No. 08-205 

IN THE

Supreme Court of the United States 

CITIZENS UNITED, 

 Appellant, 

 v. 

FEDERAL ELECTION COMMISSION, 

 Appellee. 

_________________________ 

On Appeal From The United States District Court 

For The District Of Columbia 

_________________________ 

Supplemental Brief Amicus Curiae of The 

Reporters Committee for Freedom of the Press 

in Support of Appellant 

Lucy A. Dalglish 

 Counsel of Record 

Gregg P. Leslie 

John Rory Eastburg 

Hannah Bergman 

Samantha Fredrickson 

The Reporters Committee for 

 Freedom of the Press 

1101 Wilson Blvd., Suite 1100 

Arlington, Va. 22209 

(703) 807-2100 
i

TABLE OF CONTENTS 

TABLE OF AUTHORITIES .......................................ii

STATEMENT OF INTEREST ................................... 1

SUMMARY OF ARGUMENT .................................... 2

ARGUMENT............................................................... 3

I. The government has interpreted the 

Constitution as allowing for expansive 

regulation of corporate and union spending 

on express advocacy, without regard for 

First Amendment protections of the press........... 3

II. This Court’s jurisprudence must be 

interpreted as requiring a constitutionally 

compelled media exemption from campaign 

finance laws ........................................................... 6

III.The constitutionally compelled media 

exemption must be defined based on the 

intent of the entity to gather and 

disseminate news ................................................ 10

CONCLUSION.......................................................... 17
ii

TABLE OF AUTHORITIES 

Cases

Austin v. Michigan Chamber of Commerce, 

494 U.S. 652 (1990) ................................. 2, 3, 11, 13 

Cusumano v. Microsoft Corp., 162 F.3d 708 

(1st Cir. 1998) ........................................................ 15 

Fed. Elections Comm’n v. Phillips Publ’g., 

517 F.Supp. 1308 (D.D.C. 1981)............................ 12 

Grosjean v. American Press Co., Inc. 297 U.S. 

233 (1936)................................................................. 4 

In re Madden, 151 F.3d 125 (3d Cir. 1998).............. 16 

McConnell v. Federal Election Comm’n, 540 

U.S. 93 (2003) .................................................passim 

Miami Herald Publ’g Co. v. Tornillo, 418 

U.S. 241.................................................................. 10 

Mills v. Alabama, 384 U.S. 214 (1966) ............ 8, 9, 13 

New York Times Co. v. Sullivan, 376 U.S. 

254 (1964)............................................................... 10 

Shoen v. Shoen, 5 F.3d 1289 (9th Cir. 1993)............ 16 

The Readers Digest Ass’n. v. Fed. Elections 

Comm’n., 509 F.Supp. 1210 (S.D.N.Y. 

1981);...................................................................... 12 

United States v. CIO, 335 U.S. 106 (1948)......... 7, 8, 9 
iii

von Bulow v. von Bulow, 811 F.2d 136, 144-

45 (2d Cir. 1987) .................................................... 15 

Statutes

Bipartisan Campaign Reform Act of 2002..... 2, 3, 5, 7 

Other Authorities

151 Cong.Rec. H9478-01 (Nov. 2, 2005)................... 11 

Brief Amicus Curiae of Reporters Committee 

for Freedom of the Press, Citizens United 

v. Federal Election Comm’n, No. 08-205............... 11 

In re ABC, CBS, NBC, New York Times, Los 

Angeles Times and Washington Post, et al. 

Matter Under Review 4929, 5006, 5090 

and 5117 at 4 (Fed. Elections Comm’n Dec. 

20, 2000)................................................................. 13 

In the Matter of Robert K. Dornan, et. al,

Matter Under Review 4689, addt’l 

statement of Comm’r Mason, (Fed. 

Elections Comm’n Feb. 14, 2000).......................... 16 

Richard Hasen, Lessons from the clash 

between campaign finance laws and the 

blogosphere, 11 NEXUS 23 (2006) .......................... 14 
1

STATEMENT OF INTEREST1

The Reporters Committee for Freedom of the 

Press is a voluntary, unincorporated association of 

reporters and editors that works to defend the First 

Amendment rights and freedom of information interests of the news media. The Reporters Committee 

has provided representation, guidance and research 

in First Amendment and Freedom of Information Act 

litigation since 1970. 

