It is with evidence-backed examples like those detailed in the reports linked above and herein that someone can best discern just how treacherous the ‘rigged system’ has become.

 

If government is allowed to openly or secretly collude with private corporate officials to stifle free speech, it is a major threat to all of our civil liberties. But to the extent that such examples are becoming more publicly known, it could be that this is fostering an opportunity for what some are calling the “great awakening” of the otherwise distracted American public.

 

What follows in Part III of this report is information from the pleadings linked here. In case of a glitch caused by cutting and pasting the information from the PDF copy of the case pleadings by the Daily Signal, the Federalist, Texas AG Ken Paxton vs. the State Department et al into this publishing software, the PDF should be seen as the correct information. For ease of reading, the following items are provided. Note that Bing AI on 12.11.2023 said that no case number could be found to this suit yet.

 

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS 

TYLER DIVISION

THE DAILY WIRE, LLC;  FDRLST MEDIA, LLC; and THE STATE OF TEXAS, by and through its Attorney General, Ken Paxton,  Plaintiffs, v. DEPARTMENT OF STATE; GLOBAL ENGAGEMENT CENTER; ANTONY BLINKEN, in his official capacity as Secretary of State; LEAH BRAY, in her official capacity as Deputy Coordinator of the State Department’s Global Engagement Center; JAMES P. RUBIN, in his official capacity as Coordinator for the Global Engagement Center of the State Department; DANIEL KIMMAGE, in his official capacity as the Principal Deputy Coordinator for the Global Engagement Center at the State Department; ALEXIS FRISBIE, in her official capacity as Senior Technical Advisor of the Technology Engagement Team for the Global Engagement Center at the State Department; PATRICIA WATTS, in her official capacity as the Director of the Technology Engagement Team at the Global Engagement Center at the State Department,

                      Defendants.

 

COMPLAINT FOR

DECLARATORY AND

INJUNCTIVE RELIEF

 

Case No. ___________

COMPLAINT

NATURE OF THE ACTION

Plaintiffs The Daily Wire, LLC (“The Daily Wire”), FDRLST Media, LLC (“The

Federalist”), (jointly “Media Plaintiffs”), and the State of Texas bring this civil action to halt one of the most egregious government operations to censor the American press in the history of the nation against the above-named Defendants for declaratory and injunctive relief, and other appropriate relief, and allege as follows:

1. The U.S. Department of State (“State Department”), through its Global Engagement Center (“GEC”), is actively intervening in the news-media market to render disfavored press outlets unprofitable by funding the infrastructure, development, and marketing and promotion of censorship technology and private censorship enterprises to covertly suppress speech of a segment of the American press.
2. Defendants have been granted no statutory authority to fund or promote censorship technology or censorship enterprises that target the American press, tarring disfavored domestic news organizations as purveyors of “disinformation.” There is no enumerated general power to censor speech or the press found in the United States Constitution, and the First Amendment expressly forbids it, providing: “Congress shall make no law … abridging the freedom of speech or of the press.” U.S. CONST. amend. I.
3. The full breadth of Defendant GEC’s censorship scheme is currently unknown. At a minimum, Defendant GEC has funded, promoted, and/or marketed two American censorship enterprises: the Disinformation Index Inc., operating under the name Global Disinformation Index (“GDI”), and NewsGuard Technologies, Inc. (“NewsGuard”). These entities generate blacklists of ostensibly risky or unreliable American news outlets for the purpose of discrediting and demonetizing the disfavored press and redirecting money and audiences to news organizations that publish favored viewpoints.

4. Media Plaintiffs are branded “unreliable” or “risky” by the government-funded and government-promoted censorship enterprises of GDI and NewsGuard, injuring Media Plaintiffs by starving them of advertising revenue and reducing the circulation of their reporting and speech—all as a direct result of Defendants’ unlawful censorship scheme.
5. Defendant State Department’s censorship funding and promotion also undermines Texas law, which requires social media companies with market power to act as common carriers. Thus, it interferes with the State of Texas’s sovereign interest in creating and enforcing a legal code.
6. This lawsuit seeks injunctive relief to halt the unconstitutional and ultra vires actions of the State Department and put an end to one of the most audacious, manipulative, secretive, and gravest abuses of power and infringements of First Amendment rights by the federal government in American history.

