Right now, across the world, people are beginning to open their eyes and realize something bigger is happening. We are being told humanity is progressing, that justice is advancing, that the world is becoming fairer — yet every day I see people struggling to survive, wildlife losing habitats, children being born into inequality, and entire ecosystems pushed closer to collapse.
People are no longer just looking for hopeful words and polished campaigns. They are looking for truth. Real truth. Because if we truly want to save animals, protect people and give future generations a fighting chance, then we must have the courage to ask whether the systems shaping this world are actually creating meaningful change — or simply becoming better at marketing the appearance of it.
That is the deeper conversation now being raised by the Fair Start Movement in relation to Harvard University and what the organization describes as a “fantasy world of social justice undone daily by birth inequity.”
This is not about attacking good people.
There are countless students, researchers, activists and educators who genuinely want to make the world better. Many dedicate their lives to helping vulnerable communities, challenging injustice and fighting for equality. That work matters. But the wider concern being raised is whether some institutions have become too focused on presenting narratives of progress while failing to fully confront the structural systems continuing to produce inequality underneath the surface.
And that matters more than ever right now.
The Fair Start perspective argues that many social justice institutions focus heavily on downstream solutions — programs, campaigns, reforms, diversity initiatives and public advocacy — while the upstream conditions driving inequality continue growing stronger every year.
In simple terms, we may celebrate individual victories while the larger system producing suffering remains largely untouched.
That is where the idea of “birth inequity” becomes central.
The argument is that children are not entering the world on anything close to equal ground. Some are born into safety, wealth, opportunity and political influence. Others are born into poverty, instability, environmental decline and systems already stacked against them from the beginning.
And as climate instability, economic inequality and ecological collapse intensify globally, those gaps only grow wider.
The concern being raised is that institutions can sometimes unintentionally create the appearance of meaningful progress by measuring outputs rather than genuine net outcomes. A university can point to programs launched, scholarships funded or initiatives promoted, but the deeper question remains: are the structural conditions affecting future generations actually improving overall?
Because that is the truth people are beginning to search for now.
Not branding.
Not polished narratives.
Not carefully managed public relations.
Truth.
The reality is that across the world we are seeing ecosystems pushed to breaking point. Wildlife is disappearing at terrifying speed. Communities are struggling under economic pressure. Young people are growing up with uncertainty about their future, while millions of children are born into conditions where survival itself becomes harder every single year.
And yet many institutions continue presenting narratives that suggest society is steadily moving toward fairness and sustainability.
That disconnect is what people are starting to question.
For those of us working directly with wildlife and vulnerable communities, these realities are impossible to ignore. I see firsthand how deeply connected everything is. When forests disappear, communities suffer. When inequality grows, ecosystems come under pressure. When people are desperate, wildlife suffers too. The survival of humanity and the survival of nature are tied together whether we acknowledge it or not.
That is why transparency matters.
Not to tear institutions down.
Not to shame people trying to help.
But to ensure that the work being done in the name of justice, sustainability and equality is actually capable of creating long-term change in the real world.
The Fair Start discussion ultimately asks a powerful question: are institutions willing to fully examine whether the outcomes they promote publicly still hold true once the wider baseline realities are honestly accounted for?
Because if we truly care about future generations, then we cannot build systems based only on appearances.
We need courage.
The courage to question whether the current path is truly sustainable.
The courage to confront uncomfortable truths about inequality, growth and ecological decline.
And the courage to build a world where justice is not simply something spoken about in lecture halls or campaign slogans, but something reflected in the actual conditions people, animals and future generations are living through every day.
That is the kind of future worth fighting for.
A future built not on illusion, but on truth.
Letter –
May 8, 2026
Attorney General Andrea Joy Campbell Office of the Attorney General Commonwealth of Massachusetts One Ashburton Place, 20th Floor Boston, MA 02108
Re: Request for Attorney General Review of Directional Impact Representations and Baseline Omission in Massachusetts Animal-Welfare Institutional Communications Under Chapter 93A
Dear Attorney General Campbell,
Fair Start Movement and TruthAlliance.global submit this letter to request review and guidance concerning a specific and recurring pattern in Massachusetts-based institutional communications: the creation of a directional impression of progress through public-facing language that does not disclose the baseline conditions necessary to interpret whether that progress is occurring on balance.
This submission is narrow and disclosure-focused. It does not allege improper motive, and it does not dispute that the institutions discussed perform real work, expend real resources, and achieve identifiable outputs. The issue is whether public-facing representations—particularly those that operate in donor-facing, student-facing, or credibility-bearing contexts—are structured in a way that invites reliance on an implied trajectory of improvement without providing the baseline information required to evaluate that implication.
The concern arises from a consistent pattern across multiple Massachusetts institutions. Language is often framed carefully to avoid explicit, measurable outcome claims. Terms such as “committed to,” “working to,” and “seeking to advance” appear frequently in institutional descriptions of animal-law programming and advocacy. At the same time, that language still communicates something to a reasonable reader. It conveys forward motion. It signals that progress is being made, or at minimum that support for the institution contributes to that progress. That signal influences behavior. It shapes donation decisions, student enrollment, partnerships, and policy attention.
The problem is not the use of aspirational language itself. The problem is that the directional impression created by that language is not accompanied by the context needed to determine whether the implied progress is occurring when broader conditions are taken into account. Public-facing materials do not typically disclose the scale of countervailing forces—continued expansion of animal agriculture, growth-driven demand, ecological degradation, and structural conditions that perpetuate harm across generations. Without that context, the impression created by the language may be materially incomplete.
This dynamic becomes more pronounced where institutions move from aspirational phrasing into definitive outcome language. In Massachusetts, MSPCA-Angell provides a clear example. The organization describes itself as “positively impact[ing] the lives of tens of thousands of animals each year” and as driving “meaningful, systemic change.” These are present-tense outcome statements. They communicate that impact is occurring and that systems have changed. At the same time, the organization has publicly disclosed that it no longer tracks the metrics used to measure its results. The combination of definitive outcome language and the absence of outcome measurement creates a gap between the impression conveyed and the substantiation available. That gap is not theoretical. It exists at the point where donors decide whether to contribute, and where the public decides whether progress is being achieved.
A similar issue arises with quantified claims made by Humane World for Animals. Statements that millions of meals have been transitioned or that over a million animals have been improved are specific and concrete. They communicate progress through numbers. But those numbers operate within a broader system that is not disclosed alongside the claim. If the total scale of animal agriculture or confinement grows by more than the improvements cited, the directional impression created by the numbers may not reflect the net trajectory. The claim itself may be accurate in isolation. The impression created by the claim, absent baseline context, may still be incomplete.
Across these examples, the same structural issue appears. Public-facing communications operate at the level of narrative, while the conditions necessary to interpret that narrative—what is counted, what is excluded, what baseline governs the claim, and how competing forces affect the outcome—are not disclosed at the point of reliance. This is the baseline omission problem. It is not a dispute about values. It is a question of whether the information environment in which decisions are made is complete enough to support those decisions.
Massachusetts General Laws Chapter 93A provides a framework for addressing this issue. The statute does not require that a statement be literally false to be actionable. It encompasses conduct that creates a misleading impression through omission of material information. Where a representation invites reliance and the meaning of that representation depends on context that is not disclosed, the omission may be material if it would change the understanding of a reasonable audience.
In this context, baseline conditions are not peripheral details. They are the elements that determine what the claim means. They define whether a statement reflects activity, projected contribution, or demonstrated net outcome. When those elements are absent, the resulting impression may be incomplete in a way that affects decision-making.
This submission therefore requests that the Office consider whether directional impact representations in Massachusetts animal-welfare communications should be evaluated under a material-omission framework when they omit baseline conditions necessary to interpret implied progress. The request is not for punitive action based on isolated statements. It is for a structured review of whether current practices create reliance risks that can be addressed through disclosure.
Specifically, we request that the Office consider initiating a Chapter 93A review of how animal-welfare institutions in Massachusetts communicate impact and progress, with attention to whether those communications distinguish between program outputs and net outcomes once baseline conditions are accounted for. We further request consideration of whether guidance should be issued clarifying that aspirational and outcome-oriented language can create materially incomplete impressions when baseline conditions are omitted.
