ALIPAC's formal FEC complaint against Google, Facebook, & Twitter

Lisa J. Stevenson
Acting General Counsel
Office of General Counsel
Federal Election Commission
1050 First Street, NE
Washington, DC 20463


October 21, 2020 (Amended Oct 30, 2020)

This is a formal complaint being filed under 52 U.S.C. § 30109(a)(1) of the Federal Election Campaign Act (“FECA”) on behalf of Americans for Legal Immigration PAC (“ALIPAC”). Based upon information and belief, as set forth below and in the attached materials, ALIPAC believes that Twitter, Inc. (“Respondent”), Facebook, Inc. (“Respondent”), and Google, Inc. (“Respondent”) have violated FECA and the Commission’s Regulations by making numerous and systematic corporate in-kind contributions to the Democratic Party and Democratic campaigns for public office (including but not limited to Joe Biden for President), through acts of censorship, abuse, suppression, coercion, intimidation, and unequal treatment of Republicans, conservatives, Christians, and other individuals and groups who oppose the shared political philosophies of these companies and the vast majority of their employees.


I, William Gheen of PO Box 30966, Raleigh, NC, 27622, as both as an individual victim and as a spokesman for the national organization Americans for Legal Immigration PAC (Founded 9/11/2004 FEC ID: C00405878 ), do hereby swear and affirm under penalty of perjury I am accurately presenting the following evidence attached, which I believe shows the corporations of Google, Facebook, and Twitter are unlawfully using corporate resources and employees to affect the outcome of US elections based on the numerous media and victim reports cited in this document.

While there are numerous reasons to believe multiple Silicon Valley corporations are acting in collusion to influence the outcome of US elections on behalf of the Democratic Party and Democratic Party candidates (including Joe Biden), the most egregious violators appear to be Google, Facebook, and Twitter from the evidence we've gathered.

This official complaint focuses on reports of election law violations by employees under the direction and control of:

Google, Inc.
CEO: Sundar Pichai
1600 Amphitheatre Parkway
Mountain View, CA 94043, USA
(650) 253-0000

Facebook, Inc.
CEO: Mark Zuckerberg
Facebook 1 Hacker Way
Menlo Park, CA 94025
1-650-308-7300

Twitter, Inc.
CEO Jack Dorsey
Twitter Headquarters 1355 Market St. Ste. 900
San Francisco, CA 94103
1-415-222-9670

Federal campaign finance law strictly prohibits corporations from making contributions to federal candidates. 52 U.S.C. § 30118(a); 11 C.F.R § 114.2(b). The term “contribution” is defined in relevant part to mean “anything of value made by any person for the purpose of influencing an election,” and includes in-kind contributions such as services. 11 C.F.R. §§ 100.52(a) & 100.52(d)(1).

It is proven and accepted that search engines listing prominence, rankings, and visibility and reach on social media platforms of the censored contents, individuals, and organizations documented in this complaint are of value because each day American individuals and companies spend millions of dollars at Google, Facebook, and Twitter to advertise their products, services, campaigns, and policy positions. This fact is also illustrated by the vast amount of campaign expenditures detailed in Federal Election Commission PAC and campaign reports found at FEC.gov where these "things of value" are purchased from Google, Facebook, and Twitter.

The stunning value of having your PAC, campaign, interest group, non-profit, or company's opposition shadow-banned, suppressed, censored, silenced, coerced, intimidated, threatened, or being placed upon an uneven playing field by these partisan companies and employees must surely be astronomical.

Therefore, we believe these companies offer the Democratic Party and Democratic campaigns things of great value by censoring, suppressing, silencing, threatening, punishing and abusing their political opposition and opponents.

Please accept and review the following compilation of evidence which is being submitted to the FEC both electronically and in hard copy.

Upon the request of the commission, we can provide hundreds of additional sworn-affidavits from victims of similar political censorship and abuse by Facebook, Google, and Twitter.

