Legal Brief
CEI et al. Opening Brief in CEI v. EPA
CERTIFICATE AS TO PARTIES, RULINGS, AND RELATED CASES Pursuant to Circuit Rule 28, petitioners American Fuel & Petrochemical Manufacturers, Clean Fuels Development Coalition, Competitive Enterprise …
Letters
Coalition Letter in Opposition to Credit Card Regulation Amendments
Dear Member of Congress: We, the undersigned organizations, oppose the inaccurately named Credit Card Competition Act of 2022 (S. 4674) as filed as Senate amendment 6201 to the…
Comment
Comments to DOE: Energy Conservation Standards Program
Comments Submitted by the Competitive Enterprise Institute, Consumers’ Research, Center for the American Experiment, JunkScience.com, Project 21, Caesar Rodney Institute, Rio Grande Foundation, Committee for…
Comment
Comments Regarding Energy Conservation Standards for Consumer Furnaces
The undersigned free market and consumer organizations have a longstanding interest in bringing to light the deleterious consequences of federal regulations, which are often neglected…
Letters
Coalition Letter Opposing Freight Rail Shipping Fair Market Act
Dear Member of Congress: We, the undersigned individuals and organizations, oppose the inaccurately named Freight Rail Shipping Fair Market Act. It will cause significant harm…
Comment
Comments to the Federal Trade Commission Regarding the Motor Vehicle Dealers Trade Regulation Rule
Comment Submitted: September 12, 2022 Docket No. FTC-2022-0046-0001 On behalf of the Competitive Enterprise Institute (CEI), I respectfully submit the following comments in response to…
Comment
Coalition Comments on Proposed Determination to Prohibit Disposal Sites in Pebble Deposit Area
Comments of the Competitive Enterprise Institute, 60 Plus Association, Heritage Action for America, Freedom Works, Project 21, Reaching America, American Lands Council, American Business…
Letters
CEI Joins Coalition Opposing Credit Card Competition Act
Dear Member of Congress: We, the undersigned organizations, oppose the inaccurately named Credit Card Competition Act of 2022 (S. 4674). The bill is…
Comment
CEI Comment on SEC ‘Investment Company Names’ Rule
Introduction The Competitive Enterprise Institute (CEI) is pleased to have the opportunity to comment on the Securities and Exchange Commission’s (SEC) current notice of proposed…
Comment
CEI Comments to EPA Regarding Environmental Protection Agency, Clean Water Act Section 401 Water Quality Certification Improvement Rule, Proposed Rule
INTRODUCTION The Competitive Enterprise Institute is a policy and analysis organization committed to advancing the principles of free markets and limited government. We are particularly…
Letters
Coalition Urges Congress to Reauthorize FCC’s Spectrum Authority
We, the undersigned, write this letter to express our support for H.R. 7624, the Extending America’s Spectrum Auction Leadership Act of 2022, which would extend…
Letters
CEI Leads Coalition Opposing the Confirmation of Joseph Goffman as EPA’s Assistant Administrator for Air and Radiation
Dear Chairman Carper, Ranking Member Capito, and Members of the Senate Committee on Environment and Public Works: The undersigned organizations and individuals write to express…
Letters
CEI Joins Coalition Letter on Proposed Antitrust Bills that Would Harm Consumers
We, the undersigned economic, legal, and public policy experts, write to express concern overlegislative and executive branch proposals aimed at dramatically expanding government antitrustand competition…
Legal Brief
CEI Files Brief of Amici Curiae in Louisiana v. Department of Energy
CERTIFICATE OF INTERESTED PARTIES Louisiana v. DOE, Fifth Circuit Case No. 22-60146. The undersigned counsel of record certifies that the following listed persons…
Comment
CEI Comments on FDA Proposed Menthol Standard
Center for Tobacco U.S. Food and Drug Administration 10903 New Hampshire Ave Silver Spring, MD 20993 Re: Tobacco Product Standard for Menthol in Cigarettes Docket…
Legal Brief
Brief of Amicus Curiae in West Virginia v. EPA
INTEREST OF AMICUS CURIAE1 The Competitive Enterprise Institute (“CEI”) is a nonprofit 501(c)(3) organization incorporated and headquartered in Washington, D.C., dedicated to promoting the…
Testimony
CEI Expert Testimony at Legislative Hearing to Strengthen Energy Infrastructure, Efficiency, and Financing
House Subcommittee on Energy 2123 Rayburn House Office Building June 22, 2022 Legislative Hearing to Strengthen Energy Infrastructure, Efficiency, and Financing Remarks of Ben…