In addition, we request that the Office review MSPCA-Angell’s use of definitive outcome language in light of its disclosed cessation of outcome measurement, and that it examine whether quantified claims by Humane World for Animals create directional impressions that are supported when evaluated against broader system-level trajectories.
The remedy sought is disclosure-forward and corrective, not punitive. The objective is to ensure that when institutions communicate impact, the public is provided with the information necessary to understand what that impact means and what it does not mean. This can be accomplished through baseline disclosure: clear statements of what is counted, what is excluded, the time horizon used, the presence of uncertainty, and the distinction between outputs and net outcomes.
Fair Start’s Tell the Truth framework provides one model for this approach. It asks institutions to align public claims with the baseline conditions that determine their meaning, so that reliance is based on complete information rather than directional impression alone. The framework is designed to be applied cooperatively, allowing institutions to maintain their advocacy while improving the clarity and integrity of their communications.
We recognize that the institutions discussed are respected and perform meaningful work. This request does not challenge that work. It addresses the structure of the information environment in which that work is presented. Where public trust is involved, clarity is not optional. It is the condition that allows that trust to function as intended.
We respectfully request confirmation of intake and identification of the division or bureau assigned for review.
Respectfully submitted,
Suriya Khan Fair Start Movement / TruthAlliance.global suriya@fairstartmovement.org 516-725-3157
There is a growing conversation happening across the world about justice, inequality and the stories institutions tell about progress.
Not just in climate activism or animal protection, but in universities, nonprofits, philanthropy and social justice movements themselves.
People are beginning to ask a difficult but necessary question:
Are we truly addressing the root causes of suffering and inequality, or are we building narratives of progress while the underlying systems continue producing harm every single day?
That question sits at the heart of the recent Fair Start Movement article discussing Yale and what the organization describes as a “fantasy world of social justice undone daily by birth inequity.” (Fair Start Movement)
Importantly, this conversation should not be framed as an attack on individuals trying to create positive change. Many people working in academia, social justice advocacy and philanthropy genuinely care deeply about equity, human rights and creating a better future. Many dedicate their lives to helping vulnerable communities and challenging injustice.
But the article raises a broader systems-level concern.
It argues that many public-interest institutions may be measuring impact inside incomplete frameworks that fail to fully account for the structural conditions shaping real-world outcomes — particularly inequality at birth, political inequity and the long-term effects of growth-driven systems. (
At the center of Fair Start’s argument is the idea that “downstream” social justice work can be continuously undermined if the “upstream” systems driving inequality remain unchanged.
The article places particular emphasis on what it calls “birth inequity.”
This refers to the reality that children enter the world under vastly unequal conditions depending on wealth, race, geography, political influence and environmental stability. Fair Start argues that these starting conditions profoundly shape health, opportunity, democratic influence and long-term survival itself, especially as climate instability and ecological degradation intensify globally.
The broader concern being raised is that many institutions discuss justice without fully accounting for these baseline inequalities.
From the Fair Start perspective, if systems continue allowing millions of children to enter conditions of severe inequity, then downstream reforms alone may struggle to produce meaningful net progress over time. The movement argues that many public-facing impact claims fail to fully disclose how structural growth, ecological degradation and political inequality may be undoing the very outcomes organizations publicly celebrate. (Fair Start Movement)
Whether one agrees entirely with Fair Start’s framework or not, the deeper questions being raised are significant.
How should institutions measure progress honestly?
How do we distinguish between symbolic progress and systemic transformation?
And how do we ensure that public trust is grounded in transparency rather than carefully managed narratives?
These are questions that are becoming harder for society to ignore.
Across the world, people are watching ecosystems deteriorate, inequality deepen and political trust erode, even while institutions continue presenting optimistic narratives about sustainability, justice and progress. Increasingly, there is public demand for more honest conversations about whether current systems are truly addressing the root causes of the crises humanity now faces. (Fair Start Movement)
For those of us working directly with animals, conservation and vulnerable communities, these realities are impossible not to see.
We see humans and wildlife increasingly competing for shrinking resources. We see communities struggling under economic and environmental pressure. We see ecosystems under stress. And we see how inequality and ecological collapse are deeply connected.
Because when systems fail people, they also fail nature.
The Fair Start article ultimately calls for something larger than political ideology or institutional branding. It calls for a deeper level of honesty about how we measure impact, how we define justice and whether the systems currently shaping the world are truly capable of delivering a fair future for the next generation.
And perhaps that is the most important part of this conversation.
There is a growing feeling across the world that something is not adding up.
People see climate campaigns, sustainability branding, corporate pledges and public-interest initiatives everywhere. We are constantly told progress is being made. Yet at the same time, forests continue disappearing, species continue vanishing, temperatures continue rising and inequality continues deepening across entire generations.
So naturally, people are beginning to ask a difficult question:
If all this progress is happening, why does the world still feel like it is moving toward crisis?
Importantly, this conversation should not be viewed as an attack on people trying to do good.
Many individuals inside environmental organizations, charities, universities and advocacy groups genuinely care deeply about protecting people, animals and the planet. Many dedicate their lives to helping others. But the Fair Start argument is that good intentions alone are not enough if the systems used to measure “impact” fail to include the baseline realities shaping outcomes in the real world.
Person giving food to another
And that distinction matters enormously.
The core concern raised by Fair Start is that institutions often celebrate downstream victories — projects completed, emissions reduced, forests protected, animals rescued, policies passed — without fully accounting for the larger upstream conditions continuing to worsen overall outcomes. According to the campaign, this creates what they describe as a “fantasy world of progress,” where isolated successes are publicly highlighted while wider ecological and social deterioration continues in the background.
In simple terms, the question becomes:
Are we measuring genuine net progress, or are we measuring selective progress inside systems that continue driving larger harm overall?
Fair Start argues that many public-interest organizations, governments and institutions have relied on what they call incomplete or distorted “baseline” assumptions when presenting impact claims to the public. Their concern is not merely about data, but about transparency. They argue that audiences deserve to understand the full context behind institutional claims of success, particularly where larger structural conditions may be undoing much of the progress being celebrated publicly.
The campaign places significant focus on climate change, inequality and intergenerational justice. It argues that ecological destruction and social inequality are deeply interconnected, and that the most vulnerable communities — especially children and future generations — often bear the heaviest consequences of systems designed around growth without long-term balance or equity.
How do we distinguish between meaningful systemic change and isolated wins that may be outweighed elsewhere?
And how do we ensure that public trust is built on transparency rather than carefully managed narratives?
These are not small questions anymore.
Across conservation, climate policy and public-interest advocacy, there is increasing recognition that outcomes cannot simply be measured through branding, fundraising success or headline achievements alone. More organizations are now being asked to disclose the assumptions, modelling limits and broader systems behind their public-facing impact claims. That conversation is growing globally. (fairstartmovement.org)
At its heart, this is really a conversation about integrity.
Because the world does not need more polished marketing around sustainability while ecosystems continue collapsing. It does not need more carefully crafted narratives around compassion while inequality and environmental instability intensify underneath the surface.
What people are looking for now is honesty.
Honesty about what is working.
Honesty about what is failing.
And honesty about whether current systems are truly creating a livable future for both humanity and the natural world.
For those of us working directly with wildlife, conservation and communities on the ground, these realities are impossible to ignore. We see humans and animals increasingly pushed into conflict over shrinking resources. We see ecosystems under pressure. We see vulnerable communities struggling to survive. And we know that protecting nature and protecting humanity cannot be separated from one another.
Because without healthy ecosystems, there is no long-term future for any of us.
David Goldman / Associated Press via LA TImes
That is why transparency matters so much moving forward.
The Honorable Letitia James Office of the New York State Attorney General The Capitol Albany, NY 12224-0341
Re: Submission Requesting Baseline-Disclosure Addendum and Settlement-Messaging Guardrails – JBS USA Climate and Sustainability Matter (Assurance of Discontinuance No. 25-067)
Attorney General James:
This submission asks the Office to close a disclosure gap that can survive enforcement itself: absent plain-language baseline disclosure, settlement messaging in a greenwashing matter can operate as an implied credibility signal for the very class of “net” climate representations whose ambiguity gave rise to the enforcement action.
