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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | 325 7TH STREET, NW, #1100 |
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City | WASHINGTON |
State | DC |
Zip Code | 20004 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 28468-12
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6. House ID# 310750000
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TYPE OF REPORT | 8. Year | 2009 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
10. Check if this is a Termination Report | Termination Date | |
11. No Lobbying Issue Activity |
INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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12. Lobbying | 13. Organizations | ||||||||
INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
Signature | Digitally Signed By: Mallory Duncan, Senior Vice President, General Counsel |
Date | 07/20/2009 |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code APP
16. Specific lobbying issues
H.R. 471 to amend the Trade Act of 1974 to provide for a limitation on presidential discretion with respect to actions to address market disruption communication of opposition; H.R. 496 to amend U.S. trade laws to restore rights under trade-remedy laws and other purposes communication of retail industry views; H.R. 499 to amend title VII of the Tariff Act of 1930 to provide that the provisions relating to countervailing duties apply to non-market economy countries communication of retail industry views;
H.R. 1105 making omnibus appropriations for the fiscal year ending September 30, 2009, communication in opposition to provision calling for monitoring of apparel imports from China and Vietnam; H.R. 1318/S. 496 to provide duty-free treatment for certain goods from designated reconstruction opportunity zones in Afghanistan and Pakistan communication of retail industry views; Requiring adjustments to antidumping margins to offset currency misalignment communication of opposition; Re-imposition of zeroing to calculate antidumping margins communication of opposition; Re-imposition of monitoring programs against apparel imports from China and Vietnam communication of opposition; Re-imposition of the Continued Dumping and Subsidy Offset Act communication of opposition; China trade and economic policy communication of retail industry views; China currency communication of retail industry views; China subsidies communication of retail industry views; Re-imposition of quotas on apparel imports from China communication of opposition; Free Trade Agreements communication of retail industry views; Andean Trade Preferences Program reauthorization communication in support; Trade preferences reform communication of retail industry views re Generalized System of Preferences, Andean Trade Preferences, African Growth and Opportunity Act, Caribbean Basin Initiative, and Haitian preferences (HOPE); Implementation of changes to the Lacey Act included in the 2008 Farm Bill communication of retail industry views; Doha Round of Multilateral Trade Negotiations communications re retail industry priorities; DR-CAFTA implementation communication of retail industry views;H.R. 3039 - Supporting a bill to provide preferential duty treatment to certain apparel articles of the Philippines.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, U.S. Customs & Border Protection, U.S. Trade Representative (USTR), Intl Trade Administration (ITA), Commerce - Dept of (DOC), State - Dept of (DOS), Homeland Security - Dept of (DHS), White House Office, U.S. International Trade Commission (ITC), Treasury - Dept of,
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Erik |
Autor |
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Steve |
Pfister |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code BAN
16. Specific lobbying issues
S. 414, Credit Card Accountability Responsibility and Disclosure Act of 2009, credit card fees & disclosures, gift cards, Durbin interchange amendment; H.R. 627, Credit Cardholders' Bill of Rights Act of 2009, all provisions; credit card fees; S.710, A bill to prohibit unfair or deceptive acts or practices relating to gift certificates, store gift cards, and other general-use prepaid cards, and for other purposes; Treasury Dept. proposals on regulatory reform
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Reserve System, Office of the Comptroller of the Currency (OCC), Treasury - Dept of
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Elizabeth |
Oesterle |
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Steve |
Pfister |
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Maureen |
Riehl |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code CSP
16. Specific lobbying issues
Red Flags Rule; gift cards; H.R. 579 to amend the Federal Food, Drug, and Cosmetic Act to improve the safety of food, drugs, devices, and cosmetics in the global market communication of retail industry views; H.R. 875 to establish the Food Safety Administration within the Department of Health and Human Services to protect the public health by preventing food-borne illness communication of retail industry views;
