Iowa Gun Owners
P.O. Box 3585, Des Moines, IA 50323   www.IowaGunOwners.org

May 3, 2017
To: Carmine Boal
Chief Clerk of the House
Statehouse
Des Moines, IA 50319
To: Members of the House Ethics Committee
Representatives’ Taylor, Baxter,
Thede, Cohoon, Kearns, Lundgren
Statehouse
Des Moines, IA 50319
Dear Ms. Boal and Members of the Committee:
I am in receipt of the complaint sent to my office dated April 24, 2017, and would request
that you dismiss this complaint as it is completely without merit and not valid in form or
substance.
Please allow me to elaborate.
In his complaint, Representative Clel Baudler alleges that I, individually, and Iowa Gun
Owners, organizationally, are required to register as a lobbyist, as our organization
engages in activity that advocates for and against legislation before the General
Assembly.
Representative Baudler appears to suffer from a lack of understanding of Iowa code and
the Legislative Services Agency’s (LSA) definition of direct lobbying activities.

A. Not Required to Register per LSA Policy
Included in the complaint sent to me was the LSA’s current position on the definition of
lobbying, lobbyists, and exceptions to those definitions.
On page two of that document are the listed exceptions to the term lobbyist, specifically
for those that appear before the legislative branch. I quote:
Unpaid or Non-designated Lobbyist: An individual who is a member, director, trustee,
officer, or committee member of a business, trade, labor, farm, professional, religious,
education, or charitable association, foundation, or organization who either is not
paid compensation to be a lobbyist or is not specifically designated as a lobbyist by
an organization. (Emphasis added.)
To summarize: A director of a charitable organization who is either not paid to lobby or

 who is not specifically designated as a lobbyist is exempt from having to register as a
lobbyist. Please note the use of the word “or.”
The word “or” clearly means that a person is not required to register if they meet the first
two criteria above and either of the last two.
I meet all four of these criteria.
1. As Representative Baudler correctly pointed out in his complaint, my title is and
has always been that of the ‘Executive Director’ of Iowa Gun Owners -- meeting
the definition of ‘director’ in the LSA’s exception above.
2. As Representative Baudler also correctly pointed out, Iowa Gun Owners is a
nonprofit 501c4 charitable organization and is registered as such with the IRS and
Iowa Secretary of State -- meeting the definition of a ‘charitable association,
foundation, or organization’ in the LSA’s exception above.
3. I have never been paid to be a lobbyist for Iowa Gun Owners. Further, in his
complaint, Representative Baudler himself provides proof of this by showing
previously filed lobbyist reports in which I show no compensation -- meeting the
definition of someone who ‘is not paid compensation to be a lobbyist’ in the
LSA’s exception above.
4. As stated in point 1 above, my title is and has always been that of “Executive
Director” going back to 2009. I have never been “specifically designated” as a
lobbyist -- in keeping with the LSA’s definition listed above. Representative
Baudler offers no proof to the contrary other than his opinions.
This definition of exceptions to the lobbyist definition is crystal clear and I clearly meet
that definition.
Representative Baudler goes on with specious speculation that I am “specifically
designated,” without providing any evidence thereof, because there is none. I am not so
“specifically designated.”

B. Not Required to Register per Iowa Code
Representative Baudler provided incomplete and out of context quotes as well as
selective interaction with the applicable code section which is the controlling definition in
Iowa Code section 68B.2(13), which says:
“ ‘Lobbyist’ means an individual who, by acting directly, does any of the following:
(1) Receives compensation to encourage the passage, defeat, approval, veto, or
modification of legislation, a rule, or an executive order by the members of the general
assembly, a state agency, or any statewide elected official.