As stated in the initial brief filed by the Reporters 

Committee in this case, the Reporters Committee has 

an interest in ensuring that the Bipartisan Campaign Reform Act of 2002 (“BCRA”), 2 U.S.C. § 431 et 

seq., is not used to suppress this feature-length political documentary, as it would be an “obvious and 

flagrant abridgement of the constitutionally guaranteed freedom of the press.” Mills v. Alabama, 384 

U.S. 214, 219 (1966). 

                                                           

1 Pursuant to Sup. Ct. R. 37, counsel for the Reporters Committee declare that they authored this brief in total with no assistance from the parties; that no individuals or organizations 

made a monetary contribution to the preparation and submission of this brief; and that written consent of all parties to the 

filing of the brief amicus curiae has previously been filed with 

the Clerk. 
2

SUMMARY OF ARGUMENT 

Amicus curiae The Reporters Committee for 

Freedom of the Press (the “Reporters Committee”) 

urges the Court to clarify its precedent in Austin v. 

Michigan Chamber of Commerce, 494 U.S. 652 

(1990), and McConnell v. Federal Election Comm’n, 

540 U.S. 93 (2003) to hold that these rulings are constitutional only if they allow the news media to engage in what would otherwise be regulated as “express advocacy” by a corporation. 

The Bipartisan Campaign Reform Act of 2002 can 

survive constitutional scrutiny if this Court recognizes a broadly defined exemption for the news media consistent with the First Amendment’s protection 

of the press. 

The government’s reading of Austin and McConnell, as articulated during the initial oral argument 

in this case, suggest those rulings do not stand for 

this proposition. However, this Court’s precedent, 

prior to Austin, supports such an interpretation. 

Moreover, the broadly defined exemption for the 

news media must be based on the intent of the news 

organization to disseminate news to the public, rather than a definition directed at protecting only at 

the traditional, or “institutional,” press. 

The original, laudable intent of Congress presumably was to limit speech by corporations that 

seek to promote their own interests by influencing 

elections, while continuing to allow all other commentary (either non-corporate entities or by the news 
3

media) on political issues. But by crafting campaign 

finance reform legislation with such attention to corporate form in a world in which so much public communication is conducted through such means, far too 

much speech is either barred, chilled, or subject to 

government approval through regulation by the FEC. 

ARGUMENT 

I. The government has interpreted the 

Constitution as allowing for expansive 

regulation of corporate and union spending 

on express advocacy, without regard for 

First Amendment protections of the press. 

This Court directed supplemental briefing on 

whether its precedent in Austin v. Michigan Chamber of Commerce, 494 U.S. 652 (1990), and the portion of McConnell v. Federal Election Comm’n, 540 

U.S. 93 (2003) which addresses the facial validity of -

Section 203 of the Bipartisan Campaign Reform Act 

of 2002 (BCRA), 2 U.S.C. § 441b, should be overruled. 

The cases should be clarified, given the government’s assertions at oral argument that under these 

two decisions, Congress has broad power to restrict 

corporate and union spending on the “functional 

equivalent of express advocacy” via a wide variety of 

media, including books and the Internet, without a 

required exemption for the news media. 

During a lengthy exchange over the breadth of 

Congress’ power to regulate speech in this area, Jus-
4

tice Alito asked whether the Constitution required 

Congress to limit its regulation to electioneering 

communications on broadcast and cable rather than 

extending the statute to books, DVDs, or the Internet. The government’s counsel replied, “The Constitution would have permitted Congress to apply the 

electioneering communication restrictions. . . . Those 

could have applied to additional media as well.” Tr. 

Oral Argument at 27:6, Citizens United v. Federal 

Election Comm’n, No. 08-205. The government continued to state that Congress could stop the use of 

corporate treasury funds to publish a book that was 

express advocacy. Id. at 28:1, Id. at 29:10 (“It – it 

can’t be prohibited, but a corporation could be barred 

from using its general treasury funds to publish the 

book and could be required to use – to raise funds to 

publish the book using its PAC.”).2

The government conceded only that there is a “potential argument” that the “institutional press” 

would have some First Amendment rights in this 

situation. Id. at 28:7. It was also the government’s 

contention that the Court had not addressed whether 

“restrictions on the use of corporate treasury funds 

for electioneering can constitutionally be applied to 

media corporations.” Id. at 34:14. 