H.R. 1298 to amend the Federal Food, Drug and Cosmetic Act with respect to the importation of prescription drugs communication of retail industry views; S. 510 to amend the Federal Food, Drug, and Cosmetic Act with respect to the safety of the food supply communication of retail industry views; Implementation of the Consumer Product Safety Improvement Act - concerns with the implementation of specific sections of the CPSIA including retroactivity, general conformity certificates, tracking labels and component testing; H.R. 1398/S. 558, Labeling Education and Nutrition Act, provisions requiring chain restaurants to provide nutritional information on menus and menu boards, provisions on premption, liability protection, and nutrition disclosure; RFID technology - privacy issues; H.R.2749, to amend the Federal Food, Drug, and Cosmetic Act to improve the safety of food in the global market, and for other purposes, provisions relating to increased penalties, reporting requirements and traceability requirements;
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Consumer Product Safety Commission (CPSC), Commerce - Dept of (DOC), U.S. Customs & Border Protection, Federal Trade Commission (FTC), Agriculture - Dept of (USDA), Food & Drug Administration (FDA)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Jonathan |
Gold |
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Erik |
Autor |
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M. Scott |
Vinson |
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Steve |
Pfister |
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Elizabeth |
Oesterle |
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Maureen |
Riehl |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code HCR
16. Specific lobbying issues
Health care reform; S. 979, Small Business Health Options Program Act of 2009, A bill to amend the Public Health Service Act to establish a nationwide health insurance purchasing pool for small businesses and the self-employed that would offer a choice of private health plans and make health coverage more affordable, predictable, and accessible; S. 391, Healthy Americans Act, A bill to provide affordable, guaranteed private health coverage that will make Americans healthier and can never be taken away.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Labor - Dept of (DOL), Health & Human Services - Dept of (HHS), White House Office
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
E. Neil |
Trautwein |
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Steve |
Pfister |
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Rachelle |
Bernstein |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code HOM
16. Specific lobbying issues
PCI data security standards; Implementation of the Importer Security Filing as required by the SAFE Port Act by U.S. Customs and Border Protection. Opposition to 100% scanning requirements on maritime cargo under the 9/11 implementation Act; Immigration reform - urge DHS to work with business on worksite enforcement of immigration law
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Commerce - Dept of (DOC), Homeland Security - Dept of (DHS), U.S. Customs & Border Protection
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Jonathan |
Gold |
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Erik |
Autor |
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Elizabeth |
Oesterle |
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M. Scott |
Vinson |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code LAW
16. Specific lobbying issues
H.R. 1173, Organized Retail Crime Act of 2009, support the bill; S. 470, Combating Organized Retail Crime Act of 2009, support the bill; H.R. 1166, E-fencing Enforcement Act of 2009, support the bill, provisions on sale of stolen merchandise online.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Justice - Dept of (DOJ),
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Elizabeth |
Oesterle |
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Maureen |
Riehl |
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Jonathan |
Gold |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code LBR
16. Specific lobbying issues
interchange fees; H.R. 1409/S. 560, Employee Free Choice Act of 2009, all provisions relating to elimination of secret ballot elections and binding arbitration; H.R. 1020, Arbitration Fairness Act of 2009, all provisions; H.R. 12, Paycheck Fairness Act, all provisions; health care reform; ERISA; pension valuation; H.R. 2460/S. 1152 Healthy Families Act, To allow Americans to earn paid sick time so that they can address their own health needs and the health needs of their families, all provisions;
H.R.1274, Working Families Flexibility Act, To permit employees to request, and to ensure employers consider requests for, flexible work terms and conditions, and for other purposes, all provisions; H.R.2067, Protecting America's Workers Act, To amend the Occupational Safety and Health Act of 1970 to expand coverage under the Act, to increase protections for whistleblowers, to increase penalties for certain violators, and for other purposes, all provisions.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE,
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Robert |
Green |
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M. Scott |
Vinson |