 (2) Is a designated representative of an organization which has as one of its purposes the
encouragement of the passage, defeat, approval, veto, or modification of legislation, a
rule, or an executive order before the general assembly, a state agency, or any statewide
elected official.
(3) Represents the position of a federal, state, or local government agency, in which the
person serves or is employed as the designated representative, for purposes of
encouraging the passage, defeat, approval, veto, or modification of legislation, a rule,
or an executive order by members of the general assembly, a state agency, or any
statewide elected official.
(4) Makes expenditures of more than one thousand dollars in a calendar year, other than
to pay compensation to an individual who provides the services specified under
subparagraph (1) or to communicate with only the members of the general assembly
who represent the district in which the individual resides, to communicate in person with
members of the general assembly, a state agency, or any statewide elected official for
purposes of encouraging the passage, defeat, approval, veto, or modification of
legislation, a rule, or an executive order.” (Emphasis added.)
Please note the use of the words “by acting directly” at the onset of this section.
Iowa Gun Owners, and myself as the Executive Director, is a grass roots organization
which exercises First Amendment rights via direct mail, emails, social media, earned
media, radio ads, TV ads, and in-person meetings with our membership, to encourage our
members and other interested parties to petition and speak their mind to the legislature
both during the legislative season and the election season.
Consequently, there are no direct lobbying activities by me. Rather, our members and
others of a like mind on our issue contact their representatives on their own behalf.
One only would have to observe what Speaker Pro-Tem Matthew Windshitl said about
me in floor debate on April 6, 2017, as proof of this, when he said, “Ask anybody in this
chamber, or the chamber across the hall how many times they’ve been talked to by Aaron
Dorr this year. Now, I ask my colleagues in this room, I’m going to ask them here in
public, you’re not going to be able to see it on video, but I’ll tell you, you can call them
and find out the answer later, can anybody in this room that is a legislator raise your hand
here today and say Aaron Dorr personally talked to me about this bill HF517 which he is
taking credit for. Anybody!? [ Brief Pause] Not a hand.” (Source: http://bit.ly/2pDOzU2
4:44:28 - 4:45:04)
A review of the House Journal of this April 6 floor action shows that the members of the
House Ethics Committee, with the exception of Representative Kearns, were present and
voted either “Aye” or “Nay” on House File 517. As this vote occurred moments after
Representative Windshitls comments, one would assume that you, personally, were given
a chance to specify whether you were personally lobbied by me and confirmed that you

 were not by not raising your hand.
Representative Baudler’s poor arguments about what he considers to be lobbying (e.g.
membership correspondence via email and Facebook alerts) are also irrelevant and, more
importantly, incorrect in light of the published LSA definition and the code of Iowa
definition of direct lobbying as cited above.
This also sets me apart from actions taken by this committee earlier this year in a case
that, while similar in charge, is different in fact. I do not do direct lobbying, whereas the
lobbyist in that case never denied conducting direct lobbying activities.
In paragraph 25, Representative Baudler makes another inaccurate and faulty conclusion
in stating that I was “aware” that the “law and rules” require registration as a lobbyist,
because of my prior registration as a lobbyist.
However, upon review of the exceptions specified in the LSA guidelines it was
previously determined that my activities do not require registration as a lobbyist, if ever
they did. Representative Baudler’s assertions to the contrary are baseless assertions
lacking any evidence.

Summary
Representative Clel Baudler and I have had an almost ten-year long political battle over
his view of the Second Amendment in which we’ve highlighted his positions via our
website, emails, activities in his district and -- as recently as last month -- in videos that
have been seen by tens of thousands of gun owners in Iowa.
His anger towards me, politically and personally, has clouded his judgement with regards
to the LSA’s defined exceptions to the lobbyist definitions and Iowa code 68B which
clearly specifies ‘direct action’ as a condition of being a lobbyist. This likely explains
why he selectively interacted with the Iowa code in his complaint, too.
The mere fact that he’s seeking punitive monetary damages speaks volumes as to his
motives as, to the best of my knowledge, this committee lacks the authority to even
impose such a sanction per the House Code of Ethics Rule 12(g), and has no immediately
discoverable history of imposing such punitive damages.
Iowa Gun Owners’ long-standing methodology of informing and mobilizing grassroots
gun owners to lobby their own legislators on a personal basis is well established at the
Capitol, and as evidenced by Speaker Pro-Tem Windshitl’s remarks from last month.
With the Speaker Pro-Tem already using the ‘People’s House’ as a bully pulpit to attack
me personally, I would hope that this committee, in light of the facts listed above, would
not further allow a member of the House to use this committee as tool to go after a
political opponent.

 Conclusion
This overt attempt to stifle the exercise of First Amendment rights of thousands of
Iowans should be met with a high level of scrutiny before this becomes part of the public
record and lead to litigation unbecoming to the dignity of the House and this Committee.
The complaint does not meet the validity standard set forth in the Iowa Code section
68B.31(6), which says:
“A valid complaint must allege all of the following:
a. Facts, that if true, establish a violation of a provision of this chapter, the rules
governing lobbyists, or the code of ethics for which penalties or other remedies are
provided.
b. That the conduct providing the basis for the complaint occurred within three
years of the filing of the complaint.
c. That the party charged with a violation is a party subject to the jurisdiction of the
ethics committee.”
Representative Baudler does not present facts, rather his baseless complaint is filled with
innuendo, falsehoods, abject speculation, arguments about what he thinks the law should
be, and a variety of other irrelevant allegations.
If anything, Representative Baudler provides in his complaint the very factual
information necessary to establish that my organization and I are exempt from registering
per the referenced provisions of Iowa Code and stated LSA policy.
For the aforementioned reasons, the House Ethics Committee rightly should dismiss this
complaint as it is totally without merit and not valid in form or substance.
Sincerely,

Aaron Dorr
Executive Director
Iowa Gun Owners