UNITED STATES COURT OF APPEALS 

FOR THE DISTRICT OF COLUMBIA CIRCUIT 

 

 ) 

ABDUL KARIM HASSAN, ) 

 ) 

 Plaintiff-Appellant, ) No. 12-5335 

 ) 

 v. ) REPLY IN SUPPORT OF 

 ) MOTION FOR SUMMARY 

FEDERAL ELECTION COMMISSION, ) AFFIRMANCE AND 

 ) RESPONSE TO MOTION 

 Defendant-Appellee. ) FOR SUMMARY REVERSAL 

 ) 

 ) 

APPELLEE FEDERAL ELECTION COMMISSION’S 

REPLY IN SUPPORT OF ITS MOTION FOR SUMMARY 

AFFIRMANCE AND RESPONSE TO APPELLANT’S 

MOTION FOR SUMMARY REVERSAL 

This case is well-suited for summary affirmance because Abdul Hassan 

faces no actual or imminent injury from the statute he challenges and thus raises no 

substantial challenge to the district court’s dismissal of his suit for lack of Article 

III standing. Even if Hassan could present a colorable argument for standing, 

summary affirmance would still be warranted on the district court’s alternative 

holding that Hassan’s claim on the merits is doomed to fail. There is no legal or 

historical support for his argument that the natural born citizen clause of the United 

States Constitution has been abrogated or repealed. This Court should therefore 

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 1 of 16
2 

summarily affirm the district court’s grant of the Federal Election Commission’s 

motion to dismiss and deny Hassan’s untimely motion for summary reversal.1

ARGUMENT 

I. SUMMARY DISPOSITION IS ESPECIALLY APPROPRIATE 

BECAUSE HASSAN HAS REPEATEDLY LITIGATED AND LOST 

HIS CHALLENGE TO THE CONSTITUTIONALITY OF THE 

CONSTITUTION’S NATURAL BORN CITIZEN CLAUSE 

This appeal’s lack of merit is most clearly demonstrated by the fact that six 

district courts (including the court below) and four courts of appeals have already 

considered Hassan’s claims regarding the natural born citizen clause, and all ten of 

those courts have rejected his arguments. Given this unanimous and extensive 

precedent — each decision of which is summarized below — the “merits of the 

parties’ positions are so clear that expedited action is justified and further briefing 

unnecessary.” Gray v. Poole, 243 F.3d 572, 575 (D.C. Cir. 2001). 

 Hassan v. Colorado, 870 F. Supp. 2d 1192 (D. Colo. 2012), aff’d, No. 

12-1190, 2012 WL 3798182 (10th Cir. Sept. 4, 2012). Hassan challenged the 

Colorado Secretary of State’s refusal to place Hassan’s name on the ballot as a 

candidate for president on the grounds that he did not satisfy the Constitution’s 

 

1

 Hassan’s response to the Commission’s motion and his motion for summary 

reversal were untimely filed on December 28, 2012. Hassan’s motion for 

summary reversal comes weeks after the December 10 deadline for such motions 

(see Order at 1 (Oct. 26, 2012)) and should be denied for that reason, as well as for 

the reasons set forth in the Commission’s motion for summary affirmance. 

Hassan’s response to the Commission’s motion was due on December 26. 

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3 

natural born citizenship requirement. The district court held that this eligibility 

requirement had not been implicitly repealed by the Fourteenth Amendment or 

invalidated under the absurdity doctrine — the same arguments that Hassan seeks 

to present to this Court on full briefing. 

The Tenth Circuit affirmed, describing the district court’s opinion as 

“extensive and thoughtful.” 

 Hassan v. Iowa, No. 11-574, slip op. (S.D. Iowa Apr. 26, 2012), aff’d, 

No. 12-2037 (8th Cir. Nov. 21, 2012).2

 Hassan challenged Iowa’s requirement that 

he certify his constitutional eligibility for the presidency in an affidavit of 

candidacy before he could appear on the state’s presidential ballot. The district 

court found that Hassan had standing to raise this challenge because he would have 

been otherwise able and ready to complete the affidavit of candidacy if he 

prevailed in the litigation. However, the court dismissed the case for failure to 

state a claim, finding no authority to support Hassan’s theory that the natural born 

citizen clause had been implicitly repealed. 