At issue is not a disagreement over values, nor a claim that nothing beneficial may have occurred. The issue is narrower and more administrable. When public-facing impact claims are communicated without the baseline conditions necessary to interpret them, the public is left to rely on an incomplete account of what is being represented. In that setting, settlement communications themselves can become a reliance event.
Purpose and Posture
Purpose. Convert settlement legitimacy into a baseline-integrity requirement. Enforcement outcomes should not function as implied validation of net-benefit narratives unless settlement communications require baseline disclosure that makes the claim falsifiable to the public.
Posture. This is not a dispute about intent, ideology, or whether any emissions-related progress occurred. It is a consumer-protection submission framed around plausibly material omissions and corrective disclosure remedies. The concern is preemptive. It applies at the point at which claims are made and repeated to the public, not only after reliance has already hardened or harm has already diffused.
Factual Posture
On November 3, 2025, your Office announced a $1.1 million settlement with JBS USA Food Company and JBS USA Food Company Holdings arising from alleged misleading climate marketing tied to “net zero” messaging, and stated that JBS USA agreed to reform marketing practices and report annually to OAG for three years.
The Assurance of Discontinuance identifies the covered “Net Zero by 2040” statement and resolves claims under Executive Law § 63(12) and General Business Law §§ 349–350, and includes monetary relief totaling $1.1 million.
Consumer Deception by Omission
Deception analysis turns on the net impression created and whether missing information is material to a reasonable audience’s understanding and decision-making. Material omissions can mislead even absent proof of motive.
In climate “net” claims, baseline omissions are often decisive. The missing information that matters here is not abstract disagreement over climate values. It is the set of plausibly material conditions that determine what a reasonable audience is actually being asked to believe: what is counted, what is excluded, what “net” depends on, how uncertainty is treated, how time horizons and discounting choices affect meaning, and whether the claim reflects a present, verified condition or a contingent future aspiration.
Where those baseline conditions are incomplete, narrowed, or omitted, the resulting representation may not satisfy the minimum conditions necessary for meaningful public evaluation. What appears to be a concrete climate achievement may instead rest on unstated accounting choices, offset assumptions, exclusions, and contingencies that materially alter the claim’s significance. In that setting, the omission is not peripheral. It is part of the claim’s meaning.
Settlement-Optics Reliance Risk
When the State resolves a greenwashing matter, the public naturally treats the resolution as a credibility signal. That is especially true where the resolution is public, formal, and issued by an enforcement authority charged with protecting consumers from misleading representations.
This submission does not claim that OAG endorsed JBS. The point is narrower. Settlement communications are themselves a public reliance event. Without a baseline-disclosure addendum, they can still leave reasonable audiences with an inference of validated net-outcome meaning that the enforcement action was meant to correct.
That risk matters because public-facing claims influence more than immediate purchasing behavior. They shape institutional trust, commercial reputation, counterpart relationships, policy discourse, and the broader public understanding of what counts as climate progress. If enforcement is to preserve its corrective function, it should not allow settlement optics to become a vehicle for credibility laundering through unresolved ambiguity.
Requests
Request 1: Baseline-Disclosure Addendum as a Condition of Ongoing Settlement Messaging
Ask OAG to publish, and require JBS to host and maintain, a plain-language baseline-disclosure addendum that must accompany any continued “net zero” or emissions-reduction messaging covered by, adjacent to, or reasonably derivative of the settled representations.
The addendum should be structured as a checklist completion for each flagship claim:
A) Claim Translation State what the claim implies to a reasonable audience versus what is actually promised.
B) Accounting Boundary Specify Scope 1, Scope 2, and Scope 3 treatment, supplier boundary rules, land-use change treatment, and which entities and brands are in scope.
C) Net Mechanism Disclose the share of reductions versus offsets or removals, offset types, quality criteria, permanence and leakage assumptions, retirement mechanics, and double-count safeguards.
D) Time and Metric Choices Disclose the baseline year, interim milestones, time horizon, and metric choices that materially change meaning.
E) Verification and Audit Trail Name the verifier, frequency, standard used, substantiation availability, and what triggers correction.
F) Decision Thresholds State what would cause the claim to be treated as no longer supportable, requiring correction or withdrawal.
Request 2: Standardized “What This Does Not Mean” Disclaimers
For statements that could imply verified net outcomes, require short standardized disclaimers that constrain inference, including:
Goal-versus-guarantee language, Reliance limits describing what audiences should not infer, Dependency disclosures, including Scope 3 dependence and offset-quality dependence, Correction triggers identifying what changes the claim’s supportability.
Request 3: Verification Hooks Tied to Existing Settlement Compliance Mechanics
Use the settlement’s existing monitoring infrastructure, including annual compliance reporting and review mechanics, as verification hooks by tying compliance certification to completion and maintenance of the baseline-disclosure addendum for each flagship claim, not solely to phrasing edits.
Request 4: Settlement Communications Guardrail for Similar Cases
Adopt a settlement-communications protocol for greenwashing matters under which no official language is used that can reasonably be read as net-outcome validation unless baseline disclosures and substantiation availability are in place and correction triggers are stated.
Legal Support for a Disclosure-Forward Remedy
This submission seeks compelled, factual, uncontroversial baseline disclosures reasonably related to preventing deception in consumer-facing marketing and settlement-adjacent communications. The requested relief does not require the Office to endorse any ideological position on climate policy. It asks only that where public-facing claims invite reliance, the baseline conditions necessary to interpret those claims are disclosed clearly enough for the public to understand what is being asserted and what is not.
That is consistent with the core consumer-protection concern here. Where a representation depends on unstated boundaries, exclusions, dependencies, or contingent assumptions, the omission of those conditions can materially distort the net impression received by a reasonable audience.
Ripeness
Ripeness is strong because the covered climate claims and settlement communications are already public, the requested relief concerns disclosure and verification mechanics rather than speculative damages quantification, and the settlement already contains compliance infrastructure that can be upgraded into baseline disclosure without departing from ordinary consumer-protection logic.
Requested OAG Actions
Acknowledge intake and identify the bureau or division assigned for review.
Publish an OAG baseline-disclosure addendum template for “net” climate claims and require JBS to host it for covered claims.
Require standardized disclaimers for any “net zero” or emissions-reduction statements that could imply verified net outcomes.
Tie annual compliance reporting to baseline-disclosure completion, maintenance, and correction triggers for each flagship claim.
If settlement communications leave unresolved the baseline conditions that determine what a “net” claim means, enforcement risks correcting deceptive phrasing while preserving deceptive inference. The minimal fix is to require baseline disclosure wherever official resolution may influence public reliance. About the www.FairStartMovement.org: Unless a person or company claiming to “add value” can prove their impact accounts for the full, preemptive cost of equitably empowering every child at birth, the claim collapses under scrutiny. That means showing conditions where each child enters the world with the health, resources, and real-world influence required to withstand climate risk, systemic inequity, and political exclusion. If those conditions are not measured, disclosed, and met, the claim is built on a distorted baseline. It shifts real costs onto the most vulnerable while preserving benefits for the claimant—turning impact reporting into a mechanism that can obscure harm rather than demonstrate it.
Respectfully Submitted,
Carter Dillard Carter@fairstartmovement.org 516-725-3157 Fair Start Movement / TruthAlliance.global
What is happening right now is bigger than one university, one legal program, or one public dispute.
Across the world, people are beginning to ask deeper questions about institutional accountability, transparency and truth. Whether in conservation, climate policy, social justice, public health or animal protection, the same concern keeps appearing: are institutions presenting real impact, or carefully managed narratives of impact?
That question now sits at the center of growing concerns surrounding the University of Denver Sturm College of Law’s animal-law programming.
And importantly, these concerns are no longer coming only from activists or campaigners.
On February 18, 2026, public health and systems governance specialist Pierrette Kengela submitted an expert perspective letter to Dean Smith of the University of Denver Sturm College of Law. Writing in his independent expert capacity, Kengela outlined growing cross-sector concerns regarding what he describes as “baseline transparency” and “impact integrity” in public-interest programming.
His letter matters because it places this issue into a much wider global context.
Kengela’s work focuses on child rights, intergenerational accountability, institutional integrity and African Union–aligned policy work examining long-term social and structural outcomes. In his letter, he explains that across multiple sectors there is increasing technical concern about how institutions communicate public-benefit impact to donors, students, stakeholders and the wider public.
