Center for Accountability in Science (CAS)
Background
The Center for Accountability in Science (CAS), “a non-profit organization dedicated to providing balance to alarmist media stories and NGO campaigns regarding the risks posed by modern technology, medicines, and products,” is a project of the nonprofit Center for Organizational Research and Education (CORE). It has been described as an astroturf group set up by the corporate lobbyst and PR marketer Richard Berman, and is one of several organizations maintained under the CORE umbrella.1“Joseph Perrone,” Science 2.0.com. Archived May 11, 2016. Archive URL: https://archive.ph/iajdc 2“About Us,” Center for Accountability in Science. Archived May 10, 2016. Archive URL: https://archive.ph/O6gHp 3“Web of Lies: Berman’s Astroturf Empire,” Stop HumaneWatch. Archived May 10, 2016. Archive URL: https://archive.ph/0zxO2
According to its website, “The Center for Accountability in Science provides a balanced look at the science behind these news stories and examines the organizations behind the effort to scare consumers.”4“About Us,” Center for Accountability in Science. Archived May 10, 2016. Archive URL: https://archive.ph/O6gHp
Citizens for Responsibility and Ethics in Washington (CREW), which publishes BermanExposed.org, describes the Center for Accountability in Science as “the latest project hatched by corporate PR man Richard Berman, who over the years has used a series of shadowy nonprofits to defend the interests of restaurants, food and booze companies, and the tobacco industry. […] CAS’s targets include the Robert Wood Johnson Foundation, the Natural Resources Defense Council, and the Centers for Disease Control and Prevention – all previous Berman targets.”5“Berman Enlists Industry Scientist for Latest Project, Flip-Flops On Cancer Risk of Tanning,” Citizens for Responsibility and Ethics in Washington (CREW), August 22, 2014. Archived May 10, 2016. Archive URL: https://archive.ph/Z6ztX
According to CREW, CAS is housed inside Berman’s Center for Organizational Research and Education, the successor nonprofit to Berman’s Center for Consumer Freedom (CCF). Sourcewatch lists the Center for Accountability in Science as a campaign of the Center for Consumer Freedom.6“Berman Enlists Industry Scientist for Latest Project, Flip-Flops On Cancer Risk of Tanning,” Citizens for Responsibility and Ethics in Washington (CREW), August 22, 2014. Archived May 10, 2016. Archive URL: https://archive.ph/Z6ztX 7“CCF selected campaigns,” Sourcewatch. Accessed May 10, 2016.
Who is Richard Berman?
Mother Jones describes Richard Berman, who has earned the nickname “Dr. Evil,” as “well known in political circles for funnelling anonymous corporate money into vicious ad campaigns attacking various advocacy groups, such as Mothers Against Drunk Driving and the Humane Society of the United States, which he has accused of spending a minuscule amount of their donations on their stated missions. Berman, who heads the DC-based communications firm Berman and Company, typically launches his offensives through a network of front groups. He has used these organizations to fight regulations governing food safety, animal cruelty, workplace safety, secondhand smoke, and even tanning beds, and in the process keeps his corporate funders anonymous.” In a secretly-taped speech shared with the New York Times, Berman bragged that “We run all of this stuff through nonprofit organizations that are insulated from having to disclose donors. There is total anonymity.”8Molly Redden. “Notorious Astroturf Pioneer Rick Berman Is Behind Business Group’s Anti-Labor-Board Campaign,” Mother Jones, March 25, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/brmNX 9Eric Lipton. “Hard-Nosed Advice From Veteran Lobbyist: ‘Win Ugly or Lose Pretty’,” The New York Times, October 30, 2014. Archive URL: https://archive.ph/qG6FN
Stance on Climate Change
While the Center for Accountability in Science does not appear to have released an official position statement on climate change, they have said “There are many reasons to worry about climate change,” linking to current NASA research on the consequences of climate change.10“No, Climate Change Probably Isn’t Killing Your Sex Life,” Center for Accountability in Science, November 10, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/yESEt
Chemicals
Glyphosate/Roundup