While each company can cite some examples of left-leaning groups they have censored, we believe our list shows an overwhelming impact on Americans who oppose the left-wing views, policies, and candidates favored by the owners, managers, CEOs, and employees who dominate Google, Facebook, and Twitter.

We urge the commission to act quickly and decisively as new victims are being added to the tracking list each week. American elections and citizens must be protected from this new form of electronic totalitarianism and abuse of power in the information age.

We believe that this extensive list of evidence makes it clear that Facebook, Twitter, and Google employees are using their company power and resources to affect the outcome of legislation, policies, and elections by silencing or diminishing those who would oppose their political and campaign and elections goals.

Direct Impact

As you can see in our Oct 2, 2018 report to Congress which is now in the Congressional Record housed in the Library of Congress (first link below for ALIPAC), we have numerous reasons to believe these three companies have cut website traffic to our website and archives at ALIPAC.us and our videos on Youtube for political reasons.

Google: This company has taken us from page 1 search results on our most important search term "illegal immigration" to not being listed in the top 100 pages. We also believe allowed someone at their company to hack and destroy our Youtube channel and when we rebuilt it they demonetized us, removed and censored videos, and block us from placing ads or being able to live stream. We are certain that if our PAC supported Google's political agenda on immigration matters, these problems would not be present. ALIPAC's positions on immigration issues shared by most Republicans are being censored, blocked, and sandbagged by Google while similar organizations who support the Democrat and Google favored positions prosper on their platform.

Facebook: We believe Facebook has applied hidden restraints on our pages to limit our growth and reach. We have caught Facebook censoring search results for our events and playing favorites in support of online trolls attacking our attempts to assemble in favor of our issues. Facebook has locked us out of our main pages just prior to national events we organized without explanation. In August of 2018, Facebook admitted they wrongfully removed political content and banned me from the platform and promised they would restore the censored posts and my access. While my ban was lifted, they never restored the post they censored.

Twitter: Twitter refuses to certify my account despite numerous requests and refuses to allow us to run ads or promote content. In November of 2017, Shortly after a Twitter employee briefly deactivated President Donald Trump's account, Twitter rejected our ad to encourage Americans to call Congress against Amnesty legislation falsely labeling our ad as "hateful content." Our ad was an image of a woman shouting into her phone and simply read, “CALL CONGRESS TO STOP AMNESTY NOW!”

Over Christmas of 2017, my account was suspended for 7 days over posts that did not violate Twitter TOS but was our celebration over defeating Dream Act Amnesty legislation before the break. Twitter called it “hateful content” and banned us for 7 days and took away our ability to ever place ads again. (Screen Shots and documentation in source links below)

Indirect Impact

We have included a total of 150 examples with documentation of Facebook, Google, and Twitter censoring, suppressing, and abusing other opponents of the political left in America to show there is clear cause to believe these violations of American laws and civil rights are extensive, systematic, and intentional. The evidence we are providing the FEC gives your regulatory agency proof and documentation of what is already a widely held belief that conservatives are being targeted.

While these Silicon Valley companies and their backing left-leaning political non-profit groups will often claim they are censoring content that is somehow "racist" or "hateful", closer inspection on a case by case basis finds there is often no evidence to support their claims and that such explanations are being offered to conceal their poltical bias and skullduggery.

At the time of this complaint, our tracking list currently contains 150 examples of conservatives and varied opponents of the left who have been banned, censored, abused, or oppressed by these platforms and can be accessed online at:

ALIPAC's List of Conservatives Censored by Silicon Valley companies Facebook, Google, Twitter
https://www.alipac.us/f31/list-conservatives-censored-silicon-valley-companies-facebook-google-twitter-363125/


Specific examples offered as evidence for our beliefs and concerns:

Documentation & Evidence List of #150 victims (Hard copy print outs available upon request)