At the center of that concern is one enormously important distinction:
The difference between “program outputs” and genuine “net outcomes.”
In simple terms, institutions may report actions taken, services delivered, advocacy campaigns launched or legal cases supported. Those are outputs. But the deeper question is whether overall conditions genuinely improved once the surrounding baseline realities and structural drivers are fully accounted for.
And that distinction changes everything.
Because if underlying systems continue expanding suffering faster than interventions reduce it, then institutions have a responsibility to communicate that reality honestly.
Kengela’s letter explains that this issue is now increasingly recognized across public health, climate accountability and governance sectors as a matter of evidence integrity and informed public reliance. Public-facing impact claims, he argues, should be clearly bounded by transparent assumptions, modelling limits and honest disclosure of baseline conditions.
That is not an attack on advocacy.
It is a call for credibility.
The concerns raised around Sturm’s animal-law programming center on whether public-facing impact language may imply meaningful net progress in animal protection without sufficiently disclosing the wider structural conditions shaping those outcomes. In other words, whether downstream successes are being publicly emphasized while upstream systems driving harm remain outside the accounting framework.
This matters deeply because law schools are not ordinary institutions.
Lady Justice on a desk by a scale on a desk near laptop
They train future legal professionals. They shape public discourse. They carry institutional authority. And when legal institutions communicate impact to the public, donors and students, there is an expectation that those representations are grounded in rigorous evidence and methodological integrity.
Kengela’s letter warns that when baseline assumptions remain implicit, program outputs can unintentionally be interpreted as evidence of broader net progress even when underlying structural conditions remain unchanged or continue worsening.
We see this problem across the world every day.
Wildlife conservation campaigns celebrate rescues while habitats continue disappearing at industrial scale. Sustainability initiatives market progress while ecosystems collapse in the background. Social justice organizations report outputs while inequality deepens year after year. While there are many great rescues happening, and conservation efforts are working, with rewilding and many species have been saved from extiction due to conservation efforts. Many species are in rapid decline, with direct conflict with people. Such as the lion.
And meanwhile, ordinary people are left believing the systems are working.
This is why transparency matters.
Not to destroy institutions, but to strengthen them.
Not to undermine advocacy, but to ensure public trust in it.
Kengela repeatedly emphasizes in his letter that this is ultimately a governance issue. From a public health and institutional integrity perspective, he argues that transparent disclosure of assumptions and modelling limitations is essential so that donors, students and the public can accurately understand what institutional metrics do — and do not — establish.
Because impact should never depend on selective visibility.
And that is the wider issue now being confronted.
Around the world, institutions have become incredibly skilled at marketing compassion. But increasingly, people are beginning to ask whether those narratives are supported by full accounting of the systems underneath them.
The world does not need more carefully managed branding around justice, sustainability or animal protection.
It needs honesty.
It needs institutions willing to openly examine whether the outcomes they publicly promote remain true once baseline realities are fully disclosed.
Because if we truly want to protect animals, protect people and create a sustainable future, then accountability cannot be treated as an inconvenience.
It must become the standard.
And perhaps most importantly, it must begin with the courage to tell the whole truth — even when the full picture is uncomfortable.
Letter –
February 18, 2026
Office of the Dean
University of Denver Sturm College of Law
2255 E. Evans Avenue
Denver, CO 80208
Subject: Expert Perspective on Baseline Transparency and Impact Integrity in Animal
Law Programming
Dear Dean Smith,
I write in my individual expert capacity as lead of the African Union–focused petition on birth
equity and intergenerational accountability, and as a public health and systems governance
specialist working at the intersection of child rights, equity, and institutional integrity.
My engagement on this issue is informed by cross-sector work examining how public-interest
claims are evaluated in contexts where structural conditions, including child-rights protections,
intergenerational equity, and climate-related vulnerability, materially shape real-world
outcomes. Across these domains, there is increasing technical emphasis on ensuring that
institutional impact language is analytically bounded by clearly stated assumptions and
methodological limits.
I am aware that FairStartMovement.org and TruthAlliance.global have filed an institutional
complaint with the University of Denver Sturm College of Law requesting written clarification
and internal review regarding (a) how animal-law programming and affiliated advocacy assess
and publicly represent impact and (b) whether public-facing claims clearly distinguish program
outputs from net outcomes once baseline variables and modelling limits are disclosed.
I offer this perspective to support careful institutional reflection on the methodological and
governance considerations raised in recent correspondence regarding impact representation in
animal law programming. At its core, the issue under discussion, namely, the use of impact
language that may imply net outcomes without explicit baseline disclosure, is increasingly
recognized across multiple sectors as a matter of evidence integrity, informed reliance, and
sound institutional governance.
This perspective is offered in the spirit of strengthening methodological clarity and informed
institutional practice. It does not seek to adjudicate underlying policy positions or advocacy
viewpoints. Rather, from a governance and public-reliance perspective, the central
consideration is whether public-facing impact representations are appropriately bounded by
transparent baseline assumptions, clear modelling limits, and a disciplined distinction between
program outputs and net system outcomes.
Context: Growing Cross-Sector Attention to Impact Integrity
Across multiple sectors, including global health, climate accountability, and social justice
programming, there is growing recognition that program outputs (e.g., services delivered, cases
supported, or interventions undertaken) must be clearly distinguished from net outcomes once
relevant baseline conditions and modelling limits are considered.
This distinction reflects well-established evaluation principles concerning attribution,
materiality of assumptions, and the decision-usefulness of public-facing evidence. It is not a
matter of perfection, but of analytical clarity and institutional credibility.
From a child-rights and intergenerational equity perspective, the question is straightforward:
public-benefit claims carry the greatest legitimacy when institutions clearly state the baseline
assumptions under which those claims are made and disclose any material limits in the
underlying models. Doing so protects donor intent, supports informed public understanding,
reduces the risk of reliance on overstated impact narratives, and strengthens confidence in
academic and advocacy work alike.
Cross-Sector Observations from AU-Aligned Work
The African Union–oriented work I help lead has emphasized that systems of accountability
across sectors increasingly require attention to how structural conditions, including
intergenerational equity dynamics, shape the real-world effects of well-intentioned
interventions. Across multiple policy environments, we have observed that where baseline
conditions and distributional assumptions remain implicit, program outputs can be
inadvertently interpreted as net progress even when underlying structural drivers of harm
remain unchanged. This is not unique to any single field; it is a recurring systems-governance
challenge with implications for evidence integrity, public reliance, and the credibility of
impact-oriented work.
During AU-aligned policy work and related cross-sector reviews, our analyses have similarly
emphasized the importance of testing whether publicly communicated program gains remain
robust once underlying structural conditions and distributional baselines are made explicit. In
practice, this involves examining (i) the stated program outputs, (ii) the baseline conditions and
equity assumptions under which those outputs are interpreted, and (iii) the extent to which the
institution has bounded any net-outcome implications through appropriate methodological
disclosure. Where these elements are not clearly aligned, even well-intentioned impact
narratives can outpace what the available evidence is positioned to substantiate.
In that spirit, I respectfully encourage continued academic engagement with evolving best
practices in impact transparency, baseline disclosure, and methodological clarity, particularly
where public-facing programs may reasonably be understood by external stakeholders as
demonstrating net social benefit.
Institutional Relevance for Academic Programs
Universities play a uniquely important role in modelling careful, evidence-based
communication for the broader public. Processes that review impact language, clarify
modelling assumptions where needed, and ensure alignment between program descriptions and
measurable outcomes can only strengthen institutional trust. This is particularly important in
fields such as animal law and social justice advocacy, where stakeholders, including students,
donors, and community partners, may reasonably rely on institutional representations when
making financial, legal, or professional commitments. Where baseline conditions materially
shape net outcomes, transparent disclosure is not merely a technical preference but an element
of sound governance and informed public reliance.
I note the University of Denver’s role in legal scholarship and animal law education and
encourage a constructive, evidence-grounded dialogue on these questions as the field continues
to evolve. Engagement with emerging standards on baseline clarity and impact framing offers
an opportunity for academic institutions to lead proactively in strengthening methodological
rigor across the sector, consistent with the broader accountability principles increasingly
recognized in global health, sustainability, and intergenerational equity work.