                                                           

2 While the government seems content with requiring corporate 

speakers to create FEC-registered political action committees, 

Tr. Oral Argument at 27:19, such a restriction is nothing short 

of a licensure requirement on the news media of a type that has 

long been held repugnant to the principles underlying the First 

Amendment. See Grosjean v. American Press Co., Inc. 297 U.S. 

233 (1936). 
5

These statements indicate both confusion and a 

misunderstanding of this Court’s precedent with regard to campaign finance regulations and the media. 

On re-argument, these statements must be taken 

by the Court as the passing of the fears Justice Thomas warned against in McConnell. 540 U.S. at 284 

(Thomas, J., concurring in part and dissenting in 

part) (“What is to stop a future Congress from determining that the press is ‘too influential,’ and that 

the ‘appearance of corruption’ is significant when 

media organizations endorse candidates or run 

‘slanted’ or ‘biased’ news stories in favor of candidates or parties?”). 

The First Amendment’s protections of the press 

and speech do not allow Congress to validly pass 

such far-reaching statutes.3 Yet, there is clearly an 

interest in Congress in expanding campaign finance 

regulation. See McConnell at 185 (Op. of Scalia, J. 

citing 148 Cong. Rec. S2101 (Mar. 20, 2002) (statement of Sen. Feingold)) (“This is a modest step, it is a 

                                                           

3 In fact, Congress could broaden the scope of what types of 

communications are covered by BCRA simply by modifying the 

definition of “electioneering communication,” 2 U.S.C. 

434(f)(3)(A)(i), which presently contains the modifier that limits 

BCRA to broadcasts only. A change of definition that eliminates 

this qualifier might seem like a mere “legislative fix” to Congress — after all, communications about elections are not inherently limited to those that are broadcast, but would logically 

cover communications in print, over the Internet, and even by 

oral exposition at a public event. Such a change in definition 

would then leave much political commentary out of the rather 

narrow media exemption in the statute, which only discusses 

news programs on broadcasts. 
6

first step, it is an essential step, but it does not even 

begin to address, in some ways, the fundamental 

problems that exist with the hard money aspect of 

the system.”). Before the situation is further complicated, the Court should take this opportunity to clarify the First Amendment protections for news media, 

broadly defined, as they exist with respect to campaign finance laws. If it does not, there will be nothing to stop Congress, as Justice Thomas pointed out, 

from regulating campaign endorsements and editorials by the news media. 

II. This Court’s jurisprudence must be interpreted as requiring a constitutionally compelled media exemption from campaign finance laws. 

The government’s interpretation of this Court’s 

precedent incorrectly focuses on only its relatively 

recent holdings in Austin and McConnell. In fact, 

regulation of campaign finance has a long history in 

the United States, one that has always heeded the 

First Amendment’s protection of a free press. This 

constitutional protection for the news media has become so ingrained within the consciousness of lawmakers that in the campaign finance legislative debates that led to BCRA, there was little discussion of 

the need to exempt the press from these statutes. 

BCRA includes this long-standing exemption. 2 

U.S.C. § 434 (f)(3)(B)(i). It excludes from regulation, 

among other things, speech that, “[a]ppears in a 

news story, commentary, or editorial distributed 

through the facilities of any broadcast, cable, or satellite television or radio station, unless such facilities 
7

are owned or controlled by any political party, political committee, or candidate.” Id. 

This Court first extensively dealt with the question of press activity in conflict with a campaign finance law in United States v. CIO, 335 U.S. 106 

(1948). There, this Court considered whether the 

Federal Corrupt Practices Act, a campaign finance 

law from 1925, prohibited the publication and distribution of a weekly periodical by a labor union that 

urged union members to vote for a congressional 

candidate. Debates on the Senate floor over the legislation indicated that the statute had not been intended to reach such activities of the press. Id. at 120 

(“[I]t is clear that Congress was keenly aware of the 

constitutional limitations on legislation and of the 

danger of the invalidation by the courts of any enactment that threatened abridgment of the freedoms 

of the First Amendment.”). Given such history, the 

Court found that if the statute, 

were construed to prohibit the publication, by corporations and unions in the 

regular course of conducting their affairs, of periodicals advising their members, stockholders or customers of danger or advantage to their interests from 

the adoption of measures or the election 

to office of men, espousing such measures, the gravest doubt would arise in 

our minds as to its constitutionality. 