“Is it dangerous? The trick is that the question assumes an absolute yes or no answer—the truth is that dosage is key. For example, is water dangerous? Technically, yes, but only if you drink too much of it. Glyphosate is of low toxicity—somewhere between baking soda and alcohol, based on data developed by the EPA. That makes glyphosate significantly less toxic than chemicals like theobromine (in chocolate) and rotenone (a pesticide used in organic agriculture). The truth is the dose makes the poison, and when it comes to glyphosate the dose is extremely small.”11“EPA (sort of) Admits: Glyphosate Not Likely Carcinogen,” Center for Accountability in Science, May 9, 2016. Archived May 11, 2016. Archive URL: https://archive.ph/Y180a
Plastic & BPA
[I]n short, ‘BPA poses no health risk to consumers because current exposure to the chemical is too low to cause harm.’ […] The hypothesis that low-dose exposure to everyday chemicals poses human health risks still lacks evidence. Until and unless evidence emerges, we should put stories like these in the garbage.”12“Calling TIME Out on Plastic Alarmism,” Center for Accountability in Science, May 5, 2016. Archived May 11, 2016. Archive URL: https://archive.ph/JPqHK
“Bisphenol-A (BPA) is one of the most studied chemicals on the planet. The U.S. Food and Drug Administration, European Food Safety Authority, and other global health and regulatory bodies have reviewed hundreds of BPA studies and conclude the chemical poses no risk to human health.“13“How Much BPA is Safe?” Center for Accountability in Science, May 18, 2016. Archived May 11, 2016. Archive URL: https://archive.ph/fIJbg
“There is also a small group of researchers that have staked their careers on the conclusion that BPA is harmful and continue to criticize large studies that show the opposite. These researchers have received millions of dollars in grant money (often from governments) to study BPA and are personally invested in getting BPA banned.”14“Bisphenol-A (BPA): Does the science support a BPA ban?” Center for Accountability in Science, August, 2014. Archived May 11, 2016. Archive URL: https://archive.ph/KzmD5
Genetically Modified Organisms (GMOs)
“There are hundreds of published studies showing the safety of genetically modified organisms. Major health and regulatory agencies around the globe (including the World Health Organization, European Food Safety Authority, U.S. Food and Drug Administration, etc.) confirm there is no risk to human health from GMOS. Yet, anti-GMO activists continue to point to a handful of studies suggesting health problems from GMOs. Unfortunately for these activists, many of these studies have been widely criticized or retracted due to allegations of data manipulation or other procedural errors.”15“Journal Retracts Study Claiming GMO Dangers Amid Allegations of Manipulated Data,” Center for Accountability in Science, January 18, 2016. Archived May 11, 2016. Archive URL: https://archive.ph/6LYW0
“Genetically Modified Organisms (GMOs) are constantly demonized by environmental activist groups as dangerous for public health or the environment. But the extensive scientific literature on GMOs simply doesn’t support these claims.”16“5 Things to Know about GMOs,” Center for Accountability in Science. Archived May 11, 2016. Archive URL: https://archive.ph/RzgEA
Funding
CORE Funding
The Center for Organizational Research and Education (CORE) is the parent organization of the Center for Accountability in Science. The Conservative Transparency reports funidng for CORE/the Center for Consumer Freedom as follows. Note that not all individual funding values have been confirmed by DeSmog.17“Center for Organizational Research and Education (formerly Center for Consumer Freedom),” Conservative Transparency. Data retrieved May 13, 2016.
For additional information, view the attached spreadsheet for CORE funding by year (.xlsx).18“Center for Organizational Research and Education (formerly Center for Consumer Freedom),” Conservative Transparency. Data retrieved May 13, 2016.
CORE as Recipient
Donor | Total |
The Lynde and Harry Bradley Foundation | $375,000 |
DonorsTrust | $89,112 |
Donors Capital Fund | $30,000 |
Grand Total | $494,112 |
CORE as Donor
Recipient | Total |
Berman and Company | $13,150,059 |
Employment Policies Institute Foundation | $6,914,000 |
Grand Total | $20,064,059 |
CAS Views on Funding
While the Center for Accountability in Science does not list its own funding sources, it does present its views on Industry-Funded research, as well as research funded by foundations and activist groups, and government-funded science.