JURISDICTION AND VENUE

7. This Court has subject-matter jurisdiction pursuant to 28 U.S.C. § 1331 because the federal claims arise under the Constitution and laws of the United States and pursuant to 28 U.S.C. § 1402 because the United States is a defendant in this action.
8. Plaintiffs seek declaratory and injunctive relief under 28 U.S.C. §§ 2201-2202.
9. Venue is proper in this District under 28 U.S.C. § 1391(b)(2) because Plaintiff the State of Texas is located in this District, and a substantial part of the events or omissions giving rise to its claims occurred here.
10. This Court is authorized to award the requested declaratory relief and grant permanent injunctive relief under 5 U.S.C. §§ 702 and 706, 28 U.S.C. §§ 1361 and 2201-2202, and its inherent equitable powers.

PARTIES

11. Plaintiff The Daily Wire, LLC is a Texas limited liability company with its principal place of business in Nashville, Tennessee.
12. Plaintiff FDRLST Media, LLC is a Delaware limited liability company with its principal place of business in Washington, D.C.
13. Plaintiff State of Texas (hereinafter “Texas”) is a sovereign state of the United States of America entitled to the protections of the United States Constitution.
14. Plaintiff Texas, through its Attorney General Ken Paxton, brings this lawsuit to protect its sovereign interest in creating and enforcing its legal code that regulates social media companies with market power as common carriers. Paxton is authorized by Texas law to sue on the State’s behalf. His offices can be reached at P.O. Box 12548 (MC 009), Austin, Texas 78711-2548.
15. Defendant U.S. Department of State is a cabinet-level executive agency of the United States of America.
16. Defendant Antony Blinken is the Secretary of State of the United States. He is sued in his official capacity.
17. Defendant Global Engagement Center (“GEC”) is an interagency center housed in, and funded by, the State Department.
18. Defendant Leah Bray is sued in her official capacity as Deputy Coordinator of the State Department’s GEC.

19. Defendant James P. Rubin is sued in his official capacity as the Coordinator of the State Department’s GEC.

20. Defendant Daniel Kimmage is sued in his official capacity as the Principal Deputy Coordinator for the State Department’s GEC.

21. Defendant Alexis Frisbie is sued in her official capacity as Senior Technical Advisor for the Technology Engagement Team at the State Department’s GEC.
22. Defendant Patricia Watts is sued in her official capacity as the Director of the Technology Engagement Team at the State Department’s GEC.

23. Hereinafter, the State Department, GEC, Antony Blinken, Leah Bray, James P. Rubin,

Daniel Kimmage, Alexis Frisbie, and Patricia Watts will be referred to jointly as the “State Department Defendants.”

GENERAL ALLEGATIONS

24. Since the Founding, Americans have relied on a free and open press to provide a check on government abuses. The independence of the press from government licensing or control was so central to this nation’s founding that many of the former colonies incorporated declarations into their state constitutions.
25. In the mid-20th century, the American press was dominated by only a few networks and wire services. For instance, in 1960, the United States’ market was limited to three TV networks, ABC, CBS, and NBC,^[1] and the majority of the national print news came from one wire service— the Associated Press.^[2]
26. In the late 20th century, the press was largely dominated by national corporate interests, and, in the 1990s, increasingly absorbed by global mergers.³ 

27. With the 21st century came a rise in the digital era which led to “a proliferation of news providers and platforms,” with approximately 6,000 jobs created in digital-only newsrooms between 2008 and 2019—a 79% increase over the period.^[3]
28. Americans, in turn, increasingly rely on this new digital media for their source of news: As of 2023, “a large majority of U.S. adults (86%) say they often or sometimes get news from a smartphone, computer or tablet, including 56% who say they do so often.” This compares to only 37% of U.S. adults who often or sometimes get news from print publications.^[4]
29. Upon information and belief, Facebook has over 180 million users throughout the United States, with a Pew Research study noting 66% of adults report using Facebook, and 31% of U.S. adults say they regularly obtain information about current events from the site.^[5]
30. Upon information and belief, X, previously known as Twitter, has approximately 70 million users in the United States,^[6] with 27% of U.S. adults saying they use X, and 12% of U.S. adults saying they regularly get news on X.^[7]
31. Forty percent of U.S. adults say they use Instagram,^[8] and 16% of U.S. adults say that they regularly get news from the site.^[9]

3 Jonathan Hardy, Journalism in the 21st Century, The Psychology of Journalism (July 22, 2021), available at https://doi.org/10.1093/oso/9780190935856.003.0002 (last visited on November 21, 2023).