The Eighth Circuit affirmed in a per curiam opinion. 

 Hassan v. New Hampshire, No. 11-552, 2012 WL 405620 (D. N.H. 

Feb. 8, 2012), aff’d, No. 12-1280 (1st Cir. Aug. 30, 2012). Hassan challenged 

 

2 The district court’s decision is available at 

https://ecf.iasd.uscourts.gov/doc1/07711567012. The Eighth Circuit’s decision is 

available at https://ecf.iasd.uscourts.gov/doc1/07711683838.

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 3 of 16
4 

New Hampshire’s statement that it would not a accept declaration of candidacy for 

president from any declarant who was not a natural born citizen of the United 

States. The district court found that Hassan “[did] not provide any support for his 

argument” that the Fourteenth Amendment implicitly repealed the Natural Born 

Citizen Clause. 

The First Circuit affirmed for the reasons given by the district court.

 Hassan v. United States, No. 08-938, slip op. at 3-6 (E.D.N.Y. June 

15, 2010), aff’d on other grounds, 441 F. App’x 10, 2011 WL 2490948 (2nd Cir. 

June 21, 2011), cert. denied, 132 S. Ct. 1016 (2012).3

 Hassan brought an action 

directly challenging the natural born citizenship provision, and the district court 

found that Hassan had standing based on his ineligibility to run for President. 

However, the court dismissed the case for failure to state a claim, finding that 

“[p]articularly given the disfavor of implicit repeal in the statutory context, this 

court cannot imply intent to overturn a specific constitutional provision based only 

on generalized principles plaintiff draws from the First, Fifth, Fourteenth, Fifteenth 

Amendments.” 

The Second Circuit affirmed the district court’s judgment, holding that 

Hassan lacked standing because he had failed to allege with any specificity how 

 

3 The district court’s decision is available at 

https://ecf.nyed.uscourts.gov/doc1/12315746772.

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 4 of 16
5 

the natural born citizen requirement had injured him or was likely to do so in the 

immediate future. 

 Hassan v. Montana, No. 11-072, slip op. (D. Mont. May 3, 2012), 

appeal pending, No. 12-35402 (9th Cir. May 17, 2012).4

 Hassan challenged the 

state’s requirement that he execute a declaration of candidacy, including a 

statement that he is a natural born citizen of the United States, to run for president 

in Montana. The district court “adopted” the reasoning of the cases discussed 

above, finding that they “persuasively reject[ed]” Hassan’s arguments that the 

Fourteenth Amendment had not implicitly repealed the natural born citizen 

requirement. 

II. HASSAN LACKS STANDING 

Hassan’s response falls far short of showing each of the three essential 

elements of constitutional standing: injury-in-fact, causation, and redressability. 

See Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-01 (1992). Hassan candidly 

admits that the “two main reasons why [he] brought this challenge” are to remedy 

perceived discrimination against citizens because of their national origin and to 

redress certain wrongs exemplified by the Dred Scott decision. (See Appellant’s 

Opp’n to Mot. for Summ. Affirmance & Cross Mot. for Summ. Reversal (“Hassan 

 

4 The district court’s decision is available at 

https://ecf.mtd.uscourts.gov/doc1/11111136316.

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 5 of 16
6 

Opp’n”) at 6-7.) Entirely absent from his legal reform agenda is any actual or 

imminent injury to Hassan himself.5

In response to the Commission’s motion for summary affirmance, Hassan 

attempts to establish his standing by arguing that the “most remarkable and 

significant finding by the district court” was that “[n]either party disputes that the 

statute provides Hassan with authority to bring suit.” (Hassan Opp’n at 21 

(quoting Mem. Op. & Order (“Op.”) Civ. No. 11-2189, 2012 WL 4470304, at 8 n.5 

(D.D.C. Sept. 2012).) But this conflates a statutory right of action with Article III 

standing, which are distinct, independent requirements. Even if Hassan has a 

statutory right to sue under 26 U.S.C. § 9011, that would have no bearing on 

whether he meets the requirements of Article III. “It is settled that Congress 

cannot erase Article III’s standing requirements by statutorily granting the right to 

sue to a plaintiff who would not otherwise have standing.” Raines v. Byrd, 521 

U.S. 811, 820 n.3 (1997); see also Common Cause v. FEC, 108 F.3d 413, 419 

(D.C. Cir. 1997) (holding that 2 U.S.C. § 437g(a)(8) — a provision allowing 

certain private parties to bring suit against the Commission — “does not confer 

standing; it confers a right to sue upon parties who otherwise already have 

 