While the CAS does cite some examples of the “Criticism of Industry Research,” it quickly defends two of the examples provided. Conversely, CAS offers an overall negative view of research funded by government and foundations:
“Foundation and Activist Group-Funded Research”
“Private foundations and special interest groups are important sources of funding for some of the most ground-breaking research being conducted in the United States. However, these organizations often already have a stance on a particular issue and are interested in funding research that further their organizations’ goals.
Activist groups also have a key interest in funding research that sounds a public safety alarm. The more concerned potential donors are about public health, the more likely they are to give additional funding to keep the group going. Researchers funded by foundations and activist groups are subject to the same pressure for positive results that recipients of government grants and industry funding are under.”19“Foundation and Activist Group-Funded Research,” Center for Accountability in Science. Archived May 11, 2016. Archive URL: https://archive.ph/sFSbz
“Government-Funded Science”
“Many Americans assume that research funded by the federal government is the most trustworthy form of research. However, nearly every aspect of the federal grant making process is full of political maneuvering and potential bias.”
”[…] Peer review has also been cited as a problem in government regulatory agencies. The Environmental Protection Agency, for instance, has been frequently criticized for its process of selecting experts to serve on the agency’s Science Advisory Board, which reviews the science used as justification for EPA’s regulatory decisions.”20“Government-Funded Science,” Center for Accountability in Science. Archived May 11, 2016. Archive URL: https://archive.ph/fytUx
“Industry-Funded Research”
“Much of the research conducted into chemicals is performed by industry. Businesses have an interest in showing that their products are safe and employ more scientists than the government, non-profits, and universities combined. Industry also often collaborates with universities to conduct joint research or fund university-run research. And as with government, university, or non-profit-funded studies, industry-funded studies are often peer-reviewed and published in prestigious journals.
” […] Most researchers acknowledge that doing away with industry funding of research is not the answer to criticism about funding bias. Instead, researchers and members of industry are promoting greater transparency and access to information about products.”21“Industry-Funded Research,” Center for Accountability in Science. Archived May 11, 2016. Archive URL: https://archive.ph/IjNlY
CORE 990 Forms
Key People
Chief Science Officer
The Center for Accountability in Science offers the following notes about their Chief Science Officer (and only listed staff member), Dr. Joe Perrone:22“About Us,” Center for Accountability in Science. Archived May 10, 2016. Archive URL: https://archive.ph/O6gHp
- “Doctorate of Science from The Johns Hopkins University, Post-Doctoral fellowship at Harvard University and his B.S. in Biology from the University of Delaware.
- Worked closely with many funding agencies and Ministries of Health to develop strategies for the use of diagnostics in public health programs.
- Served as the Vice President for Business Development and Technology Transfer for the University of Maryland Biotechnology Institute.
- Served as an advisor to the World Health Organization and served on the WHO Diagnostic Steering Committee.”
Citizens for Responsibility and Ethics in Washington (CREW) notes that CAS does not Perrone’s history of industry work.23“Berman Enlists Industry Scientist for Latest Project, Flip-Flops On Cancer Risk of Tanning,” Citizens for Responsibility and Ethics in Washington (CREW), August 22, 2014. Archived May 10, 2016. Archive URL: https://archive.ph/Z6ztX Perrone used to be the president of JBP Consulting and previously worked at Becton, Dickinson, and Company, a medical technology company. He has also been an advisor to several other companies including Biomedical Enterprises and FASgen.24(Press Release). “Joseph Perrone Joins SRI International to Direct Molecular Diagnostics and Rare and Neglected Diseases Group,” SRI International. Archived May 11, 2016. Archive URL: https://archive.ph/PjHmt 25“Joseph Perrone, Sc.D.” LinkedIn. Accessed May 10, 2016. Archived .pdf on file at DeSmog.
Actions
July 2015
Joseph Perrone, Chief Scientific Officer for the Center for Accountability in Science, argues that di-isononyl phthalate (DINP) and di-isodecyl phthalate (DIDP), two chemicals linked to high blood pressure and diabetes in children, may not be at fault, CBS News reports.26“‘Safer’ chemicals in plastics may be hazardous to kids,” CBS News, July 9, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/lcZPZ
Perrone summarized his view as follows:
“Before companies can use any chemicals that may come into contact with food, the U.S. Food and Drug Administration reviews them for safety. Just last year, the European Commission, which sets strict standards for chemical safety, re-evaluated the phthalates DINP and DIDP and concluded that they are safe in ‘all current consumer applications.’