Direct Impact on ALIPAC and William Gheen documentation

ALIPAC
ALIPAC Report To Congress on Silicon Valley Censorship
https://www.alipac.us/f8/alipac-repo...orship-363704/

https://www.washingtontimes.com/news/2018/aug/23/facebook-admits-error-deleting-william-gheen-immig/

https://www.breitbart.com/tech/2017/11/17/twitter-bias-continues-yanks-ad-promoting-legal-immigration-hate-speech/

https://www.breitbart.com/tech/2016/...l-immigration/
https://www.wnd.com/2018/01/twitter-...KoDA0D0oCBW.99


Indirect Impact Examples

Ryan Hartwig: Former Facebook content moderator at Cognizant. confirming bias against conservatives as an eye-witness during interview with Tim Poole of Timcast (View Here)
Video
https://youtu.be/QhTSp2aM700


U.S. Border Chief Mark Morgan Locked Out of Twitter Account for Border Wall Post (Sent as an amendment to FEC Oct 30, 2020)
https://www.alipac.us/f12/report-u-s...wall-p-380301/

White House press secretary Kayleigh McEnany
https://www.alipac.us/f9/twitter-loc...r-bide-380124/

The Trump Campaign
https://www.alipac.us/f9/twitter-sus...iden-s-380134/

The New York Post
https://www.alipac.us/f9/twitter-blo...emails-380115/

Lauren Witzke Republican candidate for U.S. Senate in Delaware
https://www.alipac.us/f12/twitter-ce...conduc-380075/

Acting Director of National Intelligence Ric Grenell
https://www.alipac.us/f9/twitter-loc...arning-380053/

Facebook Censors Tucker Carlson for ‘False News’
https://www.alipac.us/f9/facebook-ce...ews%92-379934/


Trump Voter Joan Herbert
https://twitter.com/OutnumberedOT/st...004971523?s=20

Center for Immigration Studies
https://www.alipac.us/f12/twitter%92...l-show-363089/

Ann Coulter
http://video.foxnews.com/v/582797040...#sp=show-clips

President Donald Trump
https://www.theverge.com/2018/8/29/1...edia-followers

Alex Jones & Infowars
https://www.alipac.us/f19/twitter-pe...-abuse-362453/

Milo Yiannopoulos
https://www.vox.com/2016/7/20/12226070/milo-yiannopoulus-twitter-ban-explained


Prager University
https://www.prageru.com/press-releas...discrimination

https://www.prageru.com/breaking-wor...ts-public-view

https://www.prageru.com/petitions/yo...eos-fight-back

GOP Rep. Marsha Blackburn
https://www.alipac.us/f19/leaked-emails-senior-google-search-engineer-advocates-censorship-%91terrorist%92-363693/

https://www.tennessean.com/story/new...ech/551572002/

Diamond and Silk
https://www.usatoday.com/story/news/...ess/554769002/

Laura Loomer
https://mobile.twitter.com/LauraLoom...44157755314177

https://m.youtube.com/watch?v=wT9Kz96cT9

The Tennessee Star for articles critical of Tennessee Democratic Senate Candidate and former TN Governor Phil Bredesen, who is running against Republican Senate Candidate and current TN Congressman Marsha Blackburn
http://tennesseestar.com/2018/08/24/...phil-bredesen/

"Activist Mommy" Elizabeth Johnston
https://www.christianpost.com/news/7...489/page4.html

California Republican congressional candidate Elizabeth Heng
https://www.enidnews.com/opinion/col...87952d5ae.html

Executive Director of the Ron Paul Institute Daniel McAdams
https://www.newsweek.com/ron-paul-tw...valley-1063378

Overpasses for America
https://www.breitbart.com/tech/2016/05/18/facebook-censoring-content-critical-immigration

Ex-Muslims of North America
https://www.nationalreview.com/2018/...r-and-unequal/

Canadian intelligence expert and prominent anti-Islamist researcher Tom Quiggin
https://torontosun.com/news/national...-terror-expert

Robert Spencer and Jihad Watch
https://pjmedia.com/homeland-securit...to-silence-me/

David Horowitz of FrontPage magazine
http://www1.cbn.com/cbnnews/2018/aug...ervative-purge