5 Hassan does not address the district court’s holding that he failed to satisfy 

the causation and redressability standing prongs (Op. at *5 n.8), which are 

independent bases for affirming the district court’s decision. (FEC Mot. for 

Summ. Affirmance at 10 n.1.) Hassan does not allege concrete facts showing that 

the natural born citizenship provision caused harm to his campaign and that its 

repeal would redress his alleged injury. 

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 6 of 16
7 

standing”). “[B]ecause Article III standing is always an indispensable element of 

the plaintiff’s case, neither [the courts] nor the Congress can dispense with the 

requirement — even if its application renders a [statutory] violation irremediable in 

a particular case.” Natural Res. Def. Council v. Pena, 147 F.3d 1012, 1020 (D.C. 

Cir. 1998). The district court correctly concluded that a statutory right of action 

does not provide Hassan constitutional standing under Article III. (Op. at *3.) 

 Hassan claims that his standing has been established by two Supreme Court 

decisions (Hassan Opp’n at 20-29), but neither decision supports that proposition. 

In FEC v. Nat’l Conservative Political Action Comm. (“NCPAC”), 470 U.S. 480 

(1985), the Commission had intervened in a lawsuit between private parties, 

arguing that the suit infringed on the Commission’s exclusive civil jurisdiction 

over enforcement of the Presidential Election Campaign Fund Act (“Fund Act”), 

26 U.S.C. §§ 9001-13. To defend that jurisdiction, the Commission argued that the 

private litigants had no “standing to bring a private action against another private 

party” under the Fund Act. NCPAC, 470 U.S. at 486. The Supreme Court agreed, 

holding that the Commission had standing “to bring a declaratory action to test the 

constitutionality of a provision of the Fund Act . . . because a favorable declaration 

would materially advance the FEC’s ability to expedite its enforcement.” 470 U.S. 

at 484-85. As a private party with no enforcement authority over the Fund Act, 

this holding cannot avail Hassan. 

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 7 of 16
8 

Hassan also relies on Adarand Constructors, Inc. v. Pena, 515 U.S. 200, 212 

(1995), in which the contractor plaintiff established injury-in-fact by showing that 

it would “very likely” compete with contractors favored by the statute at issue — 

an “imminent” injury that was “certainly impending.” Adarand, 515 U.S. at 211 

(internal quotation marks omitted). Hassan argues that he is similarly injured by 

being forced to compete on an unequal footing with candidates receiving grants 

under the Fund Act. (Hassan Opp’n at 21.) But, as the district court noted, Hassan 

cannot prevail on this argument without showing “that at some imminent or 

identifiable future time, he will be the nominee of a major or minor political party, 

as defined in the Fund Act, but will be denied funding, on an unequal footing with 

natural born citizens.” (Op. at *5.) Hassan has not made and cannot possibly 

make such a showing on the basis of the facts alleged in his complaint. See id. 

(noting that Hassan’s complaint contained no allegations that any voter or party 

held back support because of his status as a naturalized citizen); see also Hassan, 

441 F. App’x at 12 (Second Circuit holding that Hassan lacked standing because 

he “d[id] not allege . . . that any potential voter or contributor has declined to 

support him in light of his ineligibility for office”). 

Finally, Hassan asserts at length that he faces competitive injury because he 

might be deemed a “candidate” within the meaning of the Federal Election 

Campaign Act, 2 U.S.C. §§ 431-457, and certain Commission regulations, 

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 8 of 16
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11 C.F.R. §§ 100.72, 100.131. (Hassan Opp’n at 25-29.) This is simply irrelevant, 

as not all “candidates” qualify for grants under the Fund Act; only the presidential 

nominees of political parties so qualify. 26 U.S.C. §§ 9002(4), 9003; FEC Mot. for 