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Steve |
Pfister |
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E. Neil |
Trautwein |
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Elizabeth |
Oesterle |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TAX
16. Specific lobbying issues
Urging Congress to increase investment in second generation biofuels & restructure existing subsidies; urging Congress to oppose e-Verify mandates in stimulus bill; Affordable Food and Fuel for America Act, a bill to reduce and eliminate the tax credit for alcohol fuel mixtures and the tariff on imported ethanol; National Sales Tax Holiday; LIFO repeal; LCM repeal; H.R. 1083, Business Activity Tax Simplification Act of 2009, all provisions;
retail depreciation, net operating loss carryback - H.R.2452 & S. 823, A bill to amend the Internal Revenue Code of 1986 to allow a 5-year carryback of operating losses, and for other purposes; Streamlined Sales Tax; H.R.690/S. 144, To amend the Internal Revenue Code of 1986 to remove cell phones from listed property under section 280F, all provisions; corporate tax reform; Value Added Tax (VAT); Urging U.S. Senate to oppose any form of tax on carbonated or sweetened beverages (no bill); Urging Treasury Department to allow companies to make new interest rate elections for pension plan years beginning in 2010, and to make pension funding regulations effective only after 12/31/09; Health care reform
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Internal Revenue Service (IRS), Treasury - Dept of,
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Rachelle |
Bernstein |
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M. Scott |
Vinson |
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Steve |
Pfister |
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Maureen |
Riehl |
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E. Neil |
Trautwein |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TRA
16. Specific lobbying issues
H.R. 947, Our Nation's Trade, Infrastructure, Mobility, and Efficiency Act of 2009, To direct the Secretary of Transportation to establish and collect a fee based on the fair market value of articles imported into the United States and articles exported from the United States in commerce and to use amounts collected from the fee to make grants to carry out certain transportation projects in the transportation trade corridors for which the fee is collected, and for other purposes, express opposition to legislation
Reauthorization of the highway bill - oppose the inclusion of user fees to pay for freight transporation that are not fair and equitable, support creation of a freight sub-account in the highway trust fund; H.R. 1799, Safe and Efficient Transportation Act of 2009, support the bill; Energy Independence and Security Act of 2007, urging Congress to freeze renewable fuel standard mandates in the resulting law; Opposing efforts to increase the current cap on the amount of ethanol permitted to be blended into gasoline; requested extension of time to comment on EPA Docket No. EPA-HQ-OAR-2009-0211; FRL-8894-5 "Notice of Receipt of a Clean AIr Act Waiver Application to Increase the Allowable Ethanol Content of Gasoline to 15%, Request for Comment"; H.R. 2355, To establish a National Goods Movement Improvement Fund to provide funding for infrastructure projects that will improve the movement of goods, mitigate environmental damage caused by the movement of goods, and enhance the security of transported goods, express opposition to legislation.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Transportation - Dept of (DOT), Homeland Security - Dept of (DHS), Energy - Dept of, Agriculture - Dept of (USDA), White House Office, Environmental Protection Agency (EPA)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Jonathan |
Gold |
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Erik |
Autor |
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Steve |
Pfister |
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M. Scott |
Vinson |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TRD
16. Specific lobbying issues
H.R. 188 to lift the trade embargo on Cuba communication in support; H.R. 471 to amend the Trade Act of 1974 to provide for a limitation on presidential discretion with respect to actions to address market disruption communication of opposition; H.R. 496 to amend U.S. trade laws to restore rights under trade-remedy laws and other purposes communication of retail industry views;
