No. 20-649

In the Supreme Court of the United States

LEVEL THE PLAYING FIELD, ET AL., PETITIONERS 

v.

FEDERAL ELECTION COMMISSION 

ON PETITION FOR A WRIT OF CERTIORARI

TO THE UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT 

BRIEF FOR THE RESPONDENT IN OPPOSITION 

LISA J. STEVENSON 

Acting General Counsel 

KEVIN DEELEY

Associate General Counsel 

HARRY J. SUMMERS

Assistant General Counsel

HAVEN G. WARD

Attorney

Federal Election Commission

Washington, D.C. 20463

ELIZABETH B. PRELOGAR

Acting Solicitor General

Counsel of Record

Department of Justice

Washington, D.C. 20530-0001

SupremeCtBriefs@usdoj.gov

(202) 514-2217
(I) 

QUESTION PRESENTED

Whether the Federal Election Commission acted 

“contrary to law,” 52 U.S.C. 30109(a)(8)(C), when it 

found that the Commission on Presidential Debates had 

not endorsed, supported, or opposed political candidates or parties, within the meaning of 11 C.F.R. 

110.13(a), and had adopted objective debate criteria, 

within the meaning of 11 C.F.R. 110.13(c).
(III) 

TABLE OF CONTENTS

Page

Opinions below .............................................................................. 1

Jurisdiction.................................................................................... 1

Statement ...................................................................................... 1

Argument....................................................................................... 6

Conclusion ................................................................................... 13

TABLE OF AUTHORITIES

Cases:

Alabama Libertarian Party v. Alabama Pub. 

Television, 227 F. Supp. 2d 1213 (M.D. Ala. 2002).......... 12

Allentown Mack Sales & Serv., Inc. v. N.L.R.B.,

522 U.S. 359 (1998)................................................................ 9

Arkansas Educ. Television Comm’n v. Forbes, 

523 U.S. 666 (1998).............................................................. 10

Becker v. FEC, 230 F.3d 381 (1st Cir. 2000), 

cert. denied, 523 U.S. 1007 (2001) ..................................... 12

Department of Commerce v. New York, 

139 S. Ct. 2551 (2019) ........................................................... 7

FEC v. Democratic Senatorial Campaign Comm., 

454 U.S. 27 (1981) ................................................................. 7

McCutcheon v. FEC, 572 U.S. 185 (2014) ........................... 13

Motor Vehicle Mfrs. Ass’n of U.S., Inc. v. State 

Farm Mut. Auto. Ins. Co., 463 U.S. 29 (1983)................... 7

Piccolo v. New York City Campaign Fin. Bd., 

No. 05-CV-7040, 2007 WL 2844939 (S.D.N.Y. 

Sept. 28, 2007) ..................................................................... 12

Timmons v. Twin Cities Area New Party, 

520 U.S. 351 (1997)........................................................ 12, 13

United States v. Johnston, 268 U.S. 220 (1925).................... 9
IV

Constitution, statutes, regulations, and rule: Page

U.S. Const. Amend. I ............................................................ 11

Administrative Procedure Act, 5 U.S.C. 551 et seq............ 12

Federal Election Campaign Act of 1971, 

52 U.S.C. 30101 et seq........................................................... 2

52 U.S.C. 30101(9)(B)(ii)................................................... 2

52 U.S.C. 30109(a)(1)......................................................... 3

52 U.S.C. 30109(a)(8)(C) ............................................... 5, 6

52 U.S.C. 30116(a)(7)(B)(i)................................................ 2

52 U.S.C. 30118(a) ......................................................... 2, 4

28 U.S.C. 1391(e)(1)............................................................... 12

11 C.F.R.:

Section 100.92 .................................................................... 2

Section 100.154 .................................................................. 2

Section 110.13 ................................................................ 2, 3

Section 110.13(a)........................................................ 4, 5, 6

Section 110.13(a)(1) ........................................................... 2

Section 110.13(c).................................................... 3, 5, 6, 9

Section 114.4(f).................................................................. 2

Sup. Ct. R. 10 ........................................................................... 9

Miscellaneous:

Black’s Law Dictionary (11th ed. 2019) ............................... 9

Funding and Sponsorship of Fed. Candidate 

Debates, 44 Fed. Reg. 76,477 (Dec. 27, 1979)..................... 2

Oxford English Dictionary (2d ed. 1989) ............................. 9

 
(1) 

In the Supreme Court of the United States

No. 20-649

LEVEL THE PLAYING FIELD, ET AL., PETITIONERS 

v.

