.<.L. _u FEDEfV\L :LtCTIOH G01·ii·~lS:~ION 500 Fifth Avenue, 40th Floor NewYork. NY 101 10 2 12-257-4880 4:,) Shapiro, Arato & Isserles LLP 201~ SEP 11 AH IQ: 35 212-202-6417 (f) www.shapiroarato.com ------------------Aff·jf;; L COUNSEL Alexandra A.E . Shapiro
[email protected] Direct: 212-257-1881 September 10, 2014 VTA FEDEX Office of the General Counsel Federal Election Commission 999 E Street, N.W. I Washington, D.C. 20463 To Whom It May Concern: We represent Level Lhe Playing field, a nonpartisan, nonprofit corporation that is not affiliated with any candidate or candidate committee. On its behalf, we hereby submit the enclosed Petition for Rulemaking requesting tbe Federal Election Commission to revise and amend 11 C.F.R. § 110.13(c), the regulation governing the criteria for candidate selection that corporations and broadcasters mu:>l use in order to sponsor candidate debates. With this letter, please find one copy of the Petition and an accompanying volume of exhibits, as well as a DVD containing electronic copies of these documents. Among other evidence, the Petition relies on expert reports from Dr. Clifford Young, head of U.S. public affairs at the polling rirm lpsos; Douglas Schoen, veteran pollster and campaign strategist; and Michael Arno. founder ora leading ballot access consulting fi1111. These reports, along with 0U1er supporting evidence, are subr11ittcd as exhibi ts to the Petition. The data and authorities that Dr. Young, Mr. Schoen, and Mr. Arno cite and rely upon in their reports are not submitted herewith, but are available for the Commission's review and can be provided upon request.