Institute for Free Speech

The Institute for Free Speech, formerly the Center for Competitive Politics (CCP), promotes the deregulation of U.S. elections, being against the McCain-Feingold act, the Disclose Act, the Fairness Doctrine, and being in favor of the Supreme Court decision Citizens United v. Federal Election Commission, which allows corporations to spend money to promote or oppose candidates in elections. It is a 501(c)(3) non-profit which states on its website that its mission is "to educate the public on the actual effects of money in politics, and the results of a more free and competitive electoral process." The Center was founded in 2005 by Bradley A. Smith, former Chairman of the Federal Election Commission. Stephen Hoersting, formerly Smith's Legal Counsel at the Election Commission, served as the Center's first Director. The current President of IFS is David Keating.

(Smith was a Republican appointed to the FEC by President Clinton in 2000 as part of the statutory requirement no more than three of the FEC's six commissioners come from any one political party. His nomination was promoted by Republican Senators, but was opposed by Vice President Al Gore and others because Smith opposed campaign finance regulations and thus they considered him "unfit" to regulate those campaign finance practices. He was confirmed as part of a package deal to secure the confirmation of other nominees. In 2004, Smith was elected Chairman of the FEC. (Unlike most federal agencies, the FEC Chairman is not designated by the President. Rather, by law each year the FEC Commissioners elect one of the six Commissioners to serve as Chairman for a one year term. By custom, the Chairmanship of the Agency rotates between Republicans and Democrats; by law, the Chairman and Vice-Chairman must be from different parties.))

The Institute for Free Speech is an "associate" member of the State Policy Network, a web of right-wing “think tanks” in every state across the country.

Overview

In August 2008, Jeanne Cummings of Politico wrote, 'Encouraged by the U.S. Supreme Court, conservatives are launching a wholesale legal assault on campaign finance laws. And among the leaders is a man once charged with enforcing those laws: former Federal Election Commission Chairman Bradley Smith. His goals are big. He doesn't want to just scale back the laws; he wants to pretty much wipe them out.'

Bradley Smith opened the Center for Competitive Politics to build a case against the regulatory system that limits individual donations to candidates, reins in the role of outside groups, and bans union and corporate contributions to political parties. With financial support that came largely from individuals he declines to name, Smith opened the Center for Competitive Politics a year later to begin challenging the current campaign finance system in both federal court and the court of public opinion. "What the Center for Competitive Politics can do and is trying to do is to bring the right kind of cases before the court," Hasen said, so Chief Justice John Roberts and his new coalition of conservatives can "knock them out of the park."'

The Center for Competitive Politics changed their name to the Institute for Free Speech in October of 2017.

Ties to the State Policy Network

IFS is an associate member of SPN. SPN is a web of right-wing “think tanks” and tax-exempt organizations in 50 states, Washington, D.C., Canada, and the United Kingdom. As of October 2019, SPN's membership totals 162. Today's SPN is the tip of the spear of far-right, nationally funded policy agenda in the states that undergirds extremists in the Republican Party. SPN Executive Director Tracie Sharp told the Wall Street Journal in 2017 that the revenue of the combined groups was some $80 million, but a 2019 analysis of SPN's main members IRS filings by the Center for Media and Democracy shows that the combined revenue is over $120 million. Although SPN's member organizations claim to be nonpartisan and independent, the Center for Media and Democracy's in-depth investigation, "EXPOSED: The State Policy Network -- The Powerful Right-Wing Network Helping to Hijack State Politics and Government," reveals that SPN and its member think tanks are major drivers of the right-wing, American Legislative Exchange Council (ALEC)-backed corporate agenda in state houses nationwide, with deep ties to the Koch brothers and the national right-wing network of funders.

In response to CMD's report, SPN Executive Director Tracie Sharp told national and statehouse reporters that SPN affiliates are "fiercely independent." Later the same week, however, The New Yorker's Jane Mayer caught Sharp in a contradiction. In her article, "Is IKEA the New Model for the Conservative Movement?," the Pulitzer-nominated reporter revealed that, in a recent meeting behind closed doors with the heads of SPN affiliates around the country, Sharp "compared the organization’s model to that of the giant global chain IKEA." She reportedly said that SPN "would provide 'the raw materials,' along with the 'services' needed to assemble the products. Rather than acting like passive customers who buy finished products, she wanted each state group to show the enterprise and creativity needed to assemble the parts in their home states. 'Pick what you need,' she said, 'and customize it for what works best for you.'" Not only that, but Sharp "also acknowledged privately to the members that the organization's often anonymous donors frequently shape the agenda. 'The grants are driven by donor intent,' she told the gathered think-tank heads. She added that, often, 'the donors have a very specific idea of what they want to happen.'"