Id. at 121. Such language indicates a requirement 

arising from the First Amendment’s protection of 

press freedom that campaign finance laws — tar-
8

geted at either labor unions or corporations — not 

constrict the press. This is true regardless of whether 

it was the print-based press that existed in 1948 or 

the broadcast and online news media that exist today. 

The holding in CIO was reiterated by the Court in 

Mills v. Alabama, 384 U.S. 214 (1966) when this 

Court struck down Alabama’s campaign finance 

statute. “The Alabama Corrupt Practices Act by providing criminal penalties for publishing editorials 

such as the one here silences the press at a time 

when it can be most effective. It is difficult to conceive of a more obvious and flagrant abridgment of 

the constitutionally guaranteed freedom of the 

press.” Id. at 219. The statute prohibited newspaper 

editorials published on election day urging readers to 

vote for a candidate. Id. at 218. 

Whatever differences may exist about 

interpretations of the First Amendment, 

there is practically universal agreement 

that a major purpose of that Amendment was to protect the free discussion 

of governmental affairs. This of course 

includes discussions of candidates, 

structures and forms of government, the 

manner in which government is operated or should be operated, and all such 

matters relating to political processes. 

The Constitution specifically selected 

the press, which includes not only 

newspapers, books, and magazines, but 

also humble leaflets and circulars, to 
9

play an important role in the discussion 

of public affairs. 

Id. (citations omitted). 

Thus, it cannot be only by legislative grace that 

the press is exempted from campaign finance statutes, as the government suggested in the initial oral 

argument in this case. Tr. at 27. The First Amendment and this Court’s jurisprudence compel a press 

exemption from these laws. Where campaign finance 

statutes have not clearly exempted the media, this 

Court’s decisions have prohibited their application to 

the press so that they may be saved. See CIO, 335 

U.S. at 121. Yet, the government in oral argument 

said Congress could, by statute, prohibit a book endorsing a candidate from being published by a corporation prior to an election. Tr. at 27. This Court has 

never tolerated such an infringement on freedom of 

the press. Indeed, where the press has been the vehicle by which public discourse of items of political importance has occurred, First Amendment protections 

have been strengthened. See New York Times Co. v. 

Sullivan, 376 U.S. 254 (1964) (constitutionalizing 

protections for certain potentially libelous speech); 

Miami Herald Publ’g Co. v. Tornillo, 418 U.S. 241 

(1974) (striking down a “right of access” statute that 

interfered with the editorial judgment of news editors). 

The Court should take this opportunity to reiterate the essence of previous holdings in its campaign 

finance cases dating back more than half a century. 

If its statements at oral argument are to be believed, 

the government has lost sight of a fundamental pur-
10

pose of First Amendment jurisprudence. The press, 

as a constitutional matter, must be and has always 

been exempt from campaign finance laws that infringe on the news media’s ability to exercise editorial discretion. Publishers cannot be stopped from 

publishing books endorsing candidates before an 

election, as the government contended, if Congress so 

deems. To do so would violate the First Amendment 

and the spirit of freedom in political discourse 

through which this country was established. 

III. The constitutionally compelled media exemption must be defined based on the intent of the entity to gather and disseminate news. 

 The media exemption must be defined broadly 

by this Court in order to prevent future regulation of 

the media. This Court should craft the press exemption based on the intent of the news organization to 

gather and disseminate news to the public, rather 

than a mere description of its mode of transmission. 

 In Austin and McConnell, the Court barely 

touched on the media exemption. In Austin, the majority briefly recognized that the institutional press 

should be exempted from campaign finance restrictions because “a valid distinction thus exists between 

corporations that are part of the media industry and 

other corporations that are not involved in the regular business of imparting news to the public.” Austin, 

494 U.S. at 669. In McConnell, the majority did not 

touch on the exemption. Thus, in the wake of these 

cases, the test for what types of media entities may 

be regulated under the BCRA remains murky and 
11

unclear. See 151 Cong.Rec. H9478-01 (Nov. 2, 2005) 

(statement of Rep. Miller) (“When Congress passed 

the Bipartisan Campaign Finance Reform Act in 

2002, the law apparently was unclear on what impact it would have on political speech on the Internet.”). 