H.R. 499 to amend title VII of the Tariff Act of 1930 to provide that the provisions relating to countervailing duties apply to non-market economy countries communication of retail industry views; H.R. 947 to direct the secretary of transportation to establish and collect a fee based on the fair market value of articles imported into the United States and use the amounts collected to make grants to carry out certain transportation projects communication of retail industry views; H.R. 1105 making omnibus appropriations for the fiscal year ending September 30, 2009, communication in opposition to provision calling for monitoring of apparel imports from China and Vietnam; H.R. 1318/S. 496 to provide duty-free treatment for certain goods from designated reconstruction opportunity zones in Afghanistan and Pakistan communication of retail industry views; S. 730 to amend the U.S. Harmonized Tariff Schedule to modify the tariffs on certain footwear communication in support; H.R. 1530 to lift the trade embargo on Cuba communication in support; Requiring adjustments to antidumping margins to offset currency misalignment communication of opposition; Re-imposition of zeroing to calculate antidumping margins communication of opposition; Re-imposition of monitoring programs against apparel imports from China and Vietnam communication of opposition; Re-imposition of the Continued Dumping and Subsidy Offset Act communication of opposition; China trade and economic policy communication of retail industry views; China currency communication of retail industry views; China subsidies communication of retail industry views; Re-imposition of quotas on apparel imports from China communication of opposition; Free Trade Agreements communication of retail industry views; Generalized System of Preferences reauthorization communication in support; Andean Trade Preferences Program reauthorization communication in support; Trade preferences reform communication of retail industry views re Generalized System of Preferences, Andean Trade Preferences, African Growth and Opportunity Act, Caribbean Basin Initiative, and Haitian preferences (HOPE); Implementation of changes to the Lacey Act included in the 2008 Farm Bill communication of retail industry views; Trade Promotion Authority communication re retail industry views; Trade Adjustment Assistance communication re retail industry views; Doha Round of Multilateral Trade Negotiations communications re retail industry priorities; DR-CAFTA implementation communication of retail industry views; Reauthorization of U.S. Customs and Border Protection - support reauthoriztion of the agency with reemphasis on balancing the mission of trade facilitation and security; Affordable Food and Fuel for America Act, a bill to reduce and eliminate the tax credit for alcohol fuel mixtures and the tariff on imported ethanol;H.R. 2272 - Supporting a bill to lift trade embargo on Cuba; H.R. 2939 - Opposing a to bill requiring review and renegotiation of existing trade agreements, and limitation on Presidential trade negotiating authority; H.R. 2927 - Opposing a bill to authorize imposing a tax on imports from any country that employs indirect taxes and rebates of such taxes upon export; S. 1027/H.R.2378- Opposing bills to amend trade laws so that exchange rate misalignment is actionable under U.S. antidumping and countervailing duty procedures;
S. 1141 - Supporting a bill to extend certain trade preferences to certain least-developed countries; S.J.Res. 17/H.J.Res. 56 - Supporting a bill approving review of impact restrictions on products from Burma.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Homeland Security - Dept of (DHS), Commerce - Dept of (DOC), Intl Trade Administration (ITA), Transportation - Dept of (DOT), U.S. Customs & Border Protection, U.S. Trade Representative (USTR), Treasury - Dept of, Natl Security Council (NSC), Environmental Protection Agency (EPA), White House Office, State - Dept of (DOS), Agriculture - Dept of (USDA)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Erik |
Autor |
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Jonathan |
Gold |
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Steve |
Pfister |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code ADV
16. Specific lobbying issues
online and behavioral advertising
17. House(s) of Congress and Federal agencies Check if None
Federal Trade Commission (FTC), U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Elizabeth |
Oesterle |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code ENV
16. Specific lobbying issues
Urging Administration to avoid increasing cap on amount of ethanol permitted to be blended into gasoline until testing to ensure environmental safety
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Energy - Dept of, Agriculture - Dept of (USDA), Environmental Protection Agency (EPA), White House Office
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
M. Scott |
Vinson |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code IMM
16. Specific lobbying issues
Immigration reform (no bill) - urging Congress to pass comprehensive immigration reform to include a temporary worker program and an earned legalization program
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
M. Scott |
Vinson |
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Elizabeth |
Oesterle |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code CPT
16. Specific lobbying issues
H.R.2196, Design Piracy Prohibition Act, To amend title 17, United States Code, to extend protection to fashion design, and for other purposes.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Elizabeth |
Oesterle |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address: http://www.nrf.com/LD2Filing
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
1 | 3 | 5 |
2 | 4 | 6 |
FOREIGN ENTITIES
27. Add the following foreign entities:
Name | Address |
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
1 | 5 | 9 |
2 | 6 | 10 |
3 | 7 | 11 |
4 | 8 | 12 |