The two new studies cited by CBS News that explore the link between phthalates and increased blood pressure and insulin-resistance have significant limitations. The authors admit that their finding that children with higher levels of phthalates in their urine is associated with a higher blood pressure and insulin resistance could be explained by other factors – notably that children who eat more processed packaged food (and thus are exposed to higher levels of phthalates) could have higher blood pressure and insulin resistance because of poorer diet, not because of phthalates. The studies neither explore how these children were exposed to phthalates nor show that phthalates actually cause health problems.
Additionally, the phthalates explored by these studies, DINP and DIDP, are also not typically used in microwavable plastic, though viewers were advised to avoid microwaving plastic. Even the most health-conscious viewer should fear neither increased exposure to these phthalates simply by microwaving their food in microwave-safe plastic containers nor exposure to these phthalates from other sources.”27“‘Safer’ chemicals in plastics may be hazardous to kids,” CBS News, July 9, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/lcZPZ
Earlier in 2015, Perrone also criticized the American Heart Association’s findings that Bisphenol A or BPA could raise blood pressure and increase your risk for heart disease. ”[T]he actual data doesn’t support the authors’ sweeping conclusions” Perrone writes in The Baltimore Sun.28Joseph Perrone. “All science is not equal,” The Baltimore Sun, January 4, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/GmW8d
April/May 2015
The Center for Accountability in Science released a primer titled “5 Things to Know about GMOs” (PDF) summarized as follows:29“5 Things to Know about GMOs,” Center for Accountability in Science. Archived May 11, 2016. Archive URL: https://archive.ph/RzgEA 30“5 Thinks You Should Know About… GMOs” (PDF), Center for Accountability in Science, April 2015. Archived .pdf on file at DeSmog.
- “Genetically modified foods pose no risk to human health.”
- “Genetically modified foods have decreased the quantity of pesticides used, and the cost of pesticides.”
- “Genetically modified foods pose no risk to the environment.”
- “Genetically modified foods produce higher yields than conventional or organic foods.”
- “Genetically modified foods don’t need a mandatory, special label.”
January 31, 2015
Reporting at The Hill, CAS Chief Science Officer Joseph Perrone posits, “what if the assumed link between air pollution and childhood asthma doesn’t actually exist?” He then makes the argument that the “EPA’s ozone reductions may actually make asthma worse.”31Joseph Perrone. “Upending EPA’s science on pollution and asthma,” The Hill, January 31, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/bdAA2
According to Perrone, “poverty may be a more important risk factor for asthma than outdoor air pollution.” He contends that the EPA should “spend more time addressing real public health threats than imposing costly rules based on dubious science that may only make us poorer and sicker.”
Paul C. “Chip” Knappenberger and Patrick J. Michaels go on to quote Perrone in their own article at the Cato Institute titled “Asthma Justification for EPA Regulations Gutted by the Latest Science.”32Paul C. “Chip” Knappenberger and Patrick J. Michaels. ”Asthma Justification for EPA Regulations Gutted by the Latest Science,” Cato Institute, February 5, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/DGaX7
Center for Accountability in Science Contact & Location
As of May, 2016, the Secretary of State Charities Program reports that the Center for Accountability in Science shared a contact address with the following organizations:33“Charitable Solicitations Program Charity Profile Report: Registration #9640,” Secretary of State Charities Program. Archived .pdf on file at DeSmog.