FEDERAL ELECTION COMMISSION 

ON PETITION FOR A WRIT OF CERTIORARI

TO THE UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT 

BRIEF FOR THE RESPONDENT IN OPPOSITION 

OPINIONS BELOW

The opinion of the court of appeals (Pet. App. 1a-15a) 

is reported at 961 F.3d 462. The opinion of the district 

court (Pet. App. 16a-70a) is reported at 381 F. Supp. 3d 

78. An additional opinion of the district court (Pet. App. 

155a-190a) is reported at 232 F. Supp. 3d 130. 

JURISDICTION

The judgment of the court of appeals was entered on 

June 12, 2020. The petition for a writ of certiorari was 

filed on November 9, 2020. The jurisdiction of this 

Court is invoked under 28 U.S.C. 1254(1). 

STATEMENT 

Petitioners filed two administrative complaints with 

the Federal Election Commission (FEC or Commission) alleging that the Commission on Presidential Debates (CPD) and a group of its officers and directors 
2 

had violated federal laws restricting corporate contributions to federal election campaigns. Pet. App. 3a, 71a. 

The FEC dismissed the complaints. Id. at 71a-122a, 

123a-154a. The district court dismissed petitioners’ suit 

challenging the FEC’s decision. Id. at 16a-70a. The 

court of appeals affirmed. Id. at 1a-15a.

1. The Federal Election Campaign Act of 1971 

(FECA), 52 U.S.C. 30101 et seq., regulates the financing 

of political campaigns. As relevant here, FECA prohibits corporations from making “contribution[s]” to federal candidates. 52 U.S.C. 30118(a). FECA provides 

that “expenditures made by any person in cooperation, 

consultation, or concert, with, or at the request or suggestion of, a candidate, his authorized political committees, or their agents, shall be considered to be a contribution to such candidate.” 52 U.S.C. 30116(a)(7)(B)(i). 

The statute further provides that “[t]he term ‘expenditure’ does not include * * * nonpartisan activity designed to encourage individuals to vote.” 52 U.S.C. 

30101(9)(B)(ii).

For 40 years, the FEC has read those provisions to 

allow certain non-profit and media organizations to use 

corporate funds to stage candidate debates. See Funding and Sponsorship of Fed. Candidate Debates, 44 

Fed. Reg. 76,477, 76,734 (Dec. 27, 1979). The Commission has explained that, because debates are “designed 

to educate and inform voters rather than to influence 

the nomination or election of a particular candidate,” 

funds donated to or spent by a qualifying organization 

are not “contributions” or “expenditures” within the 

meaning of FECA. Ibid.; see 11 C.F.R. 110.13, 100.92,

100.154, and 114.4(f). A debate sponsor can qualify 

for that safe harbor only if it does not “endorse, support, 

or oppose” political parties or candidates. 11 C.F.R.
3 

110.13(a)(1). In addition, the sponsor must use “preestablished objective criteria” when choosing debate 

candidates, and cannot “use nomination by a particular 

political party as the sole objective criterion” for general-election debates. 11 C.F.R. 110.13(c).

The CPD is a non-profit, private corporation that 

was established in 1987 to sponsor presidential debates. 

Pet. App. 76a, 79a. The CPD has hosted debates for

every presidential election since then. Id. at 79a. Since 

2000, the CPD has considered a candidate eligible to 

participate in its debates if the candidate satisfies three 

criteria: (1) constitutional eligibility to be President; (2) 

qualification for enough state ballots to have a mathematical chance of winning the Electoral College; and (3) 

support of at least 15% of the national electorate, “as 

determined by five selected national public opinion polling organizations, using the average of those organizations’ most recently publicly-reported results at the 

time of determination.” Id. at 80a-81a (citation omitted); see id. at 3a. The CPD has stated that the polling 

threshold “best balance[s] the goal of being sufficiently 

inclusive to invite those candidates considered to be 

among the leading candidates” against other goals, such 

as ensuring that the debate is not “‘hindered by the 

sheer number of speakers.’” Id. at 87a (citation omitted).