From a public health and governance perspective, the distinction between reported outputs and
demonstrated net outcomes is not merely semantic; it is central to risk interpretation, resource
allocation, and institutional credibility. Where baseline conditions materially influence
downstream effects, good practice increasingly favors transparent disclosure of key
assumptions so that donors, students, and the public can accurately interpret what program
metrics do, and do not, establish.
Sincerely,
Pierrette Kengela
Public Health Expert
Lead Contributor, AU Birth Equity Petition
Founder, Joy4All Global Initiative
Save the Animals Save The World, was set up by Ryan Parker, a wildlife conservationist, wildlife presenter, safari guide and animal rescuer. With a love of the natural world, and being in the wild making more sense. My idea is that restoring wild areas, letting nature take its course, an ecological balance of evolutionary grand design. But with a growing human population, fighting for resources, human population pushing the climate, more people pushed into poverty.
More and more wildlife is coming into conflict with humans. Animals are not only fighting for wild areas, but also urban areas. We cannot blame the people who are trying to survive, and we cannot blame the animals. They are both the result of social inequalities. And why is this bad?
Once you start removing nature, a species, whether it be plant, fungi, or animal, from birds, to insects, spiders, to large mammals. Every species has an important role to play. Take that away, the ecosystem starts to fail, and this affects us humans. It affects crop growth, flooding, human health, disease control, and even climate, and so much. You just need to check out the benefits of rewilding wolves to Yellowstone national park, or Humpbacks returning in numbers, or the benefits of beavers returning to the U.K. The importance of parrots, or the importance of song birds, to the importance of elephants, or sharks. The list is endless.
So we need to teach people how to live alongside these amazing animals. How to coexistence. As most of the time, the funding from governments, large companies do not reach, the local people. For me conservation is about uniting people. For conservation to work, to help the planet, we need to work together without discrimination. A brotherhood of man.
And me personally how do I do this? Through love! To give hope. My passion and excitement for the natural world! I love it with my heart, and I can get people excited about wildlife. As a safari guide, as wildlife presenter. If I can show what beauty we have on this planet, from wildlife to landscapes. I can make people fall in love with it and fight to save it. This is why I make wildlife films, and take people on safari. I am a conservationist sales man here to save the world. But also prove that people do not have to be a conservationist, know the difference between an alligator or crocodile, or be part of a rich organization. That everyone can make a difference, by simple things, that do not cost money, or spending in the right place if they do. By being kind! This is how! Myself I align myself to work with small grassroots NGO companies working for little money, that is dangerous, hard, with little support. Just like me, I struggle to pay my rent and pay to rescue animals. So I understand them. These are the people that are making a difference! An inspiration. And any company that supports that same ethos, I will be happy to work with them, like I do supporting the Fair Start Movement!
Because if we can work together, to save animals, they will save the world!
For too long, institutions across the world have learned how to market compassion better than they measure outcomes.
That is the deeper issue now emerging around the University of Denver Sturm College of Law’s animal-law programming and the wider concerns being raised regarding public-facing impact claims, donor representations and institutional accountability.
At the centre of this dispute is a simple but enormously important question:
What happens when institutions present “impact” to the public while excluding the baseline realities that determine whether any genuine net progress actually exists?
Because that is where trust begins to break down.
The public narrative surrounding Sturm’s animal-law brand has been built around rescue-adjacent work, activist defence, clinics, advocacy and legal reform. These are all emotionally compelling and highly marketable areas of work. But concerns now being raised publicly suggest that the impact framework being relied upon may exist inside a controlled accounting model — one that measures visible downstream successes while failing to fully account for the larger upstream systems continuing to expand suffering overall.
And that distinction changes everything.
Because if an institution highlights isolated victories while excluding the broader baseline drivers that continue increasing harm, then what is being presented may no longer reflect true net impact. It becomes a selective narrative rather than complete accounting.
This is not simply a philosophical disagreement about activism.
It is a question of evidence integrity.
The TIPOC argument being raised is fundamentally about transparency. It argues that truth in public impact claims requires institutions to disclose the context necessary for those claims to be properly understood. A law school, of all places, understands how omission works. A statement does not need to be technically false in order to become misleading. If favourable variables are included while unfavourable baseline conditions are excluded, the public can easily be led toward conclusions the full evidence may not support.
And when that narrative is tied to donor funding, recruitment, institutional prestige and moral authority, the stakes become even higher.
Because this is not just about branding.
It is about whether public trust is being earned honestly.
The concern being raised is that institutions can continue producing marketable “wins” indefinitely if they operate inside incomplete accounting systems. Downstream advocacy will always appear successful if the underlying baseline conditions driving harm are kept outside the frame. Meanwhile, the harder upstream work — work that might actually reduce the baseline pipeline of suffering itself — becomes politically difficult, financially inconvenient and structurally unsupported.
That creates a dangerous equilibrium.
One where omission becomes normalised because honesty becomes competitively disadvantageous.
This matters profoundly within legal education.
A law school is not simply another nonprofit organisation producing awareness campaigns. It is a credentialing institution responsible for training future professionals to think rigorously, analyze evidence carefully and communicate claims responsibly. If impact language is allowed to imply net societal benefit without complete accounting, then students risk learning the worst possible lesson: that moral language can substitute for analytical integrity.
That is not justice.
That is narrative management.
And this is why formal accountability measures are now being demanded publicly and in writing.
The requests being raised are not vague emotional complaints. They are structured governance demands.
They include calls for a written response issued under the Dean’s authority identifying who holds responsibility for impact claims, donor representations and program oversight. They include requests for documented legal review by University counsel examining public-facing materials, internal methodologies and the standards used to define institutional “impact.”
There are also calls for escalation beyond the program’s own internal incentive structures, including involvement from wider University leadership and oversight mechanisms designed specifically for situations where reputational protection risks overriding accountability.
Record preservation has also been demanded immediately, including internal drafts and communications, because institutions under scrutiny often attempt to quietly revise narratives after concerns become public.
Most importantly, there are calls for public corrections wherever net outcomes may have been implied without genuine net accounting.
Because silent edits are not accountability.
They are damage control.
The broader issue here extends far beyond one university.
Across conservation, sustainability, public health and social justice sectors, the same structural problem keeps appearing: institutions learning how to market virtue while avoiding full disclosure of the systems-level realities underneath.
But the world does not need better narratives anymore.
It needs honesty.
Because if organisations truly want to protect animals, protect people and protect the future of this planet, then impact cannot be measured through selective visibility.
What is becoming increasingly clear across the world is that this conversation is no longer limited to animal welfare alone.
The questions now being raised around institutional transparency, impact representation and public accountability are appearing across public health, climate policy, child rights, sustainability and international governance. The deeper we look, the more we find the same structural issue repeating itself: institutions presenting outputs as evidence of meaningful progress, while failing to fully disclose the baseline conditions that continue driving harm underneath the surface.
These concerns were further reinforced through an independent expert letter submitted by Pierrette, a public health and systems governance specialist whose work focuses on child rights, intergenerational accountability, equity policy and institutional integrity, including African Union–aligned work examining long-term social and structural outcomes.
In his letter, Pierrette explains that across multiple sectors there is increasing concern around how institutions communicate public-benefit impact. In particular, the distinction between “program outputs” and genuine “net outcomes” is becoming central to modern standards of accountability and evidence integrity.
And that distinction matters enormously.
Because there is a major difference between reporting actions taken, campaigns launched or services delivered — versus proving that overall conditions genuinely improved once wider structural realities are taken into account.
Pierrette’s letter does not seek to attack advocacy itself, nor undermine the importance of animal protection, social justice or public-interest work. Instead, it raises broader governance questions that institutions across the world are increasingly being forced to confront:
Are public-facing impact claims being communicated with sufficient transparency?
Are baseline assumptions clearly disclosed?
Are modelling limitations openly acknowledged?
And are institutions carefully distinguishing between measurable outputs and actual system-wide outcomes?
These questions sit directly at the center of the current concerns surrounding the University of Denver’s animal law programming and associated public-facing advocacy efforts.
At issue is whether institutional impact language may have implied meaningful net progress in animal protection without sufficiently disclosing the wider structural realities surrounding inequitable growth, systemic harm and the limitations of the underlying models being relied upon.
