington, D.C. 20463

Dear Sir or Madam:
 

As you are aware, the National Legal and Policy Center filed this week a Complaint with the Federal Election Commission ("Commission") against Grassroots.com, Inc., the League of Women Voters, Center for Governmental Studies and Democracy Network ("DNet").

Following several news articles regarding our Complaint, an internal memo apparently from Grassroots.com was posted yesterday on the Internet and subsequently forwarded to our offices. A copy of the Grassroots.com internal memo is attached.

I would direct your attention to the reference(s) in the memo regarding an apparent ex parte communication with individual(s) at the Commission concerning the acquisition of DNet by Grassroots.com. "We had a follow-up informal discussion with the FEC a month ago confirming the October 1999 ruling is not changed under Grassroots."

If, indeed, such an 'informal discussion' took place, it would seem that such contacts are wholly inappropriate. Further, it appears that the Respondents have not only initiated such contact(s) but are also relying on the contact(s) as though formally rendered by the Commission.

The additional reference in the memo that "Our lead attorney on the case is a former head of the FEC and is well apprised of both the law and the commission's workings' is a representation that, because the lead counsel is a former Commissioner, some inside knowledge and advantage exists."

We hereby request that the 'informal discussion' referenced in the memorandum be investigated and that all information related to the conversation(s) be made part of the public record as soon as possible.

We further demand that all person(s) at the Commission involved in the referenced 'informal discussion' be disqualified from participating in any manner whatsoever in the review, investigation, consideration, deliberation(s) or decision(s) relating to our Complaint against the various Respondents.

We appreciate your immediate response to this request.

Sincerely,

Peter Flaherty
President

NLPC's FEC Complaint against Groots.com, et al.

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