Summ. Affirmance at 3-4. Once again, Hassan has not shown any likelihood that 

he would ever become such a nominee even if he were constitutionally eligible to 

be elected president. (Op. at *4; FEC Mot. for Summ. Affirmance at 8-10.)6

III. HASSAN’S CLAIMS LACK MERIT 

The Commission has shown that this Court should summarily affirm the 

district court’s alternative holding that the natural born citizenship requirement has 

not been implicitly repealed. (FEC Mot. for Summ. Affirmance at 12-17; see also

supra pp. 2-5 (noting that every federal court to consider Hassan’s claims has 

rejected them).) In his response, Hassan argues that this Court should not 

summarily affirm because (1) the district court was required to empanel a threejudge court to review Hassan’s claims, and (2) this case is, according to Hassan, 

one of first impression. His arguments are meritless. 

 

6 Hassan notes that four of his prior lawsuits were dismissed for failure to 

state a claim, not on standing grounds. (Hassan Opp’n at 29; see also supra

pp. 2-5.) Far from establishing a blanket injury sufficient to convey standing to 

sue here, those cases turned on a specific act — submitting a statement of 

candidacy — that Hassan was willing and able to complete in each case. Here, 

however, Hassan has made no showing that he is similarly able to become the 

nominee of a major or minor political party eligible for public funds under the 

Fund Act. See 26 U.S.C. § 9003. 

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A. A Three-Judge Court Is Not Required for Frivolous or 

Insubstantial Claims 

Hassan argues that only a three-judge court can dismiss a case brought 

pursuant to 26 U.S.C. § 9011 for failure to state a claim. (Hassan Opp’n at 12-13.) 

Hassan relies on a sentence in Wertheimer v. FEC, 268 F.3d 1070, 1074 (D.C. Cir. 

2001), which notes that, as a general matter, dismissals for failure to state a claim 

are considered by a three-judge court. However, Hassan ignores the wellestablished exception to that general rule for insubstantial or frivolous claims. 

(FEC Mot. for Summ Affirmance at 11 n.2.) “A single district court judge should 

not certify to a three judge panel . . . frivolous or non-justiciable claims.” Nat’l 

Comm. of the Reform Party of the United States v. Democratic Nat’l Comm., 

168 F.3d 360, 367 (9th Cir. 1999); see also Bailey v. Patterson, 369 U.S. 31, 33 

(1962) (holding that three-judge court is not required if claim is “wholly 

insubstantial” or “frivolous”).7

 And Hassan’s assertion that a three-judge court 

 

7

 Section 9011(b) explicitly requires that it be construed in accordance with the 

three-judge court provision in 28 U.S.C. § 2284, the successor statute to the 

provision at issue in Bailey. A very similar standard also applies in the campaignfinance context under 2 U.S.C. § 437h, a provision of the Federal Election 

Campaign Act that provides for certification of constitutional questions directly to 

an en banc court of appeals. See Judd v. FEC, 304 F. App’x 874, 875 (D.C. Cir. 

2008) (“[J]udicial review provisions under 2 U.S.C. § 437h . . . do not apply 

where, as here, the constitutional challenge . . . is frivolous.”); Goland v. United 

States, 903 F.2d 1247, 1257-58 (9th Cir. 1990); Cal. Med. Ass’n v. FEC, 453 U.S. 

182, 192 n.14 (1981) (“[W]e do not construe § 437h to require certification of 

constitutional claims that are frivolous, or that involve purely hypothetical 

applications of the statute.”) (citations omitted). 

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 10 of 16
11 

could conserve judicial resources by rapidly sending this case to the Supreme 

Court (Hassan Opp’n at 8) is even farther afield: If his claims are not substantial 

enough to merit the attention of three judges from the lower courts — and they are 

not — they a fortiori fail to merit the attention of nine Justices. This is precisely 

why district courts serve an important gate-keeping role in weeding out frivolous 

or insubstantial cases under 2 U.S.C. § 9011(b) — a role the single-judge district 

court properly carried out when it dismissed this case. 

B. The Natural Born Citizenship Requirement Has Not Been 

 Repealed 

 Hassan claims that his case cannot be deemed “insubstantial” for purposes of 

summary affirmance because there is no Supreme Court authority that has settled 

the issue he presents. (Hassan Opp’n at 12-20.) In fact, there is ample authority on 

this point. The district court properly concluded the Schneider v. Rusk, 377 U.S. 