Comment
CEI Comments on Proposed SEC Rule: Enhancement and Standardization of Climate-Related Disclosures for Investors
Comments submitted by the Competitive Enterprise Institute et al. June 17, 2022 In the matter of the proposed rule “The Enhancement and Standardization of Climate-Related…
Letters
Coalition Opposes SEC’s Proposed Rule: Enhancement and Standardization of Climate-Related Disclosures for Investor
Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street NE Washington, DC 20549-0609 The undersigned individuals and organizations strongly oppose the Securities and Exchange…
Comment
CEI Comments to SEC on Proposed Climate-Related Disclosures Rule
Comment letter submitted by the Competitive Enterprise Institute, et al. June 2022 In the matter of the proposed rule “The Enhancement and Standardization of Climate-Related…
Comment
CEI Comments to Senate Banking Committee on JOBS Act 4.0
Senator Pat ToomeyRanking Member, Senate Banking Committee455 Dirksen Senate Office BuildingWashington, D.C 20510Dear Senator Toomey,On behalf of the Competitive Enterprise Institute (CEI), it is our…
Comment
CEI Comments to the National Telecommunications and Information Administration Regarding Report on Competition in the Mobile App Ecosystem
Alex Reinauer, Research Fellow, Competitive Enterprise Institute Comment Period Closes: May 23, 2022 Comment Submitted: May 23, 2022 Docket No. NTIA-2022-0001 On behalf of the…
Comment
CEI Letter Opposing the Department of Labor’s Proposed Changes to the Davis-Bacon Act
Via Regulations.Gov Hon. Marty Walsh Secretary of Labor United States Department of Labor 200 Constitution Ave NW Washington, DC 20210 Updating the Davis-Bacon and Related…
Letters
36 Organizations Sign Coalition Letter Condemning Menthol Prohibition Proposal
We, the undersigned 36 organizations, representing millions of taxpayers and consumers across the United States, strongly urge you to reject any proposed ban on menthol…
Letters
CEI Leads Coalition Letter on Kigali Amendment to the Montreal Protocol on Substances That Deplete the Ozone Layer
Comment
CEI Comments to Federal Energy Regulatory Commission: Docket No. PL21-3-000
Federal Energy Regulatory Commission, Order on Draft Policy Statements, March 24, 2022. Docket No. PL21-3-000 Comments submitted by Marlo Lewis, Patrick Michaels, and Kevin Dayaratna.
Comment
Joint Comments on the Securities and Exchange Commission’s Incursion into Private Markets.
RE: Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews (SEC Release Nos. IA-5955; File No. S7-03-22) Dear Ms. Countryman: The undersigned organizations appreciate…
Legal Brief
Brief of Amicus Curiae – Case No. 22-60008
UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT Case No. 22-60008 Consumers’ Research, et al., v. Federal Communications Commission, et al., Brief of…
Comment
Comments to the Consumer Financial Protection Bureau on its Request for Information on “Junk Fees”
Dear Director Chopra: On behalf of the Competitive Enterprise Institute (CEI), I respectfully submit the following comments in response to the Consumer Financial Protection Bureau’s…
Letters
CEI Joins Coalition Letter on FDA Ban on Synthetic Nicotine
Dear Commissioner Califf, We write to you in opposition to a new regulation signed into law by Congress that will effectively ban vapor products that…
Letters
CEI Joins Coalition Opposing Weaponizing Antitrust Law
Dear Senator, Despite full control of Congress and President Joe Biden in the Oval Office, the Democratic Party finds many of its top legislative priorities…
Comment
Comments to the Federal Trade Commission Regarding Forthcoming Merger Guideline Revisions
Comment Period Closes: April 21, 2022 Comment Submitted: April 3, 2022 Docket No. FTC-2022-0003-0001 On behalf of the Competitive Enterprise Institute (CEI), we respectfully submit…
Testimony
Testimony on House Bill No. 2525, as Amended (Forfeiture Reform)
House Bill No. 2525, as amended, will improve Tennessee’s justice system. I thank the Criminal Justice Subcommittee for allowing me to express my views about…
Letters
CEI Joins Coalition Letter on Durbin Amendment
Dear Chairman Brown, Ranking Member Toomey, Chairwoman Waters, and Ranking Member McHenry: The undersigned organizations write in opposition to any legislation that would expand or…
Comment
CEI Comments to the FCC: FCC-21-127