2. Petitioners filed administrative complaints alleging that the CPD and twelve of its officers and directors 

had violated FECA and the FEC’s debate regulations 

in hosting the 2012 presidential debates. Pet. App. 76a; 

see 52 U.S.C. 30109(a)(1) (allowing any person who believes that a violation of the statute has occurred to file 

a complaint with the FEC). More specifically, they alleged that the CPD had violated 11 C.F.R. 110.13 by (1) 
4 

endorsing and supporting the Democratic and Republican parties and opposing third parties and independents and (2) using a 15% polling threshold to choose debate candidates. Pet. App. 2a-3a. Petitioners alleged 

that, as a result, the funds received and expended by the 

CPD constituted corporate contributions that were prohibited by 52 U.S.C. 30118(a). Pet. App. 76a. 

The Commission dismissed the complaints, finding 

that there was no reason to believe that the CPD had 

violated FECA or FEC regulations. Pet. App. 3a-4a. 

Following a challenge in court and a remand for further 

consideration of the record, the FEC again dismissed 

the complaints. Id. at 4a, 37a-38a. 

The Commission first determined that there was no 

reason to believe that the CPD had endorsed, supported, or opposed political candidates in violation of 11 

C.F.R. 110.13(a). Pet. App. 90a-105a. The FEC rejected petitioners’ reliance on decades-old statements 

by individual CPD directors and officers, explaining 

that those statements had little continuing relevance 

given the “significant indications” that the CPD had 

changed over time, had “made concerted efforts to be 

independent in recent years,” and was open to participation by independent candidates. Id. at 97a-99a. The 

Commission also rejected petitioners’ reliance on a 2015 

statement by a CPD co-chair that the CPD “primarily 

go[es] with the two leading candidates, it’s been the two 

political party candidates . . . except for 1992 when 

Ross Perot participated.” Id. at 100a (citation omitted). 

The FEC found that the statement, in context, “appears 

to be more an assertion of historical fact than an admission that [the] CPD favors candidates from the two major political parties over others.” Id. at 100a-101a. Finally, the Commission rejected petitioners’ reliance on 
5 

the fact that CPD directors and officers, acting in their 

personal capacities, had supported or contributed to political candidates. The FEC explained that those personal activities did not show that the CPD, a separate 

legal entity, had violated 11 C.F.R. 110.13(a). Pet. App.

102a-105a. 

The FEC also rejected petitioners’ contention that 

the CPD’s 15% polling threshold for debate participation was not an “objective” criterion, as required by 11 

C.F.R. 110.13(c). Pet. App. 105a-121a. The Commission

explained that its regulations do not require “a single 

set of objective criteria all staging organization[s] must 

follow,” but rather give organizations “leeway to decide 

what specific criteria to use.” Id. at 106a (citation omitted). The FEC rejected petitioners’ argument that the 

threshold was so high that only Democrats and Republicans could achieve it, observing that George Wallace 

in 1968, John Anderson in 1980, and Ross Perot in 1992 

had all reached the 15% threshold. Id. at 107a. The 

agency also rejected petitioners’ “policy arguments” 

about the virtues of including third-party candidates in 

the debates, explaining that “these points, no matter 

how compelling, do not bear on the [FEC’s] consideration of whether or not the 15 percent threshold is an objective criterion.” Id. at 120a.

3. Petitioners filed suit against the FEC, alleging 

that the agency’s dismissal of their administrative complaints was “contrary to law.” 52 U.S.C. 30109(a)(8)(C). 

The district court dismissed petitioners’ action. Pet. 

App. 37a-66a. The court found that the Commission’s 

analysis of the “endorse, support, or oppose” evidence 

was reasonable, explaining that petitioners’ “simple disagreement” with the FEC’s evaluation of the facts could 

not justify setting aside the agency’s decision. Id. at 
6 

58a. The court similarly found that the FEC’s decision 

regarding the 15% polling threshold was reasonable. 

Id. at 63a. 