The concern is not necessarily that individuals involved lacked good intentions. Many people working within these institutions genuinely want to create positive change. But intention alone cannot replace transparency.
Because if suffering expands faster than interventions reduce it, then institutions have a responsibility to communicate those realities honestly.
In his letter, Pierrette explains that across global health, sustainability and governance sectors, there is increasing emphasis on what is known as “evidence integrity” — ensuring that publicly communicated impact claims are analytically grounded, methodologically transparent and properly bounded by clear assumptions.
This is becoming one of the defining issues of institutional trust in the modern world.
From climate policy to child-rights work, systems experts are increasingly warning that when baseline conditions remain hidden or poorly disclosed, even well-intentioned advocacy can unintentionally create overstated narratives of progress. Programs may highlight outputs — cases supported, services delivered, campaigns launched — while larger structural conditions continue worsening overall outcomes in the background.
We see this happening globally every day.
Wildlife disappears while conservation campaigns raise millions. Forests shrink while sustainability reports celebrate incremental targets. Children continue suffering under systems that publicly market themselves as advancing social equity. Communities face hunger and instability while institutions produce carefully managed narratives designed to reassure stakeholders that progress is being made.
Meanwhile, the planet itself continues absorbing the consequences.
That is why this issue matters beyond any one university, campaign or organization.
The deeper question is whether institutions operating in the public-interest space are willing to hold themselves to the same standard of transparency they often demand from governments and corporations.
Because accountability cannot only exist outwardly.
It must also exist inwardly.
Pierrette’s letter ultimately calls for stronger methodological clarity, transparent baseline disclosure and more disciplined communication around institutional impact claims. Not to weaken advocacy, but to strengthen public trust in it.
Because a world facing ecological collapse, inequality and growing social instability cannot afford narratives that outpace reality.
People deserve clarity.
Donors deserve informed understanding.
Students deserve truthful institutional representations.
And the public deserves confidence that organizations claiming to create change are willing to openly disclose both the successes and the limitations of what their programs are actually achieving.
There comes a point where we have to stop applauding promises, and start measuring outcomes.
Across the world, we are seeing major institutions, charities, corporations and organisations present themselves as leaders in environmental protection, sustainability, animal welfare and social progress. Many of the people within these organisations genuinely care. Many begin with honourable intentions. But when operations scale, priorities can shift. Profit margins, public image, fundraising targets and institutional KPIs can begin to outweigh the very mission these organisations were created to serve.
That is where accountability matters.
What we are now seeing is a growing dispute over whether certain institutions are using legally and ethically sound baselines when fundraising around animal protection and public-benefit work. In particular, serious concerns have been raised regarding whether publicly promoted animal protection efforts were presented in a way that failed to disclose the wider systems of inequitable growth that continued to undo those same efforts in practice.
This issue sits at the centre of the letters submitted to the University of Denver and to the Attorney General’s Office in Denver.
The purpose of these letters is not outrage for the sake of outrage. It is clarification. Transparency. Accountability. They seek to assess the standards used in public-facing animal law and animal protection programming, particularly where institutions represent outcomes to donors, investors and supporters as meaningful progress, while broader conditions may show worsening realities underneath the surface.
This is not a small issue.
If an institution claims success in protecting animals, but the surrounding systems continue expanding suffering faster than protections reduce it, then the public deserves to understand that reality honestly. If fundraising campaigns present isolated victories while larger structural growth continues driving exploitation, then those baselines must be disclosed clearly and openly.
Because outcomes matter more than narratives.
A quick assessment of broader trends during the relevant period raises difficult questions. Not only were more animals subjected to abuse and suffering than programming efforts were able to prevent, but wider indicators across society also showed increasing levels of human suffering, including rising child neglect, poverty and instability. These baseline failures are not confined to one field. They repeat across environmental policy, social systems, conservation, food reform and public-benefit campaigns whenever outputs are marketed as net success without proper disclosure of the surrounding conditions.
This is why transparency must become standard practice moving forward.
The public should know exactly where money goes. Investors should know whether goals are truly being achieved. Donors should know whether campaigns are producing measurable net improvements, or whether they are merely slowing damage while larger systems continue accelerating harm elsewhere.
Without honest baselines, progress can become an illusion.
This same issue can be seen far beyond universities or legal programs. Around the world, humans and wildlife are increasingly being pushed into conflict over shrinking resources. Forests disappear. Water systems collapse. Species vanish. Communities face hunger, displacement and instability. And as inequality deepens, more people are forced into survival-driven crime, exploitation and desperation.
Everything is connected.
If wildlife disappears, ecosystems collapse. If ecosystems collapse, human survival collapses with them. Nature is not separate from humanity. It is the foundation underneath all human life.
We cannot build a sustainable future while ignoring the systems driving destruction in the background.
That is why this moment matters.
The goal is not to attack good people trying to help. The goal is to create a higher standard — one built on truth, measurable outcomes and transparency. A standard where organisations no longer hide behind carefully crafted narratives while underlying realities worsen year after year.
Because the world does not need better marketing around compassion.
It needs courage.
It needs institutions willing to be honest about what is working, what is failing, and where reform is truly needed. It needs systems where funding reaches the ground effectively, where public trust is earned through measurable integrity, and where protecting animals, people and the planet becomes more than a slogan.
If we truly want a future where humanity and nature survive together, then accountability is not optional.
It is the beginning.
Letter ‘
February 11, 2026
Office of the Dean
University of Denver Sturm College of Law
2255 E. Evans Avenue
Denver, CO 80208
Re: Open Letter to the University of Denver, Sturm College of Law, Regarding Animal Law
Programming, Donor-Intent Governance, and Baseline Disclosure in Public “Impact” Claims
Dean Smith
Summary of requests
Within 14 days, provide a written response confirming whether any donor requested
return of funds connected to the Animal Activist Legal Defense Project and/or Animal
Law Programming, identify the gift instrument terms and any restrictions, and identify
the university office handling the request.
Within 30 days, provide an accounting of the relevant funds (amounts, dates received,
restrictions, expenditures to date), the policy basis for any decision to deny return, and
the decision authority.
Within 60 days, conduct and publish an internal review of the Project/Program’s public
impact statements to ensure they do not imply net benefit without disclosing baseline
variables and modeling limits, and adopt a written standard for future impact reporting in
this programming.
This letter is submitted to request institutional process and written clarification regarding the
standards used to assess and publicly represent impact in animal law programming and related
advocacy, based on information Fair Start activists received after terminating their role in the
programming. It is not a critique of intent, nor a dispute over values. It is an inquiry into whether
prevailing impact frameworks omit baseline variables in ways that may misstate net outcomes,
distort competition among advocates, and impede coordinated correction of known harm. This is
not infighting among advocates. It is a governance and public-reliance question about what is
being claimed, what is being measured, and what is being omitted.
Those engaged in upstream reforms cannot compete with actors who benefit from inequitable
growth dynamics while funding downstream advocacy and avoiding the implications of that
growth. This is a collective-action problem: the system rewards omission and penalizes
disclosure. That is why we are asking for institutional review and formal written answers rather
than informal discussion.
Core Issue Under Review: Whether “Impact” Claims are Bounded by Baseline Disclosure
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At the center of this concern is legitimacy. Public claims of value or impact are relative to what?
They either remain accurate once assessed in full context, or they do not. When institutions claim
public benefit while omitting legally relevant baseline variables, particularly those related to
growth, political equity, and the creation of future persons, those claims can become structurally
misleading even when program outputs are real.
The core issue is that the standards being used to assess and report “impact” can conflict with
fundamental human-rights norms and the preemptive basis of legal legitimacy. Institutions
should not imply net outcomes while omitting whether and how baseline variables are treated
and what the modeling limits are.
To evaluate public-benefit claims, Fair Start uses what we refer to as the XYZ test, a minimum
legitimacy check that asks whether public claims of value or impact (X) remain accurate once
assessed against baseline inequity impacts during the value assessment and impact reporting,
relative to children’s rights and political equity standards (Y), and the actual value and impact,
on balance in the key context, accounting for the correct baseline Y (Z). The point is not that any
single program controls all macro drivers. The point is that net-outcome implications should not
be implied without disclosing whether and how these baseline variables are treated, and what the
modeling limits are.