 The law is especially unclear because of the constantly evolving world of media. Before Austin and 

McConnell, and before many of the latest advancements in technology, it was relatively simple to define the media. Newspapers, magazines, and broadcast and cable newscasts were all considered journalism and were all easily granted an exemption from 

campaign finance regulation. See generally The 

Readers Digest Ass’n. v. Fed. Elections Comm’n., 509 

F.Supp. 1210 (S.D.N.Y. 1981); Fed. Elections Comm’n 

v. Phillips Publ’g., 517 F.Supp. 1308 (D.D.C. 1981). 

But as technological advancements change the mode 

in which news is transmitted, it is no longer so easy 

to discern who is a member of the news media and 

who is not. See generally Brief Amicus Curiae of Reporters Committee for Freedom of the Press, Citizens 

United v. Federal Election Comm’n, No. 08-205. And 

the distinction will be even murkier in the future as 

the practices, methods and modes of journalism continue to evolve. Thus, the media exemption must be 

broadened so as to include not only traditional institutional media corporations, but also organizations 

like Citizens United that are distributing pertinent 

political news to the public. 

 As Justice Scalia foreshadowed in his dissent in 

Austin, the majority opinion left the door open for 

regulation of the press. 
12

Members of the institutional press, despite the Court's approval of their illogical exemption from the Michigan law, 

will find little reason for comfort in today's decision. The theory of New Corruption it espouses is a dagger at their 

throats. The Court today holds merely 

that media corporations may be excluded from the Michigan law, not that 

they must be. 

Austin, 494 U.S. at 691. 

 

 Without a clearly enunciated and broad standard announced by this Court, the likelihood of media regulation and censorship is high. As the government stated during oral arguments, McConnell

and Austin allow the FEC to impose campaign finance regulations on a variety of media organizations, including book authors. Supra Part I. Amicus

urges the Court to clarify the standard that has 

emerged after Austin and McConnell and to adopt a 

broadly defined standard that exempts entities that 

have the intent to gather and disseminate news, 

commentary and other information. 

 Broadening the standard would help preserve 

valuable public debate about elections and campaigns. The news media is exempted from campaign 

finance regulation in order to preserve its critically 

important role in covering elections. The exemption 

exists, not for the journalists themselves, but so that 

the public has access to and can participate in important political discussions. See generally Mills, 384 U.S. 
13

214. Broadening the exemption to include not just 

traditional press organizations but also nontraditional news organizations and information 

gatherers furthers the goals of the original intent of 

the media exemption. As the FEC recognized in response to a complaint that ABC, CBS, NBC, The New 

York Times, The Washington Post and the Los Angeles Times were making illegal corporate campaign 

contributions because of their commentary about political candidates, the media exemption allows the 

press to continue to serve the important role of election coverage. 

It is clearly a part of the normal press 

function to attend to the competing 

claims of parties, campaigns and interest groups and to choose which to feature, investigate or address in news, 

editorial and opinion coverage of political campaigns. The question of whether 

a news organization may have credulously or recklessly accepted and reported the claims of one political party 

or candidate is the type of inquiry which 

the courts have held to be foreclosed by 

the [Federal Election Campaign Act]’s 

media exemption. 

In re ABC, CBS, NBC, New York Times, Los Angeles 

Times and Washington Post, et al. Matter Under 

Review 4929, 5006, 5090 and 5117 at 4 (Fed. 

Elections Comm’n Dec. 20, 2000) (available at

http://eqs.sdrdc.com/eqsdocs/000011BC.pdf). 

When it is clear that the entity is a traditional 

media organization, the Court should continue to ap-
14

ply the media exemption as it historically has. But, 

when there is a question about whether or not the 

entity is a news organization, the Court should look 

to the function of organization and its intent to distribute news to the public. See generally Richard Hasen, Lessons from the clash between campaign finance laws and the blogosphere, 11 NEXUS 23 (2006). 

 In a related area of law, federal courts have already adopted an intent-based functional definition 

in determining what types of entities are news organizations. When determining whether to apply a 

reporter’s privilege to a non-traditional news gatherer, courts have adopted a test that applies a privilege to those entities that can show they had “the intent to use material – sought, gathered or received – 

to disseminate information to the public and that 

such intent existed at the inception of the newsgathering process.” von Bulow v. von Bulow, 811 F.2d 

136, 144-45 (2d Cir. 1987). In von Bulow, the court 

refused to apply a reporter’s privilege because a 

woman who said she was an author did not have the 

intent to gather news and disseminate it to the public from the beginning. Id.