A set of coordinated fundraising proposals obtained and released by The Guardian in early December 2013 confirm many of these SPN members' intent to change state laws and policies, referring to "advancing model legislation" and "candidate briefings." These activities "arguably cross the line into lobbying," The Guardian notes.

Ties to the Koch Brothers

Between 2012 and 2015 the Center for Competitive Politics received $57,237 from the Charles G. Koch Foundation.

According to the Center for Public Integrity, the Institute for Free Speech, “like Cato and the Institute for Justice ... has Koch connections [and] has also received funding from the Charles Koch Foundation.”

Koch Wiki

The Koch brothers -- David and Charles -- are the right-wing billionaire co-owners of Koch Industries. As two of the richest people in the world, they are key funders of the right-wing infrastructure, including the American Legislative Exchange Council (ALEC) and the State Policy Network (SPN). In SourceWatch, key articles on the Kochs include: Koch Brothers, Koch Industries, Americans for Prosperity, American Encore, and Freedom Partners.

Ties to the Lynde and Harry Bradley Foundation

Between 2008 and 2016 the Center for Competitive Politics received $640,000 from the Lynde and Harry Bradley Foundation.

In 2010, Bradley A. Smith, founder of the Institute of Free Speech/Center for Competitive Politics, was a winner of the “Bradley Prize,” which “honor scholars and practitioners whose accomplishments reflect the Lynde and Harry Bradley Foundation mission to restore, strengthen and protect the principles and institutions of American exceptionalism.”

Bradley detailed the most recent grants in internal documents examined by the Center for Media and Democracy (CMD). Below are the descriptions prepared by CMD. The quoted text was written by Bradley staff.

2016: $125,000 to support general operations (litigation, research and public education activities). The grant will be used by CCP to fight those calling for greater disclosure rules “to chill speech,” part of a national effort to allow campaign finance donors to hide their identities.

2015: $100,000 to support general operations.

2014: $75,000 to support general operations. Key factors in CCP’s selection of cases, in addition to the existence of a favorable plaintiff, are as follows: “the probabilities of winning and anticipated cost and resource allocation; the impact of victory on the legal landscape and campaign finance law generally; opportunities to publicize favorably deregulation through litigation; and the potential of a favorable decision to impact positively legislature incentives to deregulate… Litigation in 2014 and beyond focuses on draconian disclosure laws to harass groups through the reporting process resulting from the Citizens United decision. Recent enactment of disclosure laws in Delaware and Utah present strong vehicles for constitutional challenges. CCP will also be studying options to seek judicial review of current IRS practices regarding political activity by nonprofits… CCP increased attention to the increasingly worrisome donor disclosure legislative initiatives across the country especially aimed at non profits, will be at most a timely and valuable contribution to ensuring the protection of free speech.”

Bradley Files

In 2017, the Center for Media and Democracy (CMD), publishers of SourceWatch, launched a series of articles on the Milwaukee-based Lynde and Harry Bradley Foundation, exposing the inner-workings of one of America's largest right-wing foundations. 56,000 previously undisclosed documents laid bare the Bradley Foundation's highly politicized agenda. CMD detailed Bradley's efforts to map and measure right wing infrastructure nationwide, including by dismantling and defunding unions to impact state elections; bankrolling discredited spin doctor Richard Berman and his many front groups; and more. Find the series here at ExposedbyCMD.org.

Ties to the American Legislative Exchange Council

Former CCP President Sean Parnell served on the Public Safety and Elections Task Force of the American Legislative Exchange Council (ALEC). At the 2011 ALEC Annual Meeting, he introduced the "Resolution in Support of Appropriate Disclosure Requirements" model policy for adoption by the Public Safety and Elections Task Force. On July 20, 2011, Parnell published an article in The Daily Caller (conservative/Republican news organization founded by conservative reporter Tucker Carlson and former Dick Cheney aide Neil Patel) criticizing Common Cause for requesting that the Internal Revenue Service look into claims that ALEC, in violation of the laws governing 501(c)(3) organizations, has engaged in lobbying. According to an August 2013 ALEC board document obtained by The Guardian, CCP terminated its ALEC membership on March 19, 2013 because the Justice Policy Project (JPP), which replaced the Public Safety and Elections Task Force at ALEC, "no longer works on issue."

