ZACHOR LEGAL I INSTITUTE April 8. 2019 Em Ralmay Chrer Exeeurrve omeer Chaifi PBC San anclsoo. California, 94104-540! ELA Dear Mr Ramy I am me Presrdem army-er Legal Insane. a non-profit legal [mu/damn that Is devout] fighting anu- Sernirian and caminmonal righrs We have been inrormed rhur Charge org has ergaged in a eanrpargn ra supprea and aenam a pelman poswd an the Change mg sue and lave a number ofoomemslhil we would hke you no mums The perruon rn quesuan can be round 2! WW "Subjecl Pcuum") ind rs a can rar the Unned snares Gavemrnenr Ia rrnesugare we ufglobnl ma-Senrruc arganraanans rhe Unned sane: Cages rs rhe essence oreruzen pursuu orpoauve change and gavernnrenr Lhe cm or whal Change mg was founded ID pvomole Mar-he Subject pearrerr was posed raChange erg the follawug eaenrs occurred . The Subject Perruon was flagged rar mcludng mlmenls (an areuon Much unrnedrarely lands ra discredil me Iegirinracy ofa paiuon) mange org was contacted <own description, Cl'angeorg is a signi?cant force in public debate and a key source of input on government policy. In many ways, Changeorg has become a public sqmre- Furthermore, Changeorg is a Princ Bene?t Corporation, a designation that requires {Strangeorg to abide by speci?c standards to achieve its stated bane?t as set forth in its corporate charter. TWhile Changeorg has not included a copy of its corporate charter in an easily found link in its website, it indicates that as a result of Public Bene?t Corporation status, ?empowering people everywhere" is a legal part of its charter.3 Under its Terms of Service, Changeorg clearly states that it makes .. no promises about the reliability of any source or the accuracy, usefulness, safety, or intellectual property rights of any user campaign or cement, nor do we endorse any political candidates, campaigns, or petitions or support any views, opinions, endorsements, recommendations, or advice that may be posted by users? and further asserm that Changeorg does not .. monitor or review petitions, fundraiser campaigns, or other content submitted by more, or evaluate them for compliance with foreign or domestic laws and regulations You therefore use the Changeorg artd lChange Politics services and rely on any content you find at your own risk.? Changeorg also hm adopted community guidelines that allow it to remove content or restrict user accounts, the circumstances under which such actions can be taken are limited to the following: l'ate speech, violence, impersonation, violation ofprivacy, bullying, graphic content, harm to children, spam and illegal acts.5 Nothing in the Subject Petition has violated any ofthe community guidelines or terms of service. In fact, even though Changeorg?s Terms of Service clearly state that Cl'cmgeorg doesn?t monitor petitions or support political positiors, that is exactly what has happened when Changeorg acted to flag, demonetise and shadowban the Subject Petition. Moreover, when the Subject Petition was challenged for accuracy, supporting documentation was provided and Changeorg continued to apply the contested content flag to the Subject Petition. This clearly is at odds with Changeorg?s Terms of Service and communityr guidelines. The negative effects of Cl'iange.org's wrongful treatment of the Subject Petition have damaged the sponsor of the Subject Petition and have materially and advermly affected the Subject Petition. The sponsor of the Subject Petition has been denied fitnncial support that other Changeorg petitions may receive and the number of signatories for the Subject Petition has been arti?cially limited by Changeorg?s capricious and, possibly, discriminatory, imposition ofcensure. Changeorg presents itselfas, and is in fact, a public forum meant to facilitate the right ofthe people to petition the government for a redress of grievances. While the Constitution?s First Amendment does not generally apply to private parties acting as such, when such a party operates and controls public platforms used by the public for public bene?t, that party becomes a quasi-state actor and can be held liable for First Puttendment violations The fact that Changeorg is also a Public Bene?t Corporation bolsters the need for Changeorg to be free from discrimination and allow all viewpoints to be expressed withoti come or other infringement. We believe that the evidence set forth above demonstrates that Clemgeorg has subjected the Subject Petition to a discriminatory campaign of democratization, shadowbaruiing and censorship, in violation of Changeorg?s own policies, governance standards for Public Bene?t Corporations and applicable state and federal laws, including anti?discrim ination principles of Califontia and Delaware law, federal prohibitions on wire fraud?; and the First Amendment. Because Changeorg?s actions have already imposed significant and long-lasting harm on the campaign to promote and hind the Subject Petition, we ask that you take the following acts: - accessed April 3, 2019. aw.hchm1,ge. ore. of?sen ice-=3 accessed April 8, 2019. change. org- policiesi?petitions, accessed April 3 2019. 6 We believe that by interfering with the sponsor ofthe Subject Petition's fundraising campaign on Changeorg, Changeorg may be in violation of IS U.S.C. ?l343. Zacnoa LEGAL 2 Provide us with information that will allow usto quantifyr the ?nancial harm of lost donations as a result of Grangeorg's adverse actions taken against the Subject Petition (including, but not limited to, number of users 1who visited the Subject Petition ?om the time it was posted until the pre sem day and the average donation received by similar petitions}; 2. Provide complimentary Promoted Petition status for Ihe Subject Petition to remediate the 11111.11 done to the Subject Petition; 3. Aclmowledge that the actions taken gainst the Subject Petition Tsi'ere wrongful and issue a public statement to that effect; 4. Remove the flag from the Subject Petition; 5. Allow Changeorg users to donate to the campaign for the Subject Petition; 6 Allow Changeorg users to search for, comment on and sign the Subject Petition through the Clangeorg platfonn; Tennirnte the activity that prevented outside search engines from having aoceas to the Subject Petition; and 3. Provide us with a copy obeangeorg?s corporate charter and other documents that specify its purpose as a Public Bene?t Corporation. We reserve the right to take an}:r and all legal action applicable the enforcement of the matters outlined in this letter and would appreciate acknowledgement of this letter within seven calendar days of receipt. Should you need additional infonnatiom please feel free to contact me at the email address above. On behalf of Zachor Legal Institute, mt Wk Marc Greendorfer President chnoa LEGAL INSTITUTE 3