This presents an institutional governance issue. Where a law school supports or hosts
programming that invites public reliance (students, donors, and the broader community), the
standards used to describe “impact” must be stated with clarity, including any modeling limits.
Institutions should be cautious about lending professional credibility to impact narratives that
cannot survive full-context review, because institutional authority can become part of the
mechanism that normalizes and propagates claims that are not actually being substantiated as net
outcomes.
Legal and Compliance Context for Counsel Review (non-exhaustive)
This complaint is submitted to facilitate counsel review and internal escalation, not to litigate in
correspondence. The University can evaluate the issues raised here against existing legal and
compliance frameworks that already govern donor restrictions and public-facing representations,
including:
Donor restrictions and gift-instrument compliance for institutional funds under Colorado’s
Uniform Prudent Management of Institutional Funds Act (UPMIFA), C.R.S. § 15-1-1101 et seq.,
including provisions addressing release or modification of restrictions and Attorney General
notice in certain circumstances (see C.R.S. § 15-1-1106).
Standards governing deceptive or misleading public representations in trade or commerce under
the Colorado Consumer Protection Act, C.R.S. § 6-1-101 et seq., including deceptive trade
practices provisions (see C.R.S. § 6-1-105). The relevance here is the governance principle:
public statements that imply net outcomes should be bounded by disclosed assumptions and
limitations to avoid materially misleading reliance.
Baseline non-discrimination and political equity principles reflected in widely accepted
human-rights norms that legal educators routinely reference, including the International
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Covenant on Civil and Political Rights (ICCPR), particularly Article 24 (protection of children
without discrimination including by birth), Article 25 (equal suffrage and participation), and
Article 26 (equal protection and non-discrimination, including on grounds of birth).
Our relationship to the programming
As you know, members of the Fair Start Movement assisted in the co-founding and operation of
the school’s Animal Activist Legal Defense Project and assisted with teaching in the Animal
Law Program in roughly 2022, including participation in a key launch event that was recorded
and framed the intended work of the program as a matter of total liberation, including
environmental restoration.
We are writing now as part of the Fair Start “Tell the Truth” campaign – while we do not
represent the funders in any capacity, given our role in recruiting them for Sturm, we are
communicating information they shared with us.
The intent of our prior work with the school was, consistent with animal liberation and right to
rescue advocacy, to eventually end animal propertyhood at both a micro-level, through criminal
liability and food reforms, and at a macro-level through baseline-corrected family reforms
needed to ensure net outcomes are not reversed by upstream dynamics. A quick assessment
shows that not only were more animals subject to abuse and suffering during the relevant time
period than the programming was able to save, but more children were subject to abuse, neglect
and suffering than animals saved during that time.
The programming at Sturm formed in the wake of controversy around another animal protection
organization hiding historic liability for having used the lower standard for evaluating
animal/environmental policy. The media covered the baseline controversy explicitly. See:
https://www.newsweek.com/secret-war-natural-rights-children-opinion-1771365 and
Our recent research for litigation against Coca-Cola’s factory farming operations showed 5x or
more the damages if we account for illegal baselining/discounting, which makes public interest
interventions that also illegal baseline/discount a deadly charade: See
The macro framework is disfavored by funders because while food law and even criminal law
reforms can ensure good media that support existing entitlements and investments, the family
law and other reforms that the macro entails pose potential preemptive liability for value
assessments and impact reporting around micro, downstream-level interventions undone by
macro, upstream-level forces that illegally enriched some at deadly cost to others.
That macro framework was not speculative or external to the institution. It was developed and
publicly articulated in collaboration with University sustainability leadership, including
co-authored peer-reviewed work involving university staff identified in public materials as
Clinical Professor and Faculty Director, Center of Sustainability. Fair Start further understands
that, after an attempted implementation effort with University stakeholders, the professor
withdrew from participation.
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That was despite extensive peer-reviewed research that shows measurable birth-equity as a
preemptive legal standard, one that makes accounting for and offsetting birth positionality a
necessary part of academic neutrality and accurate research. The deadly costs of “separate but
equal” reproductive rights, versus “no child is worth more than another” will kill millions:
https://www.kff.org/racial-equity-and-health-policy/disparities-in-access-to-air-conditioning-andimplications-for-heat-related-health-risks/
Due to the role of key funders involved, who reject the need for assessing value and reporting
impact in the context of child inequity exacerbated by growth, and who reject macro-level
reforms that would treat measurable birth equity as a fundamental human right, we do not
believe the Project or Program ultimately met the macro goals originally contemplated.
We also understand that funders were aware of the larger context, including prior national
discussion condemning animal protection efforts that failed to account for countervailing impacts
of inequitable growth and birth-based political equity.
During the resulting schism, efforts were made to reframe Fair Start’s work as downstream
population activity rather than the upstream equity override it is. This included the elevation of a
partner organization that subsequently received a substantial grant and removed Fair Start-related
content from its public materials. The effect was to obscure the equity analysis originally
understood by all parties and to avoid confronting the legitimacy implications of the baseline
issue described here.
We are aware that Fair Start’s relationship to a professional funder complicated matters, and we
have since severed ties and are pursuing similar requests for reforms around conflicts of interest
standards before the Association of Fundraising Professionals to address the problem.
Our First Request: donor funds, donor intent, and remedy
We understand that at least one donor who supported the upstream, baseline-disclosure work
originally contemplated for this programming later requested return of funds after the upstream
framework was not implemented, and that the school declined. We request written confirmation
of:
● Whether a return request was made, by whom, and the date received
● The gift instrument terms (restrictions, purpose language, any conditions)
● The office and decision authority that denied or is evaluating return
● The policy and legal basis for denial (including any UPMIFA analysis)
Requested remedy
We request one of the following, in writing, with a dated implementation plan:
Return: full return of the relevant funds to the donor(s), with a closing accounting; or
Restricted reallocation: transfer of the relevant funds into a segregated, restricted
account used only for the upstream work that was originally contemplated and that
resolves the reliance issue at the center of this complaint, including:
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● Adoption of a written impact-reporting template (baseline disclosure + modeling
limits + outputs vs net outcomes)
● Internal review and correction/disclaimer of any public statements implying net
outcomes without disclosure
● Publication of a short standards memo describing the baseline used for any
impact language going forward
Escrow pending review: placement of the funds into escrow pending completion of the
60-day internal review and any required notice/review by appropriate oversight channels.
If the University asserts that return or reallocation is not feasible, we request a written alternative
resolution proposal that is functionally equivalent in integrity terms, including documentation of
constraints, responsible offices, and next steps.
Core disclosure standard requested (for institutional adoption)
We request adoption of a written standard for animal-law programming communications
that:
● States the baseline used for any impact language,
● Discloses modeling limits relevant to any net-outcome implications, and
● Distinguishes outputs (services performed, cases handled, rescues supported)
from net outcomes.
Campaign posture and standards pathway (non-punitive, process-driven)
This request is process-driven and non-punitive. The objective is early alignment on a
baseline (not “purity”), with a voluntary, pass/fail diagnostic standards pathway that
organizations and institutions can use to test whether their metrics and assumptions are
structurally coherent with their stated missions. The goal is documented governance,
donor-intent compliance, and corrective disclosure so that public reliance is not induced
by net-outcome implications the institution is not substantiating.
Illustration of the standard problem: institutional narratives and campaign dynamics
Baseline errors are not confined to any one domain. They recur wherever outputs are
narrated as net outcomes without disclosure. For illustration, we will be addressing these
same modeling issues in the context of Denver’s 2024 slaughterhouse ban effort
(Ordinance 309), where competing public-benefit claims in a high-salience context
illustrate why modeling limits and baseline disclosure matter.
Preemptive standards referenced
A central obstacle to reform is the collective action problem. Because major actors
depend on the same flawed impact standard, any institution that corrects it independently
can incur disproportionate reputational and competitive harm. Our response has been to
turn to state law and to legally preemptive standards that align public-benefit claims with
measurable empowerment and political equity.
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Continued use of prevailing standards for evaluating value and reporting impact out of
context misaligns legal obligations and the coercive power of the state from the objective
empowerment and self-determination of those subject to them.
