The Public Interest Legal Foundation (PILF), an Indiana-based group that litigates to protect election integrity, submitted the complaint Tuesday to the Office of the General Counsel at the FEC claiming that Hillary Clinton's campaign committee and other left-wing groups may have violated campaign finance laws.
"This complaint is based on information and belief that respondents have engaged in public communications, campaign activity, targeted voter registration drives, and other targeted GOTV [get out the vote] activity under 11 C.F.R. 100.26 and 11 C.F.R. 114.4 at the request, direction, and approval of the Hillary for America campaign committee and the Democratic National Committee in violation of 11 C.F.R. 109.20 and 11 C.F.R. 114.4(d)(2) and (3)," the complaint states.
"Complainant's information and belief is based on findings from an investigation conducted by Project Veritas Action and their published reports regarding the same, as well as on news sources."
"'If the Commission, upon receiving a complaint ... has reason to believe that a person has committed, or is about to commit, a violation of [the FECA] ... [t]he Commission shall make an investigation of such alleged violation ... ' 52 U.S.C. § 30109(a)(2); see also 11 C.F.R. § 111.4(a)."
PILF argues that the groups within the videos–which were caught on tape discussing possible voter fraud scenarios–have organized voter registration drives and other GOTV activities that could have potentially registered people who are not United States citizens.
"On the same information and belief, these voter registration drives and other GOTV activity were coordinated with DNC and HFA by express communication through agents of Democracy Partners and The Foval Group," the complaint reads. "These communications resulted in coordination of voter registration activity in violation of 11 C.F.R. 114.4(c)(2) and (d)(2)-(4) by all parties involved."
The complaint also mentions the "paid protesters" referenced by Democratic operatives within the videos who were allegedly paid to incite violence at Donald Trump rallies.
"Upon information and belief, and based upon the facts set forth above, Respondents Hillary for America, the Democratic National Committee, Democracy Partners, Americans United for Change, and their agents, named and unnamed above, have, each of them, individually and collectively, violated the Federal Election Campaign Act of 1971, as amended, and must be held accountable and liable for their unlawful actions," the complaint concludes.
Clinton campaign treasurer Jose H. Villarreal, the Democratic National Committee, Democracy Partners, Americans United for Change, Scott Foval, and Voces de la Frontera Action are additionally listed as respondents on the complaint alongside Hillary for America.
J. Christian Adams, president of PILF, hopes the FEC will investigate the matter.
"American voter rolls are corrupted with unacceptable numbers of aliens who are illegally registered to vote," Adams said. "Groups should not be coordinating with campaigns and political parties to exploit vulnerabilities in our election system. We hope this matter is fully investigated by the FEC and that if aliens are voting, they are prosecuted by the Justice Department. That would mark a change in DOJ policies of the last 7 years."