32. TikTok has over 150 million users in the United States, with 21% of U.S. adults saying they use TikTok^[10] and 14% of U.S. adults saying they regularly get news from the site.¹²
33. Eighty-two percent of U.S. adults say that they use YouTube, and 26% of U.S. adults say that they regularly get news on YouTube.^[11]
34. Of those who indicated they get their news digitally, 67% said they often or sometimes use news websites or apps as a news source, 50% said they often or sometimes use social media as a news sources, and 71% responded that they use Google or other search engines to get the news.^[12] Google and other search engines use algorithms to rank search results, and those algorithms can be customized to down-rank disfavored digital press outlets.^[13]
35. As the new media gained strength, the federal government, upon information and belief, conspired with the legacy media, technology giants, social media companies, and software and technology developers to censor the press that do not adhere to the preferred views of federal officials.
36. Social media and other digital platforms are widely considered the modern public square.

However, over the last year, between the release of the internal communications at Twitter (commonly referred to as the “Twitter Files”), the preliminary discovery in Missouri v. Biden, the House of Representatives’ release of the “Facebook Files,” and ongoing responses to FOIA requests, Americans have learned the federal government has coerced social media platforms to censor disfavored press and viewpoints.^[14]

38. This lawsuit focuses on a different wing of the government’s Censorship-Industrial Complex: the State Department Defendants’ funding and promotion of censorship technologies and private censorship enterprises that blacklist Media Plaintiffs, negatively impacting Media Plaintiffs’ ability to circulate and distribute their publications to both current and potential audiences, and intentionally destroying Media Plaintiffs’ ability to obtain advertisers.

Media Plaintiffs: The Daily Wire and The Federalist

39. Plaintiff The Daily Wire’s news and media business was founded in 2015 and operates a website and platform distributing written news, commentary, podcasts, and premium subscription video-on-demand.
40. Plaintiff The Daily Wire embraces high standards of journalism^[15] but “does not claim to be without bias.” Rather, it is a “right-of-center media” organization that prides itself on being “opinionated,” “noisy,” and “having a good time.”

41. Founded in 2013, Plaintiff FDRLST Media, LLC is a digital-only media outlet operating as The Federalist and covering such things as politics, policy, culture, and religion.
42. Plaintiff The Federalist also adopts high standards of journalism while embracing its rightof-center perspective.
43. The First Amendment guarantees Media Plaintiffs’ Freedom of Speech and Freedom of the Press, without regard to their political leanings.
44. Media Plaintiffs rely heavily on social media outlets, web browsers, internet search tools, and other computer technology to distribute their content.

Federal Government Conspires with Big Tech & Social Media Outlets to Silence New Media

45. The federal government’s efforts to silence the new media have been detailed in the Missouri v. Biden lawsuit, with preliminary evidence showing a vast and unprecedented government-censorship complex unparalleled in American history.^[16]
46. The preliminary evidence, including numerous emails, reports, and evidence of regular meetings, phone calls, and information exchanges between government officials and social media platforms, produced in Missouri v. Biden, shows that myriad federal government agencies and officials have engaged in a coordinated effort to suppress speech on social media that runs counter to the federal government’s preferred narrative. Indeed, having threatened and cajoled social media platforms for years to censor disfavored viewpoints and speakers, government officials across numerous federal agencies have moved into a phase of open collusion with the social media companies to suppress speakers, viewpoints, and content that question the government’s positions or policies under the guise of preventing the spread of so-called disinformation, misinformation, and mal-information.^[17]
47. The evidence reveals that federal officials have likewise teamed up with private research institutions, backed by substantial resources and federal funding, to establish a mass-surveillance and mass-censorship enterprise that utilizes sophisticated techniques to review hundreds of millions of American citizens’ electronic communications in real time, working closely with tech platforms to covertly censor millions of individuals.^[18]

State Department’s GEC Leads One Arm of the Government’s Censorship Complex, Targeting Speech by Americans, to Americans, in America.