About ALEC

ALEC is a corporate bill mill. It is not just a lobby or a front group; it is much more powerful than that. Through ALEC, corporations hand state legislators their wishlists to benefit their bottom line. Corporations fund almost all of ALEC's operations. They pay for a seat on ALEC task forces where corporate lobbyists and special interest reps vote with elected officials to approve “model” bills. Learn more at the Center for Media and Democracy's ALECexposed.org, and check out breaking news on our PRWatch.org site.

Opposing the Disclose Act

The DISCLOSE Act would require corporations to publicly disclose contributions to organizations and trade associations that might make expenditures for campaign ads. The bill was introduced in response to the U.S. Supreme Court's ruling in the Citizens United case allowing corporate spending in campaigns. Advocates of stricter campaign finance laws say that the public has a right to know exactly who is funding political ads.

The Center for Competitive Politics and other groups including Americans for Tax Reform, The American Conservative Union, CatholicVote.org, and Citizens Against Government Waste argue that provisions in the DISCLOSE ACT go beyond disclosure to actually prohibit speech, and sent a letter to Congress calling the bill "an unequivocal ban on free speech, masquerading as an exercise in accountability."

Funding

Between 2010 and 2015, IFS (then- the Center for Competitive Politics) received $4,227,480 combined from DonorsTrust and Donors Capital Fund. The twin Donors organizations are advertised as a way for very wealthy people and corporations to remain hidden when "funding sensitive or controversial issues," creating a lack of accountability. (See DonorsTrust and Donors Capital Fund Grant Recipients for more).

Other top donors between 2006 and 2014, per Conservative Transparency:

• Donors Capital Fund - $4,848,480
• Robert W. Wilson Charitable Trust - $1,081,250
• Searle Freedom Trust - $600,000
• DonorsTrust - $590,500
• The Lynde and Harry Bradley Foundation - $425,000
• Ed Uihlein Family Foundation - $411,000
• Dunn's Foundation for the Advancement of Right Thinking - $130,000
• The Randolph Foundation - $125,000
• Richard and Helen DeVos Foundation / DeVos Urban Leadership Initiative - $100,000

According to the Center for Competitive Politics (CCP), "In order to maintain its independence, the Center for Competitive Politics accepts no government funding. We receive funding from individuals and foundations. Approximately five percent of CCP’s funding comes from for-profit corporations. CCP is a nonprofit, tax-exempt educational foundation organized under Section 501(c)(3) of the Internal Revenue Code. Contributions to CCP are tax deductible under the law."

In its 2006 annual return to the Internal Revenue Service, the CCP states that it had total revenue of $373,571 with expenses of $284,118. It listed its 2005 income as having been $251,005. It reported income of $820,851 in 2007 and $1,425,502 in 2008.

For 2008, Media Matters lists the following funders:

• Castle Rock Foundation ($25,000), founded with an endowment from the Adolph Coors Foundation
• Lynde and Harry Bradley Foundation ($20,000)

Lee Fang, writing at the blog "Think Progress," has claimed that Center is a "front group" of libertarian activist Howie Rich, which the Center has denied. The Center for Competitive Politics, along with groups such as the Cato Institute and the U.S. Chamber of Commerce, worked in favor of the Supreme Court decision Citizens United v. Federal Election Commission. The groups filed amicus briefs to the Court.

Research

The CCP releases regular research studies on the role of money in US elections. This research has been criticized by groups such as the Brennan Center for Justice, which generally takes the opposite side from the CCP on questions of campaign finance and corporate speech. The Brennan Center argues that the CCP's research is plagued by methodological flaws and inappropriate conclusions drawn from undisclosed data points. CCP's original research reports, as well as copies of legal briefs, legislative testimony, and commentary published by the organization, are available through the organization's website.