These standards are outlined here:
● https://fairstartmovement.org/fair-start-today-moves-to-standardize-climate-dama
ge-evaluations-at-the-un-and-override-any-conflicting-standards/
● https://fairstartmovement.org/wp-content/uploads/2025/11/Fair-Start-MovementACPHR-Petition-3.pdf
● https://markets.businessinsider.com/news/stocks/fair-start-movement-urges-califo
rnia-attorney-general-to-recognize-full-justice-standard-as-preemptive-of-fraud-cl
aims-1035104323
● https://fairstartmovement.org/fair-start-and-truth-alliance-file-notice-of-preemptiv
e-standards-with-the-california-attorney-general/
Recent enforcement efforts, including Truth-in-Legitimacy compliance initiatives at the state
level, reflect the beginning of an effort to enjoin business models whose public-benefit claims
rely on these same flawed standards. These efforts operationalize the legitimacy principles
described above and are relevant to how institutions should evaluate and bound public-facing
impact claims.
Public representations at issue
We are specifically concerned with public statements and materials that could reasonably be read
as implying net benefit without disclosing baseline variables or modeling limits. For counsel
review and institutional handling, we request identification and review of the specific items
below:
“Supporting animal activists in their efforts to elevate awareness and understanding of
animal well-being”
“Developing best practices in the counseling and representation of activists,
whistleblowers, and investigators”
“Catalyzing a network of attorneys positioned to advance the welfare of non-human
animals”
“Exploring new and compelling narratives designed to elevate understanding of animal
suffering”
“Partnering with key stakeholders and supporters, including, without limitation,
plant-based and other humane producers, academic institutions, non-profit
organizations, labor activists, reformist professional associations, and environmental
organizations”
“Forging a more inclusive, populist, and activist-centered animal welfare movement.”
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“While the AALDP cannot agree to take cases without screening, we are eager to hear
from activists in need of our assistance. Please contact the AALDP.”
“Interested in working with the AALDP as a volunteer attorney? Please complete the
volunteer attorney sign-up sheet.”
That said, it is less about the claims, and more about the baseline numbers behind the claims, and
deviation from what would be accurate and legitimate accounting for illegal shifting of
costs/harms onto the most vulnerable.
Fair Start states the baseline-disclosure dispute is inseparable from donor intent and institutional
reliance because at least one donor has stated, “When I made my gift to Sturm in 2022, it was my
understanding that it would be used for an ecocentric baseline,” and Fair Start further states that
since January 2023 funders and institutional stakeholders have “doubled down on the
anthropocentric standard,” creating a material mismatch between what was reasonably
understood to be funded and what baseline governed “impact/public benefit/liberation”
representations.
Anthropocentrism is human-centered valuation; ecocentrism recognizes intrinsic ecosystem and
nonhuman value, and Fair Start’s position is that the University must state baseline choice
(including any turn to animal-centric and human-centric systems) with modeling limits because it
determines whether outputs are being narrated as net outcomes and can create downstream harm
when donors, students, and the public rely on implied net benefit. Funding for this effort rests on
a simple premise: the baseline must be explicitly defined, measured, and audited against
collective-action incentives, with specific protection for those most likely to absorb harm when
claims outpace evidence, including protected classes under civil-rights and anti-discrimination
law.
Fair Start states return requests have been made and should be treated as a reliance signal
requiring documented resolution, including Frank (A. F. Rothschild, PhD, Director, Center for
Contemporary Equine Studies) stating the institution should “either return CCES’s grant or
implement our funding for the designated purpose stated in our Agreement with DU Sturm, as
promised,” and requests written baseline clarity (promised vs applied), a full accounting, and a
written remedy of return, restricted reallocation to the designated baseline purpose, escrow
pending review, or a functionally equivalent integrity remedy.
Systems shouldn’t teach, assume, or operationalize legal authority unless there is measurable
empowerment of the people subject to that authority. Otherwise, we’re just automating “separate
but equal” under a technological veneer.
Fair Start’s model in Denver is that we don’t build new institutions, we require existing
institutions to replace non-compliant parts. The same logic would apply to AI governance. If the
language doesn’t invert toward “no child worth more than another,” it fails the baseline.
We propose a standardized reusable legal injunction mechanism triggered by
consumer-protection style action when a public-facing impact/benefit claim materially implies
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net benefit without disclosing the baseline and model limits pushing institutions and government
to either prove benefit under a stated baseline or correct the claim.
Our Second Request: participate in the Tell the Truth campaign and assess value and report
impacts in context.
Fair Start Movement and TruthAlliance.global offer a legitimacy-based framework grounded in
the principle that all facts are relative to values, and that value and impact claims either
constitute or deconstitute legitimate political systems relative to a legally required ideal of
measurable empowerment.
Participation in the Tell the Truth campaign, as it relates to the College of Law, would minimally
include:
● A public clarification distinguishing program outputs from net outcomes
● An updated impact-reporting template that discloses baseline variables and modeling
limits
● A non-punitive, voluntary pass/fail diagnostic standards pathway that can be used
● Internally to test structural coherence of impact language and underlying assumption
● A meeting hosted by the College where competing impact standards are evaluated in a
structured, evidence-based format
The fundamental driver is illegal baselining/discounting, and birth-inequity based growth that
enriches funders, but does more harm than good by the advocates’ and funders’ own professed
values – saving animals. Illegal baselining assumes children deserve what they are born with,
even as growth degrades their prospects, rather than what rights and political legitimacy require.
That said, we recognize that fundamental equity reforms are a collective action problem – so we
ask all as part of the Tell the Truth campaign to back the development and implementation of
model constitutional injunction to block illegal baselining in business models. If it’s illegal to not
hire persons of color, it’s illegal to enrich mostly white children at deadly cost to children of
color.
See:
https://markets.businessinsider.com/news/stocks/fair-start-movement-urges-california-attorney-g
eneral-to-recognize-full-justice-standard-as-preemptive-of-fraud-claims-1035104323
Unless a person or company claiming to add value to the world can show they were evaluating
and reporting by accounting for the preemptive costs of having to measurably empower all
children equitably as they enter the world—and at a standard where those children could protect
themselves from the climate crisis—the person or company making the claims was using an
illegal Ponzi/equity-fraud standard and benefiting at deadly cost to others, mostly children of
color.
Those willing to account for those costs, to legitimate political systems and engage in the most
just and effective reforms possible, cannot compete with those who do not – but they don’t have
to.
Total Liberation Colorado (TLC) Packet
Denver Institutional Complaint
8
Given the specific funders at issue, a fair application of the baseline would center on the
on-balance and birth-inequity / growth impacts on animals used in ejiao production, as well as
the vulnerable populations who rely on these animals and experience the related oppressive
impacts of the industry.
Systems shouldn’t teach, assume, or operationalize legal authority unless there is measurable
empowerment of the people subject to that authority. Otherwise, we’re just automating “separate
but equal” under a technological veneer.
Fair Start’s model in Denver is that we don’t build new institutions, we require existing
institutions to replace non-compliant parts. The same logic would apply to AI governance. If the
language doesn’t invert toward “no child worth more than another,” it fails the baseline.
Meeting request
To resolve these issues efficiently, we request a meeting with the appropriate University
representatives (College of Law leadership and the office(s) responsible for donor funds and
public communications for the relevant programming). Proposed agenda:
donor funds status, accounting, restrictions, and decision authority
the specific public impact statements identified above and what corrections/disclaimers are
needed
adoption of an impact-reporting standard for animal-law programming and next steps with dates
Conclusion
We encourage the University of Denver and the Sturm College of Law to address the donor
funds issue, to correct public representations where necessary, and to engage in the Tell the Truth
campaign by adopting an impact standard that does not omit baseline variables and that clearly
distinguishes outputs from net outcomes.
About FairStartMovement.org and TruthAlliance.global
Fair Start Movement and TruthAlliance.global are solution-focused, compliance-oriented
organizations. Our objective is to secure accurate disclosures, lawful handling of donor-restricted
funds, and governance processes that allow institutions to correct public-facing statements where
needed. Where an institution is willing to engage, we can provide structured documentation,
draft disclosure templates, and a defined process for separating outputs from net outcomes in
impact communications, with clear modeling limits suitable for counsel review and institutional
adoption.
Respectfully submitted,
Name: Suriya Khan
Email