48. In addition to its role in pushing social media companies to censor speech, Defendant GEC has taken the lead in coordinating the government’s efforts to silence speech.^[19]
49. Defendant GEC, a multi-agency center housed within Defendant State Department, originated in 2011 as the Center for Strategic Counterterrorism Communications (CSCC), following the Obama administration’s issuance of an executive order that created the center to support federal agency communications in targeting “violent extremism and terrorist organizations.”^[20]  

50. In 2016, the Obama administration issued a second executive order morphing the CSCC into GEC but leaving its counterterrorism mission intact.²³
51. When Congress created GEC through its passage of the National Defense Authorization Act (“NDAA”) for fiscal year 2017, the Center’s purpose was expanded beyond its original mandate of countering the influence of international terrorists, such as the Islamic State, al-Qaeda, and other foreign extremists. Specifically, the 2017 NDAA directed GEC to “coordinate efforts of the Federal Government” to counter foreign state and nonstate “propaganda and disinformation efforts aimed at undermining United States national security interests.”^[21]
52. In 2019, the NDAA further expanded GEC’s mission, authorizing it to counter foreign “propaganda and disinformation” that undermines not only the United States’ national security interests, but also the “policies, security, or stability” of the U.S. and our allies.^[22] 

53. While Congress dramatically expanded the breadth of GEC’s mission, its purpose remained limited to combatting “foreign” disinformation. Congress explicitly included a limitation in the spending bills that provided: “None of the funds authorized to be appropriated or otherwise made available to carry out this section shall be used for purposes other than countering foreign propaganda and misinformation that threatens United States national security.”^[23] (emphasis added).

GEC Violates Its Congressional Mandate by Targeting Americans’ Speech

54. While Congress forbade GEC from using funds appropriated or otherwise made available to it to counter Americans’ speech, as detailed throughout this complaint, many of GEC’s activities and initiatives targeted speech spoken in America among Americans, including Media Plaintiffs’ speech and press rights.

Disinfo Cloud: State Department’s Alter Ego

55. Many of GEC’s activities and initiatives were performed by Defendant State Department’s alter ego: the private, for-profit, and now-shuttered entity Park Capital Investment Group, LLC, also known as Park Advisors or Disinfo Cloud, which the State Department funded with a $3,000,000 contract.^[24]
56. Among other things, GEC used Park Advisors to funnel money to, and serve as a sales representative for, censorship technologies and private censorship enterprises.²⁸

57. GEC also used Park Advisors to develop and manage multiple initiatives of GEC under the moniker “Disinfo Cloud,” also known as Disinformation Cloud.^[25]
58. According to the Office of the Inspector General of the State Department, GEC’s

Technology Engagement Team (“TET”) “funded and supported the Disinformation Cloud website, an open-source platform that GEC’s grantee partner maintained.”^[26]

59. Disinfo Cloud represented the brand under which the for-profit business, Park Advisors, funneled money from the State Department to various entities, such as the $100,000 awarded to

GDI in connection with its 2021 “U.S.-Paris Tech Challenge,” GEC’s invitation-only annual event^[27] to “counter propaganda and disinformation use” in Europe.^[28] That 2021 event was sponsored by GEC, in collaboration with U.S. Embassy Paris, the Atlantic Council’s Digital Forensic Research Lab (DFR Lab), the Cybersecurity and Infrastructure Security Agency (CISA), the North Atlantic Treaty Organization (NATO), the U.K. Department for Digital, Culture, Media and Sport, the Office of the Tech Ambassador of Denmark, and the Digital Communication Network, as well as Park Advisors and Disinfo Cloud.^[29]

60. Christina Nemr, a former State Department employee who had been a founding member of the State Department’s Countering Violent Extremism (CVE) program, served as the director of Park Advisors and as the administrator of Disinfo Cloud.^[30]
61. Although the State Department has confirmed that it paid Park Advisors to manage Disinfo