4. The court of appeals affirmed. Pet. App. 1a-15a. 

Like the district court, the court of appeals found the 

Commission’s analysis of the “endorse, support, or oppose” regulation to be reasonable. Id. at 9a-10a. The 

court of appeals explained that the FEC had “thoughtfully evaluated the record,” and that petitioners had 

“failed to show that the [FEC’s] decisionmaking was arbitrary or unreasonable.” Id. at 10a. The court also 

held that the Commission had “acted reasonably” in reviewing the polling threshold. Id. at 14a. The court observed that “[t]here is no legal requirement that the 

[FEC] make it easier for independent candidates to run 

for President.” Ibid.

ARGUMENT

Petitioners contend (Pet. 17-38) that the FEC acted 

contrary to law in dismissing their claims that the CPD 

had endorsed, supported, and opposed political candidates, in violation of 11 C.F.R. 110.13(a), and had failed 

to apply objective debate-eligibility criteria, in violation 

of 11 C.F.R. 110.13(c). The court of appeals correctly 

rejected those arguments, and its decision does not conflict with any decision of this Court or another court of 

appeals. Further review is not warranted. 

1. The court of appeals correctly sustained the 

FEC’s rejection of petitioners’ claims that the CPD had 

violated 11 C.F.R. 110.13(a) by endorsing, supporting, 

or opposing candidates or parties. See Pet. App. 5a-10a. 

A reviewing court may overturn the Commission’s decision to dismiss an administrative complaint only if that 

decision was “contrary to law.” 52 U.S.C. 30109(a)(8)(C). 
7 

Under this Court’s precedents, a reviewing court applying that standard owes “deference” to the FEC’s application of the statute, and the court should uphold the 

agency’s decision as long as it is “‘sufficiently reasonable’ to be accepted.” FEC v. Democratic Senatorial 

Campaign Comm., 454 U.S. 27, 37, 39 (1981) (citation 

omitted). To satisfy that requirement, the Commission

need only have “examined ‘the relevant data’ and articulated ‘a satisfactory explanation’ for [its] decision, ‘including a rational connection between the facts found 

and the choice made.’” Department of Commerce v.

New York, 139 S. Ct. 2551, 2569 (2019) (quoting Motor 

Vehicle Mfrs. Ass’n of U.S., Inc. v. State Farm Mut. 

Auto. Ins. Co., 463 U.S. 29, 43 (1983)). 

Here, the FEC “carefully considered” petitioners’ 

arguments, “thoughtfully evaluated the record,” and 

then “offered detailed explanations in support of its 

view that plaintiffs failed to show impermissible bias.” 

Pet. App. 5a, 10a. For example, in evaluating petitioners’ invocation of decades-old statements made by individual CPD officers and directors, “it was reasonable 

for the [FEC] to believe that statements made about the 

CPD in 1987 do not adequately describe the CPD as it 

exists today.” Id. at 6a; see id. at 8a (“The [FEC] considered [petitioners’] submissions and articulated reasonable explanations for assigning the decades-old 

statements little probative value.”). Petitioners also relied on “contemporaneous evidence of the CPD’s alleged bias,” but the Commission “again provid[ed] reasonable explanations supported by the record,” for example by “[c]onsidering [a CPD officer’s] words in the 

appropriate context.” Id. at 8a-9a. The court determined that petitioners’ arguments “amount to a disa-
8 

greement with the Commission’s view,” but that petitioners “ha[d] failed to show that the [FEC’s] decisionmaking was arbitrary or unreasonable.” Id. at 10a. 

Petitioners contend that the Commission and court 

of appeals “categorically reject[ed] circumstantial evidence” and required petitioners to obtain “unattainable 

‘smoking gun’ proof” of bias in order to prevail. Pet. 19-

20; see Pet. 21 (“FEC’s new categorical refusal to consider this type of circumstantial evidence”); Pet. 22 

(“categorically excludes * * * evidence demonstrating 

the partisan bias”); Pet. 25 (“the D.C. Circuit agreed 

with the FEC that, as a matter of law, none of this evidence could even conceivably inform the FEC’s assessment”). Neither the FEC nor the court of appeals imposed any such categorical rule. The FEC explained: 

“[T]he Commission must evaluate whether [petitioners’] evidence on the formation and evolution of CPD 

and on the alleged partisanship of CPD officers and directors either demonstrates directly or supports a reasonable inference that the CPD has endorsed or supported the Democratic and Republican Parties * * * or 

opposed third parties.” Pet. App. 92a (emphasis added). 

