[brief] In Counts 1-8, Count 12, Counts 14-15, and Count 18, Complainant submits that “Respondents” violated N.J.S.A. 18A:12-24.1(g).  At its core, these Counts contend that “the Board” acted unethically because it did not provide accurate information, and/or presented biased or incomplete information to the public regarding the referendum.  In its review, the Commission finds that Complainant has not articulated exactly how any of the named Respondents may have specifically violated the confidentiality provision and/or the inaccurate information provision of N.J.S.A. 18A:12-24.1(g).  Instead, Complainant offers nothing more than general and vague conclusory statements about what the “Board” may have done, but does not offer any detailed facts evidencing how the named Respondents may have engaged in unethical conduct.  Because such generalized accusations are wholly insufficient to satisfy Complainant’s burden of proof, the Commission finds that the alleged violations of N.J.S.A. 18A:12-24.1(g) in Counts 1-8, Count 12, Counts 14-15, and Count 18 should be dismissed.  As for the other violations of N.J.S.A. 18A:12-24.1(g) detailed in the Complaint, namely against Respondent [...] in Count 5, Respondent [...] and Respondent [...] in Count 9, Respondent [...] in Count 10, and Respondent [...], Respondent [...], Respondent [...], and Respondent [...] in Count 13, the Commission finds that even if the facts as asserted are proven true by sufficient credible evidence, they would not support a violation(s) of N.J.S.A. 18A:12-24.1(g).  Even if Respondent [...] went “out of his way” to highlight the “potential negatives” if the referendum did not pass, and did not discuss “the shortcomings of the referendum … itself” (Count 5); even if Respondent [...] and Respondent [...] attended a [...] meeting and urged them to “remain neutral” (Count 9); even if Respondent [...], after using a disclaimer noting that he was speaking in his capacity as a private citizen (and not on behalf of the Board), “intentionally withheld material, non-private information” about the referendum (Count 10); and even if Respondent [...], Respondent [...], Respondent [...], and Respondent [...] have “grossly distorted the narrative around this referendum” and deleted certain social media posts “in an attempt to hide their membership and leadership within” [...], the Commission finds that Complainant has failed to proffer factual evidence that any of the named Respondents took action to make public, reveal or disclose information that was not public under any laws, regulations or court orders of this State, or information that was otherwise confidential.  Moreover, Complainant did not provide any factual evidence that substantiates the inaccuracy of the information provided by Respondents, and evidence that establishes that the inaccuracy was other than reasonable mistake or personal opinion or was not attributable to developing circumstances.  Although it is clear that the named Respondents, in the circumstances described, advocated for a matter or issue of public importance which they felt was in the best interests of the District, Complainant has not pled sufficient facts evidencing unethical behavior by each of the named Respondents.