Cloud, a search of the government’s official webpage for grants, contracts, or awards, USASpending.gov, reveals no grants or contracts awarded to Disinfo Cloud, Park Advisors, or

Park Capital Investment Group. Rather, the only documented payment to any of those entities is a COVID-era loan of nearly $40,000 to Park Capital Investment Group in 2020.^[31]

62. An audit of GEC by the State Department’s Inspector General revealed Park Capital Investment Group received a $2,997,345 award for the performance period from September 25, 2018, through September 18, 2020.^[32]
63. The Office of Inspector General’s report on GEC found GEC lacked oversight of contractors and had insufficient internal controls “to ensure contractors did not perform inherently governmental functions”—which, upon information and belief, the State Department deemed to include funding the development of censorship technology and the widespread marketing efforts to silence disfavored speakers and media outlets.³⁷

Disinfo Cloud Served as a De Facto Arm of GEC’s TET

64. Disinfo Cloud operated as a de facto government entity, launching, managing, and/or marketing several initiatives of TET, illustrated below.^[33]

65. Disinfo Cloud’s management of the “Disinfo Cloud” platform—one of TET’s six historical initiatives—consisted of creating and launching the Disinfo Cloud webpage, which, among other things, acted “as a repository to catalog an ever-growing list of CPD tools and technologies.” (“CPD” stands for “Countering Propaganda and Disinformation.”)³⁹

66. The State Department website describes Disinfo Cloud as “an unclassified platform used by the U.S. government, foreign partners, and technology providers to identify and learn about technologies to counter adversarial propaganda and disinformation.”^[34]
67. The State Department claimed that Disinfo Cloud users included “Congress and over a dozen federal agencies, including the Departments of Defense, Energy, Treasury, and the FBI,” as well as “foreign partners, such as the Australian Government, Estonian Government, European Union, and the United Kingdom Government,” and, significant to this complaint, “Providers,” “including Academia, Private Sector, and Tech Vendors.”^[35]

68. Upon information and belief, the Disinfo Cloud repository of CPD tools and technologies included many that targeted American speech, including Media Plaintiffs.
69. The CPD tools included supposed fact-checking technologies, media literacy tools, media intelligence platforms, social network mapping, and machine learning/artificial intelligence technology.^[36]
70. Disinfo Cloud assessed the various CPD tools and technologies, first by completing opensource research to learn about the tool, its manufacturer, and the technology involved. The team would then summarize the research in a one-to-three-page summary.^[37]
71. Disinfo Cloud would subsequently conduct more probing research of these censorship tools and technologies, contacting the tools’ creators, requesting a remote demonstration, and obtaining more intricate technical details. Disinfo Cloud would then compile a ten to twelve-page report on the technology.^[38]

72. Disinfo Cloud “identified and assessed over 365 tools and technologies.”^[39]
73. The Disinfo Cloud webpage was originally available only to “.mil and .gov” users, but access was later opened to the private sector, “including private industry, social media companies, academic, and civil society, with more than 2,000 users provided access to Disinfo Cloud.”^[40]
74. Park Advisors’ Director Christina Nemr, who served as the Administrator of Disinfo Cloud, stated the Disinfo Cloud platform was originally “meant to be just .mil and .gov but then we realized that was a bit limiting. We want these tools to be tools that anyone working in the counter-disinformation space is aware of . . . .”⁴⁷

GEC Takes Its Censorship Team on the Road

75. In 2019, GEC established a satellite office in Silicon Valley as part of its “Silicon Valley Engagement” initiative.

76. Through its Silicon Valley Engagement initiative, GEC marketed censorship technology to American companies, including the major social media companies, such as Twitter (now X), Meta, LinkedIn, and others. Those American companies were then encouraged to join Disinfo

Cloud to identify “a technological solution” suited to the specific tech company’s needs to “counter propaganda and disinformation.”^[41]

[1] Katie McLaughlin, 5 Things That 1960s TV Changed, CNN, available at https://www.cnn.com/2014/05/29/showbiz/tv/sixties–five–things–television/index.html (last visited on November 21, 2023).

[2] Associated Press, Our Story, available at https://www.ap.org/about/our–story/ (last visited on November 21, 2023).

