MEMORANDUM
TO:

Program Team

FROM:

Kimberly Begg, Esq.
Vice President & General Counsel

DATE:

May 25, 2018

RE:

Advising our Students about TPUSA

Nationwide, student activists are coming to us with questions about
Turning Point USA (TPUSA). They tell us they are frustrated that TPUSA
claims credit for their events and creates turmoil within their YAF chapters and
other groups. Students are seeking direction from our team about whether to
cooperate with TPUSA.
In order to provide guidance to students, our team needs to understand that
TPUSA is unlike any of the many Conservative Movement organizations we have
worked with in the past.
This memo is not a comprehensive analysis of concerns about TPUSA’s
approach. It is not a report on the many alarming incidents students have shared
with us over the years. Rather, it is a compilation of information from public
sources, outlining the lack of integrity, honesty, experience, and judgment of this
growing organization.
Founded in 2012 by Charlie Kirk,
TPUSA emerged to “identify, educate, train, and
organize students to promote the principles of
freedom, free markets, and limited government.”
From the start, Kirk made bold claims about TPUSA that could not
possibly be true about a start-up organization working with young people. Early
marketing materials described TPUSA as the umbrella organization for the young
Conservative Movement, under which Young America’s Foundation,
Leadership Institute, Intercollegiate Studies Institute, The Fund for American
Studies, Young Americans for Liberty, and other groups operate.

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 Early on, Kirk made a name for himself by appearing regularly on Fox
News. He gained the confidence and support of key business leaders in the Midwest,
who made significant gifts to grow TPUSA quickly.
Kirk established an impressive social media
and online presence for TPUSA. What he lacked in
activities, he made up for through clever marketing,
using pictures of students holding up signs and making
unverified claims about the thousands of students
involved with TPUSA.
Conservative Movement groups started hearing from supporters about
TPUSA’s claims that they held more activities than all youth groups combined. This
claim has never been remotely true. Consider:
Young America’s Foundation’s conferences and
seminars, campus lecture program, Young Americans for
Freedom chapters, Center for Entrepreneurship & Free
Enterprise, National Journalism Center, and Reagan
Ranch program
Leadership Institute’s schools, workshops, training
programs, Campus Network, and Campus Reform
Intercollegiate Studies Institute’s fellowships, seminars
and conferences, ISI Societies, Collegiate Network, and
Intercollegiate Review
The Fund for American Studies’ journalism and public
policy fellowships, seminars, international programs, and
European Journalism Institute
Clare Boothe Luce Policy Institute’s campus lectures and
initiatives, conferences and seminars, fellowships,
internships, and Luce Societies
Young Americans for Liberty’s conferences, resources,
and chapters
Students for Life of America’s national conferences;
chapters for middle school, high school, and college
students; and National Field Program
2

 We called this falsehood to Kirk’s personal attention, but he has never
corrected it.
Several years ago, the leader of a conservative youth group shared that a
supporter of her organization, who had recently met with Kirk, challenged her
about why TPUSA had more chapters than did her organization. The leader was
skeptical of the claim, so she asked her staff to contact their best student activists
to learn more. They concluded Kirk’s claim was wildly untrue. The actual
number of students involved with TPUSA, and those who had started chapters, was
minimal. This group—and other youth groups—have been operating in an
environment distorted by Kirk’s fabricated claims ever since.
At some point, Kirk began making progress in
recruiting young people to become involved with
TPUSA. The numbers are still wildly inflated, as
discussed in more detail below, but the TPUSA of 2018
has its own programs and chapters, leading to a new set
of issues.
A series of negative articles, identifying
legitimate concerns about TPUSA, have emerged in
recent months. There has been much discussion about
what should be done to prevent TPUSA—
which was recently described by Mediaite as
the organization “known as much for racism as
it is for diaper-wearing”—from discrediting all
conservative organizations that specialize in
reaching young people.
I. Falsification of Numbers and Activities
TPUSA’s falsification of numbers and activities has been widely known
among Conservative Movement leaders for years. As a result, many groups,
reaching far more students than TPUSA, have felt pressure to inflate their own
numbers in order to compete.
Here are a few documented cases of TPUSA’s falsification of numbers
and activities.