Past Litigation

The Institute for Free Speech characterizes their previous legislative battles in the following way on their website:

‘’’Carey v. FEC Carey et al v. FEC, asks the FEC to acknowledge what the courts have already decided: that any political action committee may make contributions to federal candidates using limited funds while also engaging in independent expenditures using segregated funds raised for that purpose. The FEC has demanded that grassroots organizations jump through burdensome regulatory hoops just to speak out about candidates running for office.

Center for Competitive Politics v. Federal Election Commission

The Center for Competitive Politics (CCP) filed a lawsuit against the Federal Election Commission (FEC) seeking a controversial agency document denied to CCP despite a Freedom of Information Act request. That document relates to a complaint against Crossroads GPS that was dismissed by the FEC last December.

Coalition for Secular Government v. Williams

Colorado resident Diana Hsieh, a doctor of philosophy, organized the non-profit Coalition for Secular Government with her friend Ari Armstrong in order to promote a secular understanding of individual rights, including freedom of conscience and the separation of church and state. Because of unconstitutionally vague state laws, confusion as to what constitutes political speech and what is covered under a press exemption, and a refusal by the state to abide by a federal court order, Hsieh and CSG have found it nearly impossible to carry out the activities of a small non-profit group without fear of running afoul of complex Colorado campaign finance laws. With CCP’s Help, the Coalition for Secular Government was victorious in court. The Colorado law was ruled unconstitutional in this case.

Corsi v. OEC

Supreme Court rulings over the past four decades have limited the scope of federal committee status to groups that are “under the control of a candidate or the major purpose of which is the nomination or election of a candidate.” Ohio purports to incorporate the major purpose test required by the 1976 Buckley v. Valeo ruling. But the OEC’s interpretation, upheld by the state courts, interpreted the statute to require an organization to register as a PAC even where political advocacy does not comprise a majority—or even a substantial portion—of its activity or expenditures.

Delaware Strong Families v. Denn

Should the state have the power to regulate groups that publish nonpartisan voter guides in the same way that it regulates candidate committees, political parties and PACs? That’s the issue at stake in Delaware Strong Families v. Attorney General of the State of Delaware, a case challenging a new Delaware law that violates the First Amendment by placing unconstitutional burdens on groups publishing nonpartisan voter guides.

Emineth v. Jaeger

The Center for Competitive Politics filed a lawsuit in the United States District Court for the District of North Dakota, challenging a state ban on “electioneering on election day.” The complaint states that the ban, which prohibits all election-day attempts to “induce or persuade” any North Dakota resident to vote a particular way, is a prior restraint on speech and unconstitutional under the First Amendment.

Holmes v. FEC

Can Congress impede political participation and association by forcing an individual to split her political donations between primary and general elections? Federal law forces individuals to split their campaign contributions on a per-election basis. Thus, in 2014, a donor was forced to split her donation into $2,600 for the primary election and $2,600 for the general. This rule impedes the political participation of a donor who only wants to support her party nominee—and avoid wasting her donation on the intra-party squabbles of a primary election. IFS filed a lawsuit on behalf of a Florida couple who are challenging this law, saying that the per-election requirement mandated by Congress force them to either potentially waste $2,600 on a candidate for the party nomination or give up exercising their constitutional rights to the full extent allowed by law.

James v. FEC

The case stems from the efforts of Virginia James, a private citizen, who seeks to give contributions directly to candidates up to the biennial aggregate limit of $117,000. However, federal law allows only $46,200 of that amount, in aggregate, to be given directly to candidates; the rest must be contributed to PACs and party committees. James is not challenging the overall limit, but rather wishes to give the entirety of her contributions to candidates directly, instead of being forced to act through PACs and other political organizations.

Independence Institute v. FEC

Can a think tank run ads advocating for public policy without first registering with the federal government and disclosing its donors? That is the question at the core of Independence Institute v. FEC. The Independence Institute, a Colorado think tank, wants to run genuine issue ads that happen to mention a name of a political candidate. Campaign finance law currently requires that the Independence Institute register with the government and report certain donors to the FEC in order to be able to run the issue ads. While speech related directly to campaigns may require disclosure, genuine issue speech does not fall under this category. In this case, CCP is defending the right to speak on public policy issues without first reporting its activities in a government database and disclosing donors who give to causes they believe in.