- The Center for Organizational Research and Education (CORE)
- CENTER FOR CONSUMER FREEDOM, THE
- Environmental Policy Alliance
- Humane Society For Shelter Pets
- HumaneWatch
- PETA KILLS ANIMALS
Mailing Address:
1747 Pennsylvania Ave NW
Ste 1000
WASHINGTON DC 20006
Street Address:
1090 Vermont Ave NW
Ste 800
WASHINGTON DC 20005Phone: (202) 420-7871
Email [email protected]
Related Organizations
Center for Organizational Research and Education (CORE)
The Center for Accountability in Science (CAS) is listed as a Project of the Center for Organizational Research and Education (CORE). Some of CORE’s other projects include the following:34“Projects,” CoreProjects.com. Archived May 14, 2016. Archive URL: https://archive.ph/dIl1j
- Center for Accountability in Science
- Center for Consumer Freedom
- Humane Watch
- PETA Kills Animals
- Prop 65 Scam
- Environmental Policy Alliance
- Big Green Radicals
- EPA Facts
- Green Decoys
- Activist Facts
Berman Front Groups
Citizens for Responsibility and Ethics in Washington (CREW) which publishes BermanExposed.org, which provides a list of Richard Berman’s “Front Groups and Projects”. Note that web domain was since bought out by Berman and Company.
The archived website noted that Charity Navigator, an independent authority on charitable giving, issue donor advisories against five of Berman’s groups:35“Richard Berman’s Front Groups and Projects,” Berman Exposed. Archived May 11, 2016. Archive URL: https://archive.ph/SyoI5
- Center for Consumer Freedom
- Employment Policies Institute
- American Beverage Institute
- Center for Union Facts
- Enterprise Freedom Action Committee
The Center for Media and Democracy’s SourceWatch project also lists a number of other “front groups” operated by Richard Berman:36“Center for Consumer Freedom,” SourceWatch. Accessed May 13, 2016.
- ActivistCash.com
- AFT Facts
- American Beverage Institute
- AnimalScam.com
- Big Green Radicals
- Center for Consumer Freedom
- Center for Economic and Entrepreneurial Literacy
- Center for Organizational Research and Education
- Center for Union Facts
- CMDScam.com
- CREW Exposed
- CSPI Scam
- Defeat the Debt
- EmployeeRightsAct.com
- Employment Policies Institute
- Enterprise Freedom Action Committee
- EPA Facts
- Green Decoys
- Hands Off My Bacon
- HumaneWatch.org
- Interlock Facts
- Interstate Policy Alliance
- LaborPains.org
- LEED Exposed
- Maternity Pens
- MinimumWage.com
- NegligentDriving.com
- No Drink Tax
- ObesityMyths.com
- PETA Kills Animals
- Physician Scam
- Protecting Bad Teachers
- Responsible Limits
- Rethink Reform
- Rotten ACORN
- Teachers Union Exposed
- The New Prohibition
- Tipped Wage
- Unite Here Exposed
- Vote Our Future
- WorkerCenters
Other Resources
Resources
- 1“Joseph Perrone,” Science 2.0.com. Archived May 11, 2016. Archive URL: https://archive.ph/iajdc
- 2“About Us,” Center for Accountability in Science. Archived May 10, 2016. Archive URL: https://archive.ph/O6gHp
- 3“Web of Lies: Berman’s Astroturf Empire,” Stop HumaneWatch. Archived May 10, 2016. Archive URL: https://archive.ph/0zxO2
- 4“About Us,” Center for Accountability in Science. Archived May 10, 2016. Archive URL: https://archive.ph/O6gHp
- 5“Berman Enlists Industry Scientist for Latest Project, Flip-Flops On Cancer Risk of Tanning,” Citizens for Responsibility and Ethics in Washington (CREW), August 22, 2014. Archived May 10, 2016. Archive URL: https://archive.ph/Z6ztX
- 6“Berman Enlists Industry Scientist for Latest Project, Flip-Flops On Cancer Risk of Tanning,” Citizens for Responsibility and Ethics in Washington (CREW), August 22, 2014. Archived May 10, 2016. Archive URL: https://archive.ph/Z6ztX
- 7“CCF selected campaigns,” Sourcewatch. Accessed May 10, 2016.