Introduction On behalf of the Competitive Enterprise Institute (CEI), I respectfully submit these comments in response to the Federal Communications Commission’s (FCC) notice of inquiry…
Letters
CEI Joins Coalition Opposing March-In over Drug Prices
Dear Secretary Becerra, On behalf of millions of Americans across the country, we urge you to ignore calls and petitions asking you to deliberately twist…
Comment
Comments on Application Of The National Railroad Passenger Corporation Under 49 U.S.C. § 24308(E)
On behalf of the Competitive Enterprise Institute (CEI), I respectfully submit this comment letter for the Board’s consideration in the FD 36496 proceeding. Founded in…
Comment
CEI Comments on Office of Science and Technology Policy’s request for comments on updating the National Artificial Intelligence Research and Development Strategic Plan
Introduction On behalf of the Competitive Enterprise Institute (CEI), I respectfully submit these comments in response to the Office of Science and Technology Policy’s request…
Letters
CEI Joins Coalition Urging Congress to End Ban on DC Marijuana Sales
Dear Members of Congress, As you and your colleagues in Congress continue to finalize funding levels and bill language in the FY22 appropriations bill, the…
Letters
CEI Joins Coalition Letter Opposing Build Back Better Agenda
President Joe Biden is preparing to deliver his State of the Union address and promote his Build Back Better agenda. The America First Policy Institute…
Letters
Coalition Letter Urging Congress to Reject Efforts to Impose Protectionist Barriers on Agricultural Imports
U.S. Senate Washington, DC, 20510 U.S. House of Representatives Washington, DC, 20515 Dear Senators and Representatives, We, the undersigned organizations representing millions of taxpayers and…
Letters
CEI Leads Coalition Opposing Freight Rail Reciprocal Switching
Dear Honorable Board Members, We, the undersigned, maintain a deep interest in free markets and the benefits they provide to the American consumer. We write…
Letters
CEI and Other Organizations Oppose the Open App Markets Act
Dear Senator, On behalf of the undersigned organizations – representing millions of taxpayers, consumers, and free market advocates across the nation – we urge you…
Letters
Coalition Letter Opposing Sarah Bloom Raskin’s Nomination to Federal Reserve
Dear Chairman Brown and Ranking Member Toomey, As public policy groups who fight for free markets, sound science, and affordable energy, we write in opposition…
Letters
CEI and Other Organizations Urge Support for Pro-Growth ALIGN Act
Dear Chair Wyden, Chair Neal, Ranking Member Crapo, Ranking Member Brady, and Members of the Senate Committee on Finance and House Committee on Ways and…
Comment
Coalition Opposes Proposed DOE Lightbulb Rule
Re: Docket Number EERE-BT-STD-0005: Department of Energy: Energy Conservation Program: Backstop Requirement for General Service Lamps: Notification of Proposed Rule: 86 FR 70,755 (December…
Comment
CEI Comments on Federal Energy Regulatory Commission Consideration of Greenhouse Gas Mitigation under Sections 3 and 7 of the Natural Gas Act.
Docket No. PL21-3-000 Comments submitted by Patrick Michaels, Kevin Dayaratna, and Marlo Lewis.[1] Thank you for the opportunity to respond to the questions posed…
Comment
Comments to Consumer Financial Protection Bureau on Small Business Lending Data Collection By Race and Gender
Dear Mr. Chopra, On behalf of the Competitive Enterprise Institute (CEI), I respectfully submit the following comments in response to the Consumer Financial Protection Bureau’s…
Comment
Comment on Proposed Rule “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights”
Assistant Secretary Khawar: Thank you for the opportunity to comment on the Employee Benefits Security Administration’s recently proposed rule on the Investment Duties regulation under…
Letters
CEI Joins NTU-Led Coalition Warns of BBB’s Impact on Drug Competition
Dear Senators and Representatives: On behalf of the undersigned organizations — taxpayer, consumer, and free market advocates from across the country — we write with…
Letters
Coalition Letter to OIRA Re: Request for OIRA to Resolve Interagency Disagreement Concerning IQA Implementation About Medical Marijuana
The Competitive Enterprise Institute (CEI) requests that OIRA resolve a dispute between two different agencies concerning responsibility for ensuring compliance with the Information Quality Act.