 The same test has been adopted in other circuits. See Cusumano v. Microsoft Corp., 162 F.3d 708 

(1st Cir. 1998) (authors were independent and had 

the intent to gather and disseminate news to the 

public and could avail themselves of a reporter’s privilege); In re Madden, 151 F.3d 125 (3d Cir. 1998); 

Shoen v. Shoen, 5 F.3d 1289 (9th Cir. 1993). 

 

 In these cases, the courts have recognized that 

there is a line between those types of organizations 
15

and individuals who are legitimately acting as the 

press and those who are not. When there is no question about whether an entity is a news organization, 

courts do not apply this test. But when it is unclear 

whether the privilege should apply, this test helps 

courts to determine if the organization or journalist 

can invoke the same constitutional protections as the 

traditional press. Under this test, only those people 

and organizations who are independent and who 

have the intent to disseminate news to the public can 

avail themselves of constitutional protection. 

 Similarly, the reasoning applied in these cases 

is appropriate in the campaign finance context. As 

mentioned above, the intent-based function need only 

come into play when there is a question whether the 

entity is a media organization. If the Court applies a 

similar test, that exempts all organizations which 

are independent from political parties and which 

have the intent to disseminate news to the public, 

the Court can ensure that all legitimate press entities are constitutionally exempt from regulation and 

censorship. 

 In the reporter’s privilege context, this is a practical and workable test that draws a distinct line. It 

could serve the same purpose in the campaign finance context as well. It would also serve the government’s interest in regulating campaign activities 

so as to avoid the appearance of corruption, while 

also preserving the First Amendment right to discuss 

and debate matters of political concern. It is not a 

strict standard and will not undermine the important 

policies and concerns behind campaign finance regulations. By looking at the intent of the organization 
16

to disseminate news, a standard such as this will further important debate and discussion about elections. Also, by exempting organizations which are 

independent of any political party, this standard will 

allow the FEC to continue to regulate true campaign 

speech. 

 The press plays an important role in covering 

campaigns and elections, and it has played that role 

since this country was founded. It is vital that this 

Court does not step on that constitutionally protected 

role by censoring the media based on its content or 

mode of distribution. “It is difficult to imagine an assertion more contrary to the First Amendment than 

the claim that the FEC, a federal agency, has the authority to control the news media’s choice of formats, 

hosts, commentators and editorial policies in addressing public policy issues.”4 Amicus thus urges 

this court to adopt a broadly-defined intent based 

test that will exempt press organizations that are 

disseminating news to the public. A broad test will 

preserve the media’s ability to provide independent 

coverage of elections and campaigns. 

 

                                                           

4 In the Matter of Robert K. Dornan, et. al, Matter Under 

Review 4689 at 6 (additional statement of Comm’r Mason, 

Fed. Elections Comm’n Feb. 14, 2000) (available at

http://eqs.sdrdc.com/eqsdocs/000038E2.pdf) (involving complaints about a congressman serving as a guest host for radio 

talk shows).
17

CONCLUSION 

 The Court should take this opportunity to make 

clear that the press, broadly defined by its intent to 

gather and disseminate information, must be exempt 

from campaign finance regulations if the statutes are 

to survive a First Amendment review. Such a ruling 

reinforces the early holdings of this Court with regard to campaign finance regulation and would protect the interests of the press as it existed in 1789, as 

it existed in the 20th century, and as it exists now. 

Whatever the aims of campaign finance regulations 

and statutes, they must be aligned with the protections the First Amendment provides for the press. A 

free, robust, and invigorated news media — one that 

is not afraid its speech will fall under the specter of 

government regulation — furthers the democratic 

goals of campaign finance reform and should be protected as the Framers intended when the First 

Amendment was adopted. 
18

Respectfully submitted, 

Lucy A. Dalglish 

 Counsel of Record 

Gregg P. Leslie 

John Rory Eastburg 

Hannah Bergman 

Samantha Fredrickson 

The Reporters Committee 

 for Freedom of the Press 

1101 Wilson Blvd., Ste. 1100 

Arlington, VA 22209-2211 

(703) 807-2100 

July 24, 2009