Independence Institute v. Williams

Can a think tank run ads advocating for public policy without first registering with the federal government and disclosing its donors? That is the question at the core of Independence Institute v. Williams. The Independence Institute, a Colorado think tank, wants to run genuine issue ads that happen to mention a name of a political candidate. Campaign finance law currently requires that the Independence Institute register with the government and report certain donors in order to be able to run the issue ads. While speech related directly to campaigns may require disclosure, genuine issue speech does not fall under this category. In this case, CCP is defending the right to speak on public policy issues without first reporting its activities in a government database and disclosing donors who give to causes they believe in.

Lake Travis Citizens Council v. Ashley

This case challenges the definition of a political committee under Texas state law. There are two key issues. First, the law itself is unconstitutionally vague because it defines a campaign expenditure as speech made “in connection with a campaign for an elective office or on a measure.” Second, the Texas Ethics Commission has defined principal purpose, a term used to determine if a group is a political committee, as expenditures on electoral advocacy constituting 25% or more of a group’s calendar year spending. The Lake Travis Citizens Council wishes to run a series of Facebook ads on issues facing the community, but because of Texas’s overbroad definitions regarding the regulation of campaign ads, the Council reasonably fears that the Texas Ethics Commission will attempt to regulate the organization and its communications as political speech.

Libertarian National Committee v. FEC

The case was filed in 2011 and concerned the estate of Raymond Groves Burrington of Knox County, Tennessee, who left the Libertarian Party $217,734 in his will. Because that amount exceeded the annual limit on contributions to national party committees, the LNC was forced to place funds in escrow, withdrawing only the amount permitted by the FEC. The LNC seeks the full amount of the bequest, as well as the ability to implement a planned giving program that would solicit bequests exceeding the annual contribution limit.

Patriotic Veterans v. Indiana

Can a group of veterans be prohibited from advocating for public policy, because they wish to use robocalls? That is the question at the heart of Patriotic Veterans v. Indiana.

Patriotic Veterans, a small advocacy organization, is challenging an Indiana law that bans automated phone calls containing a political message. Political groups with limited resources use automated phone calls to inexpensively spread their message and gain support, but Indiana regulations have effectively targeted political calls. This infringes on Patriotic Veterans First Amendment rights, limiting their ability to advocate for causes they believe in. Groups with more resources can afford live operator calls and other communication methods that are unaffected by the ban. By imposing more costs on smaller politically active groups like Patriotic Veterans, while exempting other kinds of speakers, Indiana has unconstitutionally limited their ability to speak out about issues and campaigns.

Rubin v. Theobald

David Rubin is a resident of the Town of Manlius, New York. He wishes to exercise his First Amendment right to engage in political speech by posting yard signs in support of his favorite political candidates on his private property. The Town of Manlius, however, prohibited individuals from displaying political yard signs except during the thirty days before and seven days after an election. Even when citizens are allowed to display such signs, they were first required to obtain a permit. The Center for Competitive Politics (CCP) legal team, representing Dr. Rubin, filed a lawsuit challenging the town’s unconstitutional restrictions on political yard signs. In early September, the Town of Manlius repealed the code and agreed to not enact further unconstitutional restrictions on yard signs. The case was voluntarily dismissed.

Utah Taxpayers Association, et al. v. Cox, et al.

When a state decides to regulate the speech of citizen groups, it must specify in an understandable way what speech triggers regulation and detailed reporting to the government. Even if a state does this correctly, does it have the power to force groups that spend only a small portion of their funding advocating for or against ballot initiatives to file reports in the same manner as it regulates candidate committees, political parties, and PACs? On behalf of the Utah Taxpayers Association, Utah Taxpayers Legal Foundation, and Libertas Institute, the Center challenged this dangerous and expansive new donor disclosure law. On July 14, 2016, Utah conceded that the law in question did indeed violate the First Amendment, and the state signed a consent decree acknowledging that it would not enforce the unconstitutional statute.’’’

Core Financials

2015

• Total Revenue: $1,956,529
• Total Expenses: $1,596,794
• Net Assets: $2,405,786

2014

• Total Revenue: $1,951,006
• Total Expenses: $1,495,165
• Net Assets: $2,046,051

2013

• Total Revenue: $1,754,752
• Total Expenses: $1,545,035
• Net Assets: $1,590,210

2012

• Total Revenue: $1,420,276
• Total Expenses: $1,252,639
• Net Assets: $1,380,493

2011

• Total Revenue: $1,816,786
• Total Expenses: $1,577,324
• Net Assets: $1,212,856

Personnel

Staff

As of August 2017:

• Bradley A. Smith, Chairman and Founder
• David Keating, President
• Allen Dickerson, Legal Director
• Matt Nese, Director of External Relations
• Joe Albanese, Research Fellow
• Alex Baiocco, Communications Fellow
• Scott Blackburn, Senior Research Analyst
• Susan Bradley, Office Manager
• Alex Cordell, Research Fellow
• Alex Kroll, Director of Development
• Tyler Martinez, Staff Attorney
• Zac Morgan, Staff Attorney
• Luke Wachob, Senior Policy Analyst
• Eric Wang, Senior Fellow
• Owen Yeates, Staff Attorney

Board of Directors

As of August 2017:

• Hunter Bates, Partner, Akin Gump
• Edward H. Crane, Founder and President Emeritus, Cato Institute
• Cleta Mitchell, Partner, Foley & Lardner LLP
• Stephen Modzelewski, Managing Member, Maple Engine LLC
• Eric O’Keefe, Chairman of the Board, Citizens for Self-Governance
• Bradley A. Smith, Chairman and Co-Founder, Center for Competitive Politics and Blackmore-Naught Designated Professor of Law, Capital University Law School
• John Snider, CPA-Retired, Treasurer

Board of Academic Advisors Board of Directors

As of August 2017:

• Stephen Ansolabehere, Professor of Government & Political Science, Harvard University
• Lillian R. BeVier, John S. Shannon Distinguished Professor of Law University of Virginia School of Law
• Bruce E. Cain, Professor of Government, Stanford University
• John Coleman, Chair, Department of Political Science, University of Wisconsin
• Richard Esenberg, Adjunct Professor of Law, Marquette University, and President, Wisconsin Institute for Law & Liberty
• Joel M. Gora, Professor of Law and Associate Dean for Academic Affairs, Brooklyn Law School
• Jay Goodliffe, Associate Professor of Political Science, Brigham Young University
• Jeffrey Milyo, Frederick A. Middlebush Professor of Social Sciences, University of Missouri
• Michael C. Munger, Chairman, Department of Political Science, Duke University
• David M. Primo, Assistant Professor of Political Science, University of Rochester
• Larry J. Sabato, Robert Kent Gooch Professor of Political Science, University of Virginia, and Director, UVA Center for Politics
• John Samples, Director, Center for Representative Government, Cato Institute
• In Memoriam, Herbert E. Alexander, Distinguished Professor Emeritus, University of Southern California; Director, Citizens Research Foundation. (In memoriam).

Former Personnel :

• Bradley A. Smith, Chairman and Founder
• David Keating, President
• Allen Dickerson, Legal Director
• Zac Morgan, Staff Attorney
• Tyler Martinez, Staff Attorney
• Anna Mackin, Staff Attorney
• Eric Wang, Senior Fellow
• Matt Neese, Director of External Relations
• Mathew McIntyre, External Relations Associate.
• Joe Trotter, Media Manager
• Luke Wachob, Policy Analyst
• Julie Drinkard, External Affairs Director
• Susan Bradley, Office Manager

Contact Details

Employment Identification Number (EIN): 20-3676886

124 S. West Street, Suite 201
Alexandria, VA 22314
Tel: (703) 894-6800
Fax: (703) 894-6811
Website: http://www.campaignfreedom.org
Blog: http://www.campaignfreedom.org/blog/
Facebook: https://www.facebook.com/centerforcompetitivepolitics
Twitter: https://twitter.com/campaignfreedom

Articles and Resources

Related SourceWatch Articles

• Campaign finance (U.S.)
• Citizens United
• DISCLOSE Act
• Fairness Doctrine
• Front groups
• McCain-Feingold

External Articles

• Craig Aaron, "Fairness Doctrine: Secret Republican Agenda Exposed!", The Huffington Post, January 8, 2009.
• Peter Overby, "In Congress, A Showdown Over Campaign Money", NPR, July 20, 2010.
• Dan Eggen, "Special-Interest Spending Surges in State Supreme Court Campaigns", Common Dreams/The Washington Post, August 16, 2010.
• Eric Lichtblau, "Long Battle of Foes of Campaign Finance Rules Shifts Landscape" New York Times, Oct. 15, 2010.