Comment
Letter to OIRA Re: Request for OIRA to Resolve Interagency Disagreement Concerning IQA Implementation About Medical Marijuana
The Competitive Enterprise Institute (CEI) requests that OIRA resolve a dispute between two different agencies concerning responsibility for ensuring compliance with the Information Quality Act.
Comment
CEI Comments on Biden Administration Proposal to Revise National Environmental Policy Act (NEPA) Implementing Regulations.
Comments of the Competitive Enterprise Institute (CEI) Thank you for the opportunity to comment on the Council on Environmental Quality’s (CEQ) proposal to modify certain…
Letters
CEI Joins Letter Opposing Nomination of Saule Omarova for Comptroller of the Currency
November 5, 2021 The Honorable Sherrod Brown Chairman Senate Committee on Banking, Housing, and Urban Affairs 534 Dirksen Senate Office Building Washington, D.C.
Letters
CEI Joins ATR Led Drug Price Control Coalition Letter
Dear Member of Congress: We write in opposition to the Democrat plan to impose price controls, a 95 percent excise tax, and inflation penalties on…
Letters
CEI Leads Coalition Letter Urging Senators to Vote Against Ratification of Kigali Amendment
November 17, 2021United States SenateUnited States CapitolWashington, DC 20510 Dear Senator: The undersigned organizations strongly urge you to vote against ratification of the Kigali Amendment…
Comment
CEI Comments on the National Highway Traffic Safety Administration’s Proposed Fuel Economy Standards for Model Year 2024-2026 Passenger Cars and Light Trucks
Comments submitted by Patrick J. Michaels, Kevin Dayaratna, and Marlo Lewis.[1] Thank you for the opportunity to comment on the National Highway Traffic Safety…
Letters
CEI Joins Coalition Opposing the Wall Street Looting Act
Dear Senators Warren & Kennedy, We are writing to express our concern about the upcoming hearing in the Senate Banking Economic Policy Subcommittee titled “Protecting…
Letters
Coalition Letter to Senate re Tax Preparer Licensing
Dear Senator: We write to urge you to oppose all proposals, including H. R. 4184 and similar legislation that may be introduced in the Senate,…
Letters
CEI Joins Coalition Urging Senate Republicans to Reject Democrat Antitrust Trap
Dear Senator, Recent media reports have indicated that Senate Democrats are crafting a package of European-style antitrust regulation. Some left-wing politicians are attempting…
Letters
CEI Joins Coalition Letter Opposing IRS Financial Reporting Requirement
The undersigned organizations write in opposition to the proposed new reporting regime to have the IRS collect the account inflows and outflows for bank, loan,…
Comment
CEI Feedback on Clarifying Laws Around Cryptocurrency and Blockchain Technologies
Competitive Enterprise Institute 1310 L Street NW, 7th Floor Washington, DC 20005 U.S. Senate Committee on Banking, Housing, and Urban Affairs 534 Dirksen Senate Office…
Comment
CEI Comments on Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards Proposed Rule
Environmental Protection Agency, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards, Proposed Rule, 83 FR 43726 (August 10, 2021) Docket ID:…
Comment
CEI’s Devin Watkins Comments on DOE’s Dishwasher Rulemaking
Hello, my name is Devin Watkins from the Competitive Enterprise Institute. It was CEI’s petition for rulemaking that caused the Department of Energy to create…
Comment
Comments to DOE Regarding Water Use Limits For Showers
Docket Number EERE-2021-BT-STD-0016; Energy Conservation Program: Definition of Showerhead; Notice of Proposed Rulemaking And Public Meeting 86 FR 38,594 (July 22, 2021) Comments Submitted by…
Letters
CEI and Other Organizations Urge Biden Administration to Prioritize Free Trade Agreements
Dear President Biden, On behalf of the undersigned groups, we urge you to pursue free-trade agreements that enhance America’s freedom, prosperity, and competitiveness. The administration…
Comment
Comments to the CMA in re: Facebook/GIPHY merger
Submitted to the Inquiry via [email protected], 1 September 2021 Thank you for the opportunity to submit comments in the matter of the Competition and…