After evaluating the evidence that petitioners had advanced, the agency concluded that the evidence “does 

not support a reasonable inference that CPD endorses 

supports or opposes political candidates or parties.” Id. 

at 105a (emphasis added). The court of appeals accordingly explained that, “far from ignoring [petitioners’] 

evidence, the [FEC] thoughtfully evaluated the record” 

and “offered detailed explanations in support of its 

view.” Id. at 10a.

Petitioners also argue (Pet. 22-26) that the evidence 

supports their assertion that the CPD has supported 

major-party candidates and opposed other candidates. 
9 

But the FEC reasonably explained why it found petitioners’ evidence inadequate, see pp. 4-5, supra, and petitioners’ factbound objections to the agency’s analysis 

do not warrant further review. See Sup. Ct. R. 10 (“A 

petition for a writ of certiorari is rarely granted when 

the asserted error consists of erroneous factual findings 

or the misapplication of a properly stated rule of law.”); 

United States v. Johnston, 268 U.S. 220, 227 (1925) 

(“We do not grant a certiorari to review evidence and 

discuss specific facts.”). 

2. The court of appeals also correctly sustained the 

FEC’s rejection of petitioners’ claims that the CPD’s 

15% polling threshold for presidential debates was not 

an objective criterion under 11 C.F.R. 110.13(c). The 

word “objective” means “[o]f, relating to, or based on 

externally verifiable phenomena, as opposed to an individual’s perceptions, feelings, or intentions.” Black’s 

Law Dictionary 1291 (11th ed. 2019); see Oxford English Dictionary 643 (2d ed. 1989) (“[d]ealing with, or 

laying stress upon, that which is external to the mind; 

treating of outward things or events, rather than inward thoughts or feelings”). This Court likewise has 

construed the term “objective” to mean “supported by 

evidence external to the [decisionmaker’s] own (subjective) impressions.” Allentown Mack Sales & Serv., Inc. 

v. N.L.R.B., 522 U.S. 359, 368 n.2 (1998). A 15% polling 

threshold is objective because it relies on externally 

verifiable information (namely, the level of public support for particular candidates as measured by polls), rather than on the debate organizers’ subjective impressions of the candidates. 

The conclusion that the CPD may use a 15% polling 

threshold accords with this Court’s precedents. The 
10

Court has held that even a government institution hosting a debate has the right to exclude a candidate who 

has “generated no appreciable public interest.” Arkansas Educ. Television Comm’n v. Forbes, 523 U.S. 666, 

682-683 (1998). The CPD, a private organization, may 

likewise use a 15% polling threshold to exclude candidates who have not generated substantial public support, and to implement a “preference for smaller debates where the candidates with the most support are 

given more time to share their views with voters.” Pet. 

App. 9a. 

The FEC’s conclusion also comports with the agency’s 

longstanding application of the regulatory term “objective.” In 1998, in its “first major enforcement action under this regulation,” the Commission explained that the

“CPD’s use of polling data * * * did not result in an 

unlawful corporate contribution.” Pet. App. 129a. The 

FEC observed at the time that it would make “little 

sense” if “a debate sponsor could not look at the latest 

poll results even though the rest of the nation could look 

at this as an indicator of a candidate’s popularity.” Ibid.

(citation omitted). 

Petitioners argue that the 15% polling threshold is 

not objective because it is not “fair” and “equitable” to 

minor parties. Pet. 27 (citation omitted). That view conflicts with the most natural reading of the word “objective.” See p. 9, supra. Petitioners’ argument also conflicts with the FEC’s longstanding view of its own regulation. The agency has explained that it cannot “question each and every . . . candidate assessment criterion,” that “the choice of which objective criteria to use 

is largely left to the discretion of the staging organization,” and that the Commission “gives great latitude” to 

debate organizers. Pet. App. 128a-129a (brackets and 
11

citations omitted). In addition, petitioners’ proposed 

interpretation—under which the FEC could review private debate-organizers’ criteria to determine whether 

they are “fair”—would raise significant First Amendment questions. 

Petitioners also suggest (Pet. 30) that no independent or minor-party candidate “has ever satisfied, or 

could ever have satisfied,” the 15% threshold. Even if 

that suggestion was accurate, it would be beside the 

point because “a threshold does not become ‘subjective’ 

merely because it is difficult to reach.” Pet. App. 14a. 