[3] Id.

[4] Jacob Liedke & Luxuan Wang, News Platform Fact Sheets, Pew Res. Ctr. (Nov. 15, 2023), available at https://www.pewresearch.org/journalism/fact–sheet/news–platform–fact–sheet/.

[5] See Mason Walker & Katerina Eva Matsa, News Consumption Across Social Media in 2021, Pew Res. Ctr. (Sept. 20, 2021), available at https://www.pewresearch.org/journalism/2021/09/20/news–consumption–across–socialmedia–in–2021/.

[6] Shradha Dinesh & Meltem Odabas, 8 Facts about Americans and Twitter as it Rebrands to X, Pew Res. Ctr. (July 26, 2023), available at https://www.pewresearch.org/short–reads/2023/07/26/8–facts–about–americans–and–twitter–asit–rebrands–to–x/.

[7] Jacob Liedke & Luxuan Wang, Social Media and News Fact Sheet, Pew Res. Ctr. (Nov. 15, 2023), available at https://www.pewresearch.org/journalism/fact–sheet/social–media–and–news–fact–sheet/.

[8] Shradha Dinesh & Meltem Odabas, supra note 7.

[9] Liedke & Wang, supra note 8.

[10] Brooke Auxier & Monica Anderson, Social Media Use in 2021, Pew Res. Ctr. (Apr. 7, 2021), available at https://www.pewresearch.org/internet/2021/04/07/social–media–use–in–2021/. ¹² Liedke & Wang, supra note 8.

[11] Id.

[12] Liedke & Wang, supra note 5.

[13] Jonathan Hardy, Journalism in the 21st Century, The Psychology of Journalism (July 22, 2021), available at https://doi.org/10.1093/oso/9780190935856.003.0002 (last visited on November 21, 2023).

[14] Missouri v. Biden, 22-cv-01213, Plaintiffs’ Reply Memorandum in Support of Preliminary Injunction, available at https://storage.courtlistener.com/recap/gov.uscourts.lawd.189520/gov.uscourts.lawd.189520.276.0.pdf

[15] https://www.dailywire.com/standards–policies (last visited November 21, 2023).

[16] See Missouri v. Biden, —-F.Supp.3d—-, 2023 WL 4335270 (W.D. LA July 4, 2023), rev’d in part, No. 23-30445, — F.4th –, 2023 WL 5821788 (5th Cir. Sept. 8, 2023), cert. granted in Murthy v. Missouri, 601 U.S. —-, — S.Ct. —, 2023 WL 6935337 (Mem).

[17] Id.

[18] Id.

[19] About Us—Global Engagement Center, available at https://www.state.gov/about–us–global–engagement–center–2/ (last visited June 17, 2023).

[20] Id. ²³ Id.

[21] Id.; National Defense Authorization Act for Fiscal Year 2017, Pub. L. No. 114-328, § 1287, 130 Stat. 2000, 254648 (2016).

[22] John S. McCain National Defense Authorization Act for Fiscal Year 2019, Pub. L. No. 115-232, § 1284, 132 Stat. 1636, 2076 (2018).

[23] National Defense Authorization Act for Fiscal Year 2017, Pub. L. No. 114-328, § 1287, 130 Stat. at 2548, (2016).

[24] Margot Cleveland, Meet the Shadowy Group That Ran the Federal Government’s Censorship Scheme, The Federalist (April 19, 2023), available at https://thefederalist.com/2023/04/19/meet–the–shadowy–group–that–ran–thefederal–governments–censorship–scheme/; Defeat Disinfo, available at https://www.state.gov/defeat–disinfo/ (last visited November 21, 2023); Office of Inspector General, United States Department of State, Audit of Global Engagement Center Federal Assistance Award Management and Monitoring, April 2020, available at https://www.stateoig.gov/uploads/report/report_pdf_file/aud–mero–20–26_7.pdf (last visited November 21, 2023). ²⁸ Margot Cleveland, Government is Marketing Censorship Tools to Big Tech to Gag Conservatives, The Federalist (April 11, 2023), available at https://thefederalist.com/2023/04/11/government–is–marketing–censorship–tools–tobig–tech–to–gag–conservatives/ (last visited November 21, 2023).