Letters
Congress Must Protect U.S. Employers by Passing the Save Local Business Act (H.R. 3185/S. 1636)
Dear Member of Congress, On behalf of the undersigned organizations and the millions of members, supporters and activists across America whom we collectively represent, we…
Letters
CEI Joins Coalition Letter : Re: Wyden-Lummis-Toomey Amendment to H.R. 3684
Dear Majority Leader Schumer and Minority Leader McConnell, The undersigned organizations—which include nonprofits, trade associations, and individual companies that participate in the United States’ vibrant…
Letters
CEI and Other Organizations Sign Coalition Letter Supporting the Wyden-Lummis-Toomey Amendment
Dear Majority Leader Schumer and Minority Leader McConnell, The undersigned organizations—which include nonprofits, trade associations, and individual companies that participate in the United States’ vibrant…
Letters
Coalition Letter of Opposition Interest Rate Cap
Dear Chairman Brown and Ranking Member Toomey, On behalf of our organizations and the millions of American individuals, families, and business owners we represent, we…
Testimony
Testimony of John Berlau Before the House Financial Services Committee, Subcommittee on Consumer Protection and Financial Institutions
Chairman Perlmutter, Ranking Member Luetkemeyer, and honorable members of this Subcommittee, thank you for this opportunity to present testimony on behalf of my organization, the…
Letters
Coalition Urges Fiscal Restraint on Infrastructure Package
Dear Representative: The undersigned organizations ask you to place common sense parameters on the next legislation to address our nation’s infrastructure. As our economy continues…
Comment
Comments to EPA Regarding the American Innovation and Manufacturing (AIM) Act
Docket No. EPA-HQ-OAR-2021-0044; Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program Under the American Innovation and Manufacturing Act; Proposed Rule 86 FR 27,150…
Comment
CEI Comments on SAFE 1 Rule – Docket ID No. EPA-HQ-OAR-2021-0257
Thank you for the opportunity to submit comments on the Environmental Protection Agency’s (EPA) reconsideration[1] of Part One of the Trump administration’s Safer Affordable…
Letters
CEI Joins Coalition Urging Lawmakers To Reject Frivolous Spending Request
Dear Chairs Klobuchar and Cicilline and Ranking Members Lee and Buck: We, the undersigned organizations, representing millions of taxpayers and consumers, urge you to reject…
Letters
CEI Joins Coalition Letter Opposing BRIDGE Act
Dear Senators, We, the undersigned organizations representing millions of taxpayers and consumers across the nation, ask you to oppose the BRIDGE Act as introduced by…
Letters
CEI Joins Coalition Urging D.C. City Council to Reject Prohibition of “Flavored” Tobacco Products
June 28, 2021The Council of the District of ColumbiaJohn A. Wilson Building1350 Pennsylvania Avenue, N.W.Washington, DC 20004Dear Chairman Mendelson and Councilmembers:The undersigned civil rights, civil…
Letters
CEI Joins Coalition Asking Congress to Oppose Any Increase in the Federal Minimum Wage
Dear Members of Congress, We, the undersigned organizations representing millions of Americans nationwide, write in blanket opposition to any increase in the federal minimum wage,…
Letters
CEI Leads Coalition Letter Opposing House Vote on Resolution to Overturn OCC “True Lender” Rule
View Full Document as PDF Dear Speaker Pelosi and Minority Leader McCarthy, As leaders of conservative and free-market groups who stand firm against…
Comment
Comments On OMB Technical Support Document on Social Cost of Carbon
View Full Document as PDF Office of Management and Budget Notice of Availability and Request for Comment on “Technical Support Document: Social Cost…
Letters
CEI Joins HJC Letter Opposing Cicilline Jayapal Bills
Dear Members of the House Judiciary Committee: At a time when voters are looking to Congress to address the country’s most pressing challenges, it seems…
Letters
CEI Joins TPA Led Coalition Calling for IRS Investigation