In any event, petitioners are incorrect: George Wallace 

(1968), John Anderson (1980), and Ross Perot (1992) are 

“independent candidates who achieved at least 15% support in pre-election polling.” Id. at 12a-13a; see id. at 

61a-63a, 65a-66a (district court findings); id. at 107a120a (FEC analysis). 

Finally, petitioners argue (Pet. 32) that the CPD 

could “manipulate” its 15% polling threshold to exclude 

independent candidates. The FEC has recognized that 

a debate organizer’s eligibility criterion might not qualify as objective if it has been “‘fixed’” or “arranged in 

some manner so as to guarantee a preordained result.” 

Pet. App. 129a (citation omitted). In denying petitioners’ administrative complaint, the Commission simply

concluded that petitioners had failed to produce evidence of any such manipulation here. As the district 

court observed, petitioners have offered only “conjecture” about “hypothetical misconduct,” not evidence of 

actual misconduct. Id. at 64a-65a. 

3. The decision below does not conflict with any decision of another court of appeals. Petitioners assert 

(Pet. 38) that, “[b]ecause FECA permits judicial review 

only in the District Court for the District of Columbia, 
12

52 U.S.C. § 30109(a)(8)(A), there is no mechanism for 

further percolation of this issue.” That is incorrect. 

Other parties have challenged the FEC’s debate regulations under the Administrative Procedure Act, 

5 U.S.C. 551 et seq. See, e.g., Becker v. FEC, 230 F.3d 

381, 384 (1st Cir. 2000), cert. denied, 532 U.S. 1007

(2001). In fact, petitioners brought (but later abandoned) just such a challenge after the FEC denied a petition for rulemaking. See Pet. 13 n.4; see also Pet. App. 

15a (“[Petitioners] suggest that the [FEC]’s rejection of 

their [rulemaking] petition was arbitrary and capricious 

‘for the same reasons’ they challenge the [FEC]’s decisions about the CPD’s neutrality and the 15% polling 

criterion.”). Other plaintiffs could file similar suits 

throughout the country. See 28 U.S.C. 1391(e)(1). The 

issues that petitioners raise also could arise outside the 

District of Columbia, in challenges to debate criteria in 

state and local races. See, e.g., Alabama Libertarian 

Party v. Alabama Pub. Television, 227 F. Supp. 2d 1213 

(M.D. Ala. 2002); Piccolo v. New York City Campaign 

Fin. Bd., No. 05-cv-7040, 2007 WL 2844939 (S.D.N.Y.

Sept. 28, 2007). Petitioners thus are mistaken in asserting (Pet. 38) that, “[a]bsent this Court’s review, the 

opinion below will likely remain the last word on the 

subject.” 

Petitioners also argue (Pet. 35) that this Court 

should grant review because the CPD “uses its vast 

power to stifle political competition and cement the 

Democratic and Republican parties’ duopoly control 

over the Presidency.” They contend (ibid.) that the “duopoly” has had “pernicious effects,” has “driven each of 

the major parties to partisan extremes,” and has “left 

constituents out in the cold.” But whatever the merits 

of a more pluralistic party system, “American politics 
13

has been, for the most part, organized around two parties since the time of Andrew Jackson.” Timmons v.

Twin Cities Area New Party, 520 U.S. 351, 367 (1997). 

Neither the Commission nor the courts are authorized

to use FEC regulations to restructure that system. To 

the contrary, for the FEC to deploy its regulations to

“level the playing field” (as one petitioner’s name puts 

it) would itself raise serious constitutional questions. 

See McCutcheon v. FEC, 572 U.S. 185, 207 (2014) (“No 

matter how desirable it may seem, it is not an acceptable governmental objective to ‘level the playing field,’ or 

to ‘level electoral opportunities,’ or to ‘equalize the financial resources of candidates.’”) (brackets and citation omitted). 

CONCLUSION

The petition for a writ of certiorari should be denied. 

Respectfully submitted.

LISA J. STEVENSON 

Acting General Counsel 

KEVIN DEELEY

Associate General Counsel 

HARRY J. SUMMERS

Assistant General Counsel

HAVEN G. WARD

Attorney

Federal Election Commission

ELIZABETH B. PRELOGAR

Acting Solicitor General

FEBRUARY 2021