[25] Margot Cleveland, Meet the Shadowy Group That Ran the Federal Government’s Censorship Scheme, The Federalist (April 19, 2023), available at https://thefederalist.com/2023/04/19/meet–the–shadowy–group–that–ran–thefederal–governments–censorship–scheme/ (last visited November 21, 2023).

[26] Office of Inspector General, United States Department of State, Inspection of the Global Engagement Center, September 2022, at 21, available at https://www.stateoig.gov/uploads/report/report_pdf_file/isp–i–22–15.pdf (last visited November 21, 2023).

[27] Gabe Kaminsky, Disinformation Inc.: State Department Bankrolls Group Secretly Blacklisting Conservative Media, Washington Examiner (Feb. 9, 2023), available at https://www.washingtonexaminer.com/restoringamerica/equality–not–elitism/disinformation–group–secretly–blacklisting–right–wing–outlets–bankrolled–statedepartment.

[28] U.S. Department of State website- U.S. Paris Tech Challenge, available at https://www.state.gov/upcomingevents–technology–engagement–division/.

[29] Id.

[30] Margot Cleveland, Meet the Shadowy Group That Ran the Federal Government’s Censorship Scheme, The Federalist (April 19, 2023), available at https://thefederalist.com/2023/04/19/meet–the–shadowy–group–that–ran–thefederal–governments–censorship–scheme/ (last visited November 21, 2023).

[31] Id.

[32] Office of Inspector General, United States Department of State, Audit of Global Engagement Center Federal

Assistance Award Management and Monitoring at 32, April 2020, available at https://www.stateoig.gov/uploads/report/report_pdf_file/aud–mero–20–26_7.pdf (last visited November 21, 2023). ³⁷ Office of Inspector General, United States Department of State, Inspection of the Global Engagement Center, at 8, September 2022, available at https://www.stateoig.gov/uploads/report/report_pdf_file/isp–i–22–15.pdf (last visited November 21, 2023).

[33] Mad Scientist: Weaponized Information Virtual Conference, July 21, 2020, at 15:45, available at 2.09 MadSci Weaponized Information: Technology Engagement Team & Disinfo Cloud – Ms. Frisbie & Nemr – YouTube. ³⁹ Technology Engagement Team, available at https://2017–2021.state.gov/bureaus–offices/under–secretary–forpublic–diplomacy–and–public–affairs/global–engagement–center/technology–engagement–team/index.html (last visited November 21, 2023).

[34] Disinfo Cloud, available at https://2017–2021.state.gov/disinfo–cloud–launch/index.html (last visited November 21, 2023).

[35] Id.

[36] Defeat Disinfo, available at https://www.state.gov/defeat–disinfo/ (last visited November 21, 2023).

[37] Mad Scientist: Weaponized Information Virtual Conference, July 21, 2020, at 19:35, available at 2.09 MadSci Weaponized Information: Technology Engagement Team & Disinfo Cloud – Ms. Frisbie & Nemr – YouTube.

[38] Id. at 20:40.

[39] The Disinfo Cloud Digest, Dec. 21, 2021, available at https://myemail.constantcontact.com/Thank–you–andfarewell—for–now–.html?soid=1134000290001&aid=ixx_30MZGGU (last visited at November 21, 2023).

[40] Id.; Mad Scientist: Weaponized Information Virtual Conference, July 21, 2020, at 30:15, available at 2.09 MadSci Weaponized Information: Technology Engagement Team & Disinfo Cloud – Ms. Frisbie & Nemr – YouTube. ⁴⁷Id.; Mad Scientist: Weaponized Information Virtual Conference, July 21, 2020, at 30:15, available at 2.09 MadSci Weaponized Information: Technology Engagement Team & Disinfo Cloud – Ms. Frisbie & Nemr – YouTube.

[41] Margot Cleveland, Government Is Marketing Censorship Tools to Big Tech To Gag Conservatives, April 11, 2023, available at https://thefederalist.com/2023/04/11/government–is–marketing–censorship–tools–to–big–tech–togag–conservatives/ (last visited November 21, 2023).

…

The balance of the information in the complaint pleadings, which includes some illustrations, are found at this link here.