James Allsup
https://www.seattletimes.com/seattle...t-provocateur/

Steven Crowder
https://dailycaller.com/2018/03/14/t...teven-crowder/

Fox News contributor Michelle Malkin
https://www.breitbart.com/radio/2018...wrong-phrases/

Mike Cernovich
https://www.thegatewaypundit.com/201...s-not-blocked/

Paul Joseph Watson
https://www.thegatewaypundit.com/201...s-not-blocked/

TGP's Jim Hoft
https://www.thegatewaypundit.com/201...s-not-blocked/

Jack Posobiec
https://www.thegatewaypundit.com/201...s-not-blocked/

Lauren Southern
https://www.dailymail.co.uk/news/art...ensorship.html

Mark Dice
https://christophercantwell.com/2014...anned-youtube/

Stefan Molyneux
https://christophercantwell.com/2014...anned-youtube/

#WalkAway founder Brandon Straka
https://davidharrisjr.com/social-and...ensored-again/

Larry Klayman of Freedomwatch
https://www.foxbusiness.com/technolo...ive-censorship

Human Coalition
https://www.christianpost.com/voice/...f-control.html

Pastor Rich Penkoski of West Virginia
https://www.christianpost.com/voice/...f-control.html

Steven Andrew, a conservative Christian Silicon Valley entrepreneur
https://www.christianpost.com/voice/...f-control.html

The Declaration of Independence
https://www.washingtonpost.com/news/...=.5f4f76f9298e

Wes Cook band's song "I Stand For The Flag"
http://www.foxnews.com/tech/2018/07/...otic-song.html

Lila Rose of Live Action
https://youtu.be/mh8FrKKd3p0

Operation Rescue
https://thehill.com/blogs/congress-b...ored-on-social

Republican Party chair Ronna McDaniel
GOP Rep. Mark Meadows
GOP Rep. Jim Jordan
GOP Rep. Matt Gaetz
Trump Jr.’s spokesman Andrew Surabian
https://news.vice.com/en_us/article/...=vicetwitterus

Dennis Michael Lynch
https://www.breitbart.com/tech/2016/...l-immigration/
https://www.alipac.us/f19/truth-denn...nsored-352668/
http://dennismichaellynch.com/conser...ng-censorship/

ACT! for America founder Brigitte Gabriel
https://www.breitbart.com/tech/2018/...-and-depraved/

LifeSite News
https://www.lifesitenews.com/news/li...dia-censorship

Islam critic Pamela Geller
https://www.breitbart.com/tech/2016/...icizing-islam/

Legal Insurrection
https://legalinsurrection.com/2017/0...tions-channel/

Turning Point USA director of communications Candace Owens
https://www.westernjournal.com/ct/ce...racist-tweets/

James Woods Suspended From Twitter Over Satirical Meme That Could "Impact An Election"
https://www.zerohedge.com/news/2018-...mpact-election

Gavin McInnes
https://www.breitbart.com/tech/2018/...gavin-mcinnes/

Nick Loeb
http://www1.cbn.com/cbnnews/entertai...out-roe-v-wade

Kathleen McKinley
https://dailycaller.com/2018/07/27/t...nder-military/

Florida State Rep. Matt Caldwell (second amendment ad)
https://ijr.com/2018/07/1111565-face...un-pro-nra-ad/

Luke Rudkowski of WeAreChange
https://dailycaller.com/2017/08/11/c...emonetization/

Jamie Glazov Editor of Frontpage Magazine
https://www.breitbart.com/tech/2018/...hots-of-abuse/

Sam Westrop of Islamist Watch
https://www.nationalreview.com/2018/...r-and-unequal/

GAB.ai
https://www.city-journal.org/html/wh...web-15586.html

CPAC gathering
Mitt Romney
Rand Paul
Glenn Beck
Ted Cruz
Wisconsin Gov. Scott Walker
Drudge Report
Chris Kyle, the former Navy SEAL who was murdered in 2013
Fox News contributor Steven Crowder
Red State
Breitbart
Washington Examiner
Newsmax
https://gizmodo.com/former-facebook-workers-we-routinely-suppressed-conser-1775461006