163, 165 (1964), line of cases — as well the decisions in the other cases brought by 

Hassan (discussed supra Part I) — stand for the proposition that the national born 

citizen requirement was not repealed by the Fifth and Fourteenth Amendments. 

(Op. at *6.) Decided long after the ratification of the Fourteenth Amendment, 

Schneider observed that “[t]he only difference [between naturalized and natural 

born citizens] drawn by the Constitution is that only the ‘natural born’ citizen is 

eligible to be President.” 377 U.S. at 165. 

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 11 of 16
12 

 Hassan suggests (Hassan Opp’n at 19) that the Schneider line of precedent 

has been superseded by Afroyim v. Rusk, 387 U.S. 253 (1967), in which the Court 

held that a naturalized citizen could not lose his citizenship by voting in a foreign 

country’s election. Although Afroyim does not even mention the natural born 

citizen requirement, Hassan seizes (Hassan Opp’n at 19-20) on its statement that a 

naturalized citizen generally possesses “all of the rights of a native citizen” and 

stands “on the footing of a native.” Afroyim, 387 U.S. at 261. But Hassan fails to 

note that the Court was actually quoting Osborn v. Bank of the United States, 22 

U.S. (9 Wheat.) 738, 827-28 (1824).8

 Because Osborn was decided long before the 

Fourteenth Amendment was ratified, it cannot lend any support to Hassan’s claims 

about the impact that Amendment had on the natural born citizenship requirement. 

Cases decided since Afroyim continue to note the vitality of the natural born 

citizenship requirement. See United States v. Klimavicius, 847 F.2d 28, 32 (1st 

Cir. 1988) (quoting Schneider and explaining “[t]he only difference drawn by the 

Constitution is that only the ‘natural born’ citizen is eligible to be President”). 

The unambiguous legislative history of the Fourteenth Amendment also 

supports summary affirmance. (Op. at *6 n.9.) Around the time of that 

 

8

 The Court in Afroyim relied upon Osborn in explaining that Congress did 

not have the power to “enlarge or abridge” the rights of naturalized citizens. 387 

U.S. at 261, 268. But Afroyim did not suggest that other provisions of the 

Constitution cannot determine the rights of naturalized citizens. 

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 12 of 16
13 

Amendment, Congress considered repealing the natural born citizen requirement. 

See generally Sarah Helene Duggin & Mary Beth Collins, “Natural Born” in the 

USA: The Striking Unfairness and Dangerous Ambiguity of the Constitution’s 

Presidential Qualifications Clause and Why We Need to Fix It, 85 B.U. L. Rev. 53, 

148 (2005) (citing H.R.J. Res. 52, 42d Cong. (2d Sess. 1871)); Malinda L. 

Seymore, The Presidency and the Meaning of Citizenship, 2005 B.Y.U. L. Rev. 

927, 947 (2005) (citing H.R.J. Res. 166-169, 42nd Cong. (3d Sess. 1872), and S. 

Res. 284, 41st Cong. (3d Sess. 1871)). In 2003, Congress considered amending the 

Constitution to repeal the requirement. See, e.g., S.J. Res. 15, 108th Cong. (1st 

Sess. 2003). And as recently as 2008, the Senate unanimously passed a resolution 

premised on the fact that the “Constitution of the United States requires that, to be 

eligible for the Office of the President, a person must be a ‘natural born [c]itizen’ 

of the United States.” S. Res. 511, 110th Cong., 154 Cong. Rec. S3645-01, 2008 

WL 1901585 (2d Sess. 2008). The resolution recounted the history of Senator 

John McCain’s birth and concluded based on expert legal analysis that he qualified 

as a natural born citizen. Id. These actions make clear that Congress itself did not 

and does not believe that the Fourteenth Amendment silently accomplished the 

repeal that Hassan advocates. 