- 8Molly Redden. “Notorious Astroturf Pioneer Rick Berman Is Behind Business Group’s Anti-Labor-Board Campaign,” Mother Jones, March 25, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/brmNX
- 9Eric Lipton. “Hard-Nosed Advice From Veteran Lobbyist: ‘Win Ugly or Lose Pretty’,” The New York Times, October 30, 2014. Archive URL: https://archive.ph/qG6FN
- 10“No, Climate Change Probably Isn’t Killing Your Sex Life,” Center for Accountability in Science, November 10, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/yESEt
- 11“EPA (sort of) Admits: Glyphosate Not Likely Carcinogen,” Center for Accountability in Science, May 9, 2016. Archived May 11, 2016. Archive URL: https://archive.ph/Y180a
- 12“Calling TIME Out on Plastic Alarmism,” Center for Accountability in Science, May 5, 2016. Archived May 11, 2016. Archive URL: https://archive.ph/JPqHK
- 13“How Much BPA is Safe?” Center for Accountability in Science, May 18, 2016. Archived May 11, 2016. Archive URL: https://archive.ph/fIJbg
- 14“Bisphenol-A (BPA): Does the science support a BPA ban?” Center for Accountability in Science, August, 2014. Archived May 11, 2016. Archive URL: https://archive.ph/KzmD5
- 15“Journal Retracts Study Claiming GMO Dangers Amid Allegations of Manipulated Data,” Center for Accountability in Science, January 18, 2016. Archived May 11, 2016. Archive URL: https://archive.ph/6LYW0
- 16“5 Things to Know about GMOs,” Center for Accountability in Science. Archived May 11, 2016. Archive URL: https://archive.ph/RzgEA
- 17“Center for Organizational Research and Education (formerly Center for Consumer Freedom),” Conservative Transparency. Data retrieved May 13, 2016.
- 18“Center for Organizational Research and Education (formerly Center for Consumer Freedom),” Conservative Transparency. Data retrieved May 13, 2016.
- 19“Foundation and Activist Group-Funded Research,” Center for Accountability in Science. Archived May 11, 2016. Archive URL: https://archive.ph/sFSbz
- 20“Government-Funded Science,” Center for Accountability in Science. Archived May 11, 2016. Archive URL: https://archive.ph/fytUx
- 21“Industry-Funded Research,” Center for Accountability in Science. Archived May 11, 2016. Archive URL: https://archive.ph/IjNlY
- 22“About Us,” Center for Accountability in Science. Archived May 10, 2016. Archive URL: https://archive.ph/O6gHp
- 23“Berman Enlists Industry Scientist for Latest Project, Flip-Flops On Cancer Risk of Tanning,” Citizens for Responsibility and Ethics in Washington (CREW), August 22, 2014. Archived May 10, 2016. Archive URL: https://archive.ph/Z6ztX
- 24(Press Release). “Joseph Perrone Joins SRI International to Direct Molecular Diagnostics and Rare and Neglected Diseases Group,” SRI International. Archived May 11, 2016. Archive URL: https://archive.ph/PjHmt
- 25“Joseph Perrone, Sc.D.” LinkedIn. Accessed May 10, 2016. Archived .pdf on file at DeSmog.
- 26“‘Safer’ chemicals in plastics may be hazardous to kids,” CBS News, July 9, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/lcZPZ
- 27“‘Safer’ chemicals in plastics may be hazardous to kids,” CBS News, July 9, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/lcZPZ
- 28Joseph Perrone. “All science is not equal,” The Baltimore Sun, January 4, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/GmW8d
- 29“5 Things to Know about GMOs,” Center for Accountability in Science. Archived May 11, 2016. Archive URL: https://archive.ph/RzgEA
- 30“5 Thinks You Should Know About… GMOs” (PDF), Center for Accountability in Science, April 2015. Archived .pdf on file at DeSmog.
- 31Joseph Perrone. “Upending EPA’s science on pollution and asthma,” The Hill, January 31, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/bdAA2
- 32Paul C. “Chip” Knappenberger and Patrick J. Michaels. ”Asthma Justification for EPA Regulations Gutted by the Latest Science,” Cato Institute, February 5, 2015. Archived May 11, 2016. Archive URL: https://archive.ph/DGaX7
- 33“Charitable Solicitations Program Charity Profile Report: Registration #9640,” Secretary of State Charities Program. Archived .pdf on file at DeSmog.
- 34“Projects,” CoreProjects.com. Archived May 14, 2016. Archive URL: https://archive.ph/dIl1j
- 35“Richard Berman’s Front Groups and Projects,” Berman Exposed. Archived May 11, 2016. Archive URL: https://archive.ph/SyoI5
- 36“Center for Consumer Freedom,” SourceWatch. Accessed May 13, 2016.