San Diegans for Secure Borders (SDSB)https://www.breitbart.com/tech/2018/...ravan-protest/

Veterans of Foreign Wars
https://www.westernjournal.com/veter...llen-brothers/

ImperatorRex
https://www.thegatewaypundit.com/201...hearing-today/

Camp Constitution
https://mailchi.mp/82b972d901b6/camp...zed-by-youtube

MassResistance
https://mailchi.mp/massresistance/ma...gbt-complaints

Amy Dryden
https://bigleaguepolitics.com/breaki...ugh-classmate/

Daily Caller and Breitbart News
https://www.alipac.us/f9/google-empl...search-367157/

Pro-Trump conservative Scott Presler
https://www.alipac.us/f9/top-pro-tru...murder-368798/

Facebook user Dana Marie
https://www.alipac.us/f9/top-pro-tru...murder-368798/

Christian Leader Franklin Graham
https://www.alipac.us/f9/conservativ...-faceb-368379/

The Gateway Pundit
https://www.alipac.us/f9/political-b...search-368356/

Brian Kolfage's Trump Wall GoFundMe page
https://www.alipac.us/f9/trump-wall-...campai-367960/

Blonde In The Belly of The Beast
https://youtu.be/aXko_CeXOJ8

Young black conservative CJ Pearson
https://www.alipac.us/f9/updated%85-...in-gop-367102/

Bitchute
https://www.alipac.us/f9/paypal-blac...ute%92-366459/

Facebook Employee Palmer Lucky
https://www.alipac.us/f9/conflicting...conser-366310/

Musician Benton Blunt
https://www.foxcarolina.com/news/gre...705d99824.html

Angel Mom Agness Gibbony
https://www.facebook.com/photo.php?f...type=3&theater

Conservative Gay Activist Scott Presler
https://www.thegatewaypundit.com/201...dering-blacks/

Angel Mom Agnes Gibbony
https://www.facebook.com/photo.php?f...type=3&theater

Conservative Raheem Kassam
British radical Islam opponent Tommy Robinson
https://www.alipac.us/f9/mohammad-sh...gram-b-370198/

Zero Hedge
https://www.alipac.us/f9/war-conserv...rds%92-370429/

Jesse Lee Peterson
https://www.alipac.us/f9/youtube-goo...terson-373232/

Youtube Google Censors James Okeefe of Project Veritas
https://www.alipac.us/f9/youtube-goo...eritas-373249/

Free Thought Project
Antimedia
Nation in Distress
Reasonable People Unite
The Resistance
Right Wing News
Snowflakes
https://www.alipac.us/f9/facebook-pu...rvative-364313/

Clash Daily
https://www.alipac.us/f9/facebook-cl...-elect-364359/

Irish Filmmaker Phelim McAleer
https://www.alipac.us/f9/facebook-bl...ionist-364585/

Trump’s social media chief Dan Scavino
https://www.washingtonexaminer.com/w...o-reason-given

Natural News
https://www.alipac.us/f9/tag-team-te...er-dai-373129/

Ben Shapiro
Jordan Peterson
https://www.alipac.us/f9/stunning-ny...ed-pus-373140/

John Lott
https://crimeresearch.org/2019/07/tw...-wont-explain/

Ken Webster Houston Radio Show Host
https://radioink.com/2019/07/15/ihea...from-facebook/

Angel Mom Mary Ann Mendoza
https://www.alipac.us/f9/angel-mom-m...brance-374425/

GOP Senate Majority Leader Mitch McConnell
https://www.alipac.us/f9/twitter-loc...rs-his-374840/

Rush Limbaugh
The Christian Post
LifeNews
Kyle Drennen of the Media Research Center
https://www.alipac.us/f9/google-does...erally-375165/

Right Side Broadcasting
https://www.alipac.us/f9/google-evil...networ-375376/

Conservative Street Artist Sabo
https://www.alipac.us/f9/paypal-de-p...months-375953/