Dear Senator, On behalf of the undersigned organizations, representing taxpayers, consumers, and free market advocates across the nation, we write to urge you to launch…
Letters
25+ Conservative Groups and Activists Urge Congress to Reject Democrat Antitrust Power Grab
Dear Member of Congress: We urge you to reject the package of European-style over-regulation in the antitrust bills spearheaded by Rep. David Cicilline (D-R.I.) and…
Comment
Public Input on Climate Change Disclosures: Questions for Consideration
View Full Document as PDF Dear Commissioner Lee, Please find below comments from the Competitive Enterprise Institute (CEI) in response to selected questions…
Comment
Marlo Lewis Comment to the SEC on Climate Risk Disclosure
View Full Document as PDF Comments of the Competitive Enterprise Institute, Caesar Rodney Institute, Committee for a Constructive Tomorrow (CFACT), Energy and Environment…
Comment
Docket No. NHTSA-2021-0030 Marlo Lewis CEI free market groups 6-11-2021
View Full Document as PDF Comments of the Competitive Enterprise Institute, American Energy Alliance, Americans for Tax Reform, Freedom Works, Caesar Rodney Institute,…
Letters
CEI Joins Letter Urging Congress to Lift DC Rider Blocking Cannabis Regulation
Dear Members of Congress, On behalf of the undersigned criminal justice reform, liberty, and drug policy organizations, we write to urge you to remove the…
Letters
CEI Joins Coalition Letter Opposed to Repealing IDCs
Letters
CEI Joins Coalition Letter Opposing H.R. 3, the Lower Drug Costs Now Act
View Full Document as PDF Dear Member of Congress: We urge you to reject efforts to pass H.R. 3, the Lower Drug Costs…
Letters
CEI Joins Coalition Letter Opposing Federal Reserve Efforts That Expand the Durbin Amendment
Letters
CEI Joins Coalition Letter Regarding Wasteful RDOF Subsidies, Hamilton Place Strategies
Dear Ms. Dortch: The Commission adopted its Rural Digital Opportunity Fund (“RDOF”) order last year despite concerns that it would subsidize the construction and operation…
Letters
CEI Joins Coalition Letter Rejecting Drug Price Control Legislation
Dear Leader Schumer, Speaker Pelosi, Republican Leader McConnell, andMinority Leader McCarthy,We represent fiscal conservatives, free market advocates, and ordinaryAmericans concerned about confiscatory taxes on the…
Letters
CEI and Other Organizations Oppose the PRO Act
Dear Member of Congress, We are writing in opposition to the Protecting the Right to Organize (PRO) Act. The PRO Act, introduced by Rep. Bobby…
Letters
CEI and Other Organizations Sign Coalition Letter Condemning Menthol Prohibition Proposal
We, the undersigned organizations, representing millions of taxpayers and consumers across the united States, strongly urge you to reject any proposed ban on menthol flavored…
Comment
CEI Comments to Federal Energy Regulatory Commission Regarding Creation of the Office of Public Participation
View Full Document as PDF Re: Docket Number AD21-9-000: Federal Energy Regulatory Commission, Creation of the Office of Public Participation Comments of the…
Comment
CEI Comments on Federal Energy Regulatory Commission Consideration of Greenhouse Gases in Natural Gas Facility Permitting
View Full Document as PDF Thank you for the opportunity to comment on the Federal Energy Regulatory Commission’s Notice of Inquiry (NOI) on…
Letters
CEI Joins Coalition Letter Regarding App Store Regulation
View Full Document as PDF Dear Senator/Representative: We, the undersigned, oppose state regulations on online application distribution platforms, more commonly known as app…
Letters
CEI Joins Coalition of 23 in Urging Pro-Growth Business Tax Policy
View Full Document as PDF Dear Chairman Wyden, Chairman Neal, Ranking Member Crapo, and Ranking Member Brady: On behalf of the undersigned taxpayer,…
Comment
Competitive Enterprise Institute Letter In Opposition To Withdrawal of Independent Contractor Status Final Rule
View Full Document as PDF On behalf of the Competitive Enterprise Institute (CEI), I respectfully submit the following comments in response to the…