The Constitution has its own specific and arduous amendment process. See

U.S. Const. art. V. That process is primarily vested in the legislative branches of 

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 13 of 16
14 

the federal and state governments. Id. The judicial branch has no role in amending 

the Constitution. See McPherson v. Blacker, 146 U.S. 1, 36 (1892) (rejecting the 

proposition that the Constitution may be “amended by judicial decision without 

action by the designated organs in the mode by which alone amendments can be 

made”); New v. Pelosi, No. 08-9055, 2008 WL 4755414, at *2 (S.D.N.Y. Oct. 29, 

2008) (“Whatever the merits, Plaintiff’s remedy lies in the constitutional 

amendment process, not the courts.”).9

 Indeed, in the few instances in which the 

qualifications for federal office have changed, these changes were accomplished by 

constitutional amendment. See U.S. Const. amend. XIV sec. 3 (prohibiting certain 

members of confederacy from serving in Congress), XXII (establishing 

presidential term limits). At most, Hassan presents policy arguments in favor of 

such an amendment (Hassan Opp’n at 4-8), but until the amendment process 

specified in the Constitution itself takes place, the natural born citizen requirement 

will remain in the Constitution and, by definition, be constitutional. 

 

9

 Hassan relies heavily (Hassan Opp’n at 5-6, 9-10, 15, 16) on analogizing the 

decision below to Dred Scott v. Sandford, 60 U.S. 393 (1856). Such a comparison 

is absurd on its face: Dred Scott was held to be a non-citizen without power even 

to sue in federal court; Hassan has presented his claims before ten such courts. 

Hassan also relies (Hassan Opp’n at 15-16) on McDonald v. City of Chicago, 130 

S. Ct. 3020, 3059-60 (2010), to argue that courts should find an implicit repeal of a 

portion of the Constitution when its provisions appear to be “irreconcilable” with 

each other. But Hassan fails to note that he is citing Justice Thomas’s concurrence, 

which was joined by no other Justice, and which in any event does not engage in 

the kind of constitutional interpretation that Hassan advocates. Nothing in Justice 

Thomas’s concurrence supports Hassan’s theory that courts should infer that 

provisions of the Constitution have been repealed by implication. 

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15 

CONCLUSION 

For the foregoing reasons, and those explained in the Commission’s Motion 

for Summary Affirmance, the Commission respectfully requests that this Court 

affirm the district court’s grant of the Commission’s motion to dismiss and deny 

Hassan’s motion for summary reversal. 

Respectfully submitted, 

Anthony Herman (D.C. Bar No. 424643) 

General Counsel 

Lisa J. Stevenson (D.C. Bar No. 457628) 

Deputy General Counsel – Law 

David Kolker (D.C. Bar No. 394558) 

Associate General Counsel 

Adav Noti (D.C. Bar No. 490714) 

Acting Assistant General Counsel 

 anoti@fec.gov 

/s/ Greg J. Mueller 

 Greg J. Mueller (D.C. Bar No. 462840) 

 Attorney 

 gmueller@fec.gov 

 FEDERAL ELECTION COMMISSION 

 999 E Street NW 

 Washington, DC 20463 

January 10, 2013 (202) 694-1650 

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 15 of 16
UNITED STATES COURT OF APPEALS 

FOR THE DISTRICT OF COLUMBIA CIRCUIT 

 

 ) 

ABDUL KARIM HASSAN, ) 

 ) 

 Plaintiff-Appellant, ) No. 12-5335 

 ) 

 v. ) 

 ) 

FEDERAL ELECTION COMMISSION, ) CERTIFICATE OF SERVICE 

 ) 

 Defendant-Appellee. ) 

 ) 

 ) 

CERTIFICATE OF SERVICE 

I hereby certify that on this 10th day of January, 2013, I electronically filed 

the Appellee Federal Election Commission’s Reply in Support of its Motion for 

Summary Affirmance and Response to Motion for Summary Reversal with the 

Clerk of the United States Court of Appeals for the D.C. Circuit by using the 

Court’s CM/ECF system. Service was made on the following through CM/ECF: 

Abdul Karim Hassan 

215-28 Hillside Avenue 

 Queens Village, NY 11427 

 (718) 740-1000 

 abdul@abdulhassan.com 

 /s/ Greg J. Mueller

 Federal Election Commission 

 999 E Street, NW 

 Washington, DC 20463 

 (202) 694-1650 

 gmueller@fec.gov 

USCA Case #12-5335 Document #1414542 Filed: 01/10/2013 Page 16 of 16