GOP Candidate Marjorie Taylor Greene
https://www.alipac.us/f9/censored-twitter-suspends-female-gop-congressional-candidate-after-trans-criticism-375973/

https://www.facebook.com/watch/live/...f_t=live_video

GOP Candidate Danielle Stella
https://www.alipac.us/f19/republican...pended-376137/

Conservative Comedian Terrence K. Williams
https://www.alipac.us/f13/conservative-comedian-terrence-k-williams-wrongfully-banned-facebook-2018-a-376620/

Judicial Watch
https://www.alipac.us/f9/stunning-yo...chment-376663/

Borderland Beat
https://www.alipac.us/f9/facebook-de...tivity-377095/

QAnon & VDARE
https://www.alipac.us/f19/facebook-r...russia-378106/

US GOP Senator Tom Cotton
https://www.bloomberg.com/news/artic...unt-over-tweet

British columnist Katie Hopkins
https://www.cnn.com/2020/06/19/busin...ins/index.html

Family Research Council
https://www.alipac.us/f9/amazon-bloc...rogram-378675/

Republican National Committee (RNC)
https://www.foxnews.com/politics/fac...ils-new-policy

Ashley Rae Goldenberg and Louis Shenker
https://culttture.com/2020/exclusive...-from-twitter/

Roger Stone
https://www.alipac.us/f9/breaking-fa...s-inca-378909/

ex-Google and Facebook employee, Patrick Shyu
https://www.alipac.us/f9/facebook-de...rative-379081/

The National Pulse
NewsBusters
The Bongino Report
Human Events
https://www.mediaite.com/news/ex-goo...sterious-list/

Donald Trump Jr.
https://www.engadget.com/twitter-don...141612714.html

America's Frontline Doctors
https://www.alipac.us/f9/dr-simone-g...ebsite-379206/

Millie Weaver aka Mellinial Millie
https://summit.news/2020/08/17/viral...makers-arrest/

Independent Video Journalist Ford Fischer (Censored for covering violent BLM activists)
https://twitter.com/FordFischer/status/1302391363456176128


We also intend to file formal complaints on these matters with the Civil Rights Division of the United States Department of Justice and with the Federal Communications Commission (FCC) and the Federal Trade Commission (FTC) as well as many state and federal elected officials.

Submitted respectfully and truthfully to the best of my knowledge,



William Gheen
President of Americans for Legal Immigration PAC
PO Box 30966
Raleigh, NC 27622
(919) 787-6009

Illegal Immigration Fighting PAC Files FEC Complaint against Big Tech Censorship

Agency provided with documentation and evidence of censorship and suppression of 148 opponents of the left.
https://pbs.twimg.com/media/Ek3z2E5X...jpg&name=small

Share and discuss this press release by email and on (FACEBOOK HERE) .. (TWITTER HERE) .. (ALIPAC HERE) .. (GAB HERE) .. (LINKED IN HERE) .. (PARLER HERE) .. (SLUG HERE) .. (MINDS HERE) .. (BRIGHTEON HERE)

For National Release | October 21, 2020

https://www.alipac.us/f8/illegal-imm...orship-380194/

Timcast IRL - Facebook Whistleblower In Studio EXPOSES Election Interference And Censorship

https://youtu.be/QhTSp2aM700

<br>https://youtu.be/QhTSp2aM700

Twitter Censorship of US Border Chief Mark Morgan Added FEC Matter Under Review MUR 7834


For National Release | October 29, 2020
https://pbs.twimg.com/media/Elh_Uo2X...jpg&name=small
Share & Discuss this national press release by email and on (FACEBOOOK HERE) .. (TWITTER HERE) .. (GAB HERE) .. (ALIPAC HERE) .. (LINKED IN HERE) .. (PARLER HERE) .. (SLUG HERE) .. (MINDS HERE) .. (BRIGHTEON HERE)

https://www.alipac.us/f8/twitter-cen...review-380305/