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 1. Fabricating Results to Cover Up a Failed $2 Million Project
Kirk’s claim that TPUSA succeeded in
getting 50 conservatives elected to student
leadership positions on campuses has been so
widely discredited, the project is not even
mentioned in its 16-page 2017 Year in Review
publication.
TPUSA raised $2 million for this
project, representing 20% of its 2017 revenue.
Accountability is important to most supporters of conservative
organizations, including Doug Deason, a member of TPUSA’s advisory
council. Deason said, “How many seats we’re winning in student councils and
government councils and presidents of student bodies is really an important metric
for the organization.”
But the success Kirk claimed to
have achieved, using this metric, was
wholly fabricated. As Politico Magazine
reported on April 6, 2018:
When I contacted a random
sample of those 50 winning
candidates (including those at
Arizona State University, UCLA,
Syracuse University, Indiana
University, the University of
North Carolina and James
Madison University), all denied
they had worked with Turning
Point USA on their campaigns.
Two said they had been contacted
by the group, but the others said
they’d never dealt with anyone
from Turning Point USA, nor had
they accepted any money or other
support. Several went further and
spoke against the organization.
4

 Arielle Yael Mokhtarzadeh, the Undergraduate Students Association
Council president at UCLA, condemned Turning Point USA and said
neither she nor anyone in her campus political party, Bruins United,
has taken any money from the group. A Bruins United post on
Facebook called Turning Point USA an organization “that openly
promotes hatred and bigotry.”
Dan Niersbach, student body president at Indiana, told me via
email that he had had “no experience working with Turning
Point USA,” and “The Indiana University Student Association
does not support their divisive rhetoric nor their unethical
involvement in student government elections.”
James Franco, the Student Association president at Syracuse
University, told me he met a Turning Point USA staffer for
coffee eight months before he ran for his current post. The
staffer offered “financial backing or staffing or leadership
support,” which Franco says he did not accept. “If they took a
look at our campaign platform, I don’t think they’d want to
support us,” Franco says. “We campaigned on having
Syracuse University be a sanctuary campus.”
In total, I spoke to seven college candidates whom Turning
Point USA has, in one form or another, claimed to have
supported in their successful bids for student body president. To
a person, all said they’d never worked with the group.
2. Making Blatantly False Claims About TPUSA’s Reach
Kirk shows little to no concern for the truthfulness of his claims about
TPUSA, ignoring the contributions made by other groups, even when confronted
about blatant falsehoods. Consider:
• Kirk claims TPUSA recruited 3,850
students at CPAC in a year when the
number of students who attended
CPAC was fewer than 2,400 (and most
were already recruited by others,
including Rand Paul’s network,
Leadership Institute, Young America’s
Foundation, and CPAC’s staff).
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 • Kirk claims TPUSA has 400 chapters. In earlier years, Kirk claimed
TPUSA had 1,200 chapters. Politico reported:
Turning Point claims grassroots support on campuses
across the country, but the closer you look, the
patchier the grass sometimes seems. I searched
through about 200 different social media feeds out of
Turning Point USA’s 400 officially registered
chapters and found that multiple chapters haven’t
updated their pages in months; some haven’t been
touched in more than a year.
• Kirk claims TPUSA is the biggest and most far-reaching youth
organization in America. Even in the context of other conservative
youth organizations, this statement is blatantly false and fails to take
into account the quality of student interactions. Stopping by a
TPUSA literature table is significantly less engaging for a young
person than participating in a Leadership Institute school or
workshop, an Intercollegiate Studies Institute Honors Program, a
Fund for American Studies Robert Novak Journalism Fellowship, a
Reagan Ranch High School Conference, a 12-week National
Journalism Center internship, a Young America’s Foundation
campus lecture, the Heritage Foundation’s Young Leaders program,
the Cato Institute’s Cato University, or the American Conservative
Union’s Conservative Political Action Conference (CPAC).
II. Boosting Numbers With Racists & Nazi Sympathizers
Kirk’s obsession with inflated numbers causes him to take shortcuts that
jeopardize the reputation of the Conservative Movement as a whole, and especially
the youth-related groups. Much has been written about the racist statements made
by TPUSA employees:
• An article published by the New Yorker on December 22, 2017,
reported that Crystal Clanton, TPUSAs No. 2 executive, had
allegedly sent a text message stating, “I HATE BLACK PEOPLE.
Like f**k them all … I hate blacks. End of story.” Clanton oversaw
most of TPUSA’s full-time staff members and campus recruiting.

6

 • Mediaite released footage of Juan Pablo Andrade praising Nazis,
saying, “The only thing the Nazis didn’t get right is that they didn’t
keep f***ing going!” while attending a TPUSA event. Andrade
worked as TPUSA’s Florida field director in 2015 and led the
group’s informal Latino caucus in 2016.
• Mediaite reported on another disturbing video at the same TPUSA
event, posted by Caesar Svbervi, an alt-right activist who
participated in the Charlottesville white supremacist march and has
been filmed with Richard Spencer. Svbervi is a student at Coastal
Carolina University. The video shows him saying it was
“awesome” that he thought a car hit a woman protesting the TPUSA
event. “[The car] hit the fucking protester” and “smashed that
b**ch, that is awesome!”
Perhaps most disturbing, Mediaite reported:
Several sources with knowledge of TPUSA’s operations, who
spoke to Mediaite on the condition of anonymity, said Svbervi
was added to a “blacklist” of activists that the nonprofit’s
leadership wanted to keep away from their Student Action
Summit to avoid controversy. The list was later scrapped in an
effort to boost attendance numbers, sources said.
III. Humiliating Diaper Event—a Consequence of Inexperience
Experience is a safeguard
against poor judgment. That’s why
well-established Conservative
Movement organizations utilize the
talent of leaders with significant and
wide-ranging experience. This is
especially important for youth groups
that rely on students across the country
to advance conservative ideas.
The senior leadership of all of the other major conservative youth
organizations includes seasoned veterans of the Conservative Movement. Working
with young people can be challenging. A certain level of unprofessionalism is
inevitable. But what happened at TPUSA on October 18, 2017—where the
7

 leadership of a national organization encouraged students to humiliate themselves
by wearing diapers on campus—would never have happened under the guidance of
a more experienced team. The leaders of well-established Conservative Movement
organizations would have never approved and applauded TPUSA’s diaper event.
The Chronicle of Higher Education reported on February 16, 2018:
Months after the “safe spaces” backlash,
Turning Point continues to be the butt of
diaper-themed jokes.
[T]he October 18 event. . . featured
students dressing up as children, blowing
bubbles, and in one case, wearing a diaper
while sucking on a pacifier. The chapter
had sought to make the point that “safe
spaces are for children.” Instead, the
image of a diaper-wearing conservative
activist was relentlessly mocked on social
media.
As Salon reported on March 25, 2018, in an article
titled, “How a ‘Diaper Protest’ Imploded a Conservative
Student Group”:
The idea was to make fun of the political left by
dressing up as literal babies. But in the process,
TPUSA itself became the butt of a joke, mocked
as “Toilet Paper USA” and turned into a viral
meme by the Twitter left.
TPUSA has demonstrated that the
thought process behind a good portion of its
activism and outreach is half-baked. Now that the
activist group can't tweet or post without some lefty
troll calling up the “Toilet Paper USA”
insult, TPUSA’s latest attempts to stir the political
pot have backfired.

8

 Kaitlin Bennett, the president of TPUSA’s Kent
State chapter, was employed by TPUSA as a campus
coordinator at the time of the diaper event. She resigned
from her position on February 12, 2018. Bennett said she
was “highly disappointed in the leadership of those higher
up than me in Turning Point USA,” who lied about not
knowing about the event in advance. Bennett told The
Chronicle of Higher Education that TPUSA’s national
leaders threw her chapter “under the bus, in front of the
whole nation.”
The Independent reported on February 26, 2018, that Kirk even
congratulated Bennett personally on the chapter’s activism at a speaking
engagement the next day. “Keep up the triggering, good job,” she says he told her.
Unfortunately, the diaper event has been widely reported by the media and
has continued to discredit young conservatives since. At the time of the writing of
this memo, it has been seven months since the incident, with no end to the
humiliating diaper references on social media in sight.
IV. Unethical Activity
Here is the full text of an email Young Americans for Liberty (YAL) sent to
its supporters alerting them to TPUSA’s illegally obtaining and using YAL’s
private membership list for their own purposes:
I want to make you aware of a very serious matter that recently
impacted YAL and our members.
You may be aware of a new, fledgling group called Turning
Point USA. In fact, they may have emailed you recently without
your consent.
This occurred because they unlawfully obtained YAL’s
members list and proceeded to solicit all of our members.
Firstly, I’d like to apologize that this happened. We take
privacy very seriously at YAL, and we’ve improved our
safeguards to prevent this from ever happening again.
But more importantly, I want to strongly caution you and all
YAL chapters against working with Turning Point USA.
9

 Normally, I wouldn’t be so direct about avoiding a specific
organization. In fact, I am an enormous advocate for
cooperation and partnering with all like-minded organizations.
We have excellent relationships with groups like Students for
Liberty, the Leadership Institute, Campaign for Liberty, and
many others.
But this recent action by Turning Point USA crossed the line. I
was willing to accept the fact that their language, strategy, and
programs often attempt to copy YAL activities. I was even
willing to accept the fact that their staff has never reached out
to our staff to introduce themselves and try to work together.
But unlawfully obtaining and using YAL’s private membership
list for their own purposes just went too far and shouldn’t go
unaddressed.
Fortunately, I had our attorneys contact them directly with a
cease and desist letter. To which, they claimed they removed
all your private data from their records. So your data should
be secure once again.
But, personally, I've had enough. And after consulting with our
staff and a few Leadership Team members, we decided that it is
not in YAL’s best interest to partner with Turning Point USA.
And I strongly encourage you to avoid their solicitations.
I’m sorry I had to send this. This is not the type of decision I
like to make. But hopefully we can move forward from here,
and this will have little to no impact on you or your chapter.
Please feel free to contact me directly by replying to this email
with any questions.
For liberty,
Jeff Frazee
Executive Director
Young Americans for Liberty

10

 Other organizations have reported unethical activity, including:
• Paid TPUSA staff members attending other organizations’ events
under false pretenses and attempting to recruit for TPUSA from the
other organizations’ existing members
• Paid TPUSA staff members claiming credit for other
organizations’ events by posting pictures on social media of
students with TPUSA signs in front of other organizations’ events
• Kirk making knowingly false statements about the longtime leader
of another conservative organization to a supporter of that
organization
Another issue of potentially illegal—although not unethical—activity,
involves Kirk’s support of a number of political candidates. Several news outlets
have reported that Kirk’s activities on behalf of TPUSA may have crossed a line in
violation of laws regulating 501(c)(3) non-profit organizations. The alleged
violations call into question Kirk’s judgment—not only about risking the loss of
TPUSA’s non-profit status—but also about giving credence to the Left’s narrative
that conservative nonprofits should be more heavily regulated.
Conclusion
The Conservative Movement has historically had a healthy understanding of
competition among the separate organizations. As a general rule, organizations
recruited support for their programs by focusing on their own strengths—not by
undermining the work of other organizations. Hard work, good ideas, and a
commitment to integrity strengthened the operations of individual organizations
and the Conservative Movement as a whole.
Kirk founded TPUSA with no college experience. He has taken some
classes, but has not graduated. His focus has always been on building his own
brand, not strengthening the Conservative Movement.
Conservative leaders were understandably uneasy about criticizing a young,
entrepreneurial conservative, who had won the trust and admiration of successful
business leaders investing in TPUSA. Most remained silent, expecting Kirk to
implode or get bored and move on to another venture.

11

 The silence of conservative leaders enabled Kirk to build TPUSA at a fast
pace. Kirk reported that 20,000 supporters gave a total of $9.8 million to TPUSA
in 2017. This is double the amount he raised for TPUSA in 2016.
The long-term damage TPUSA could inflict on conservative students and
the Conservative Movement can no longer be ignored.
Although it runs counter to our instincts to advise students against becoming
involved with other conservative organizations, students deserve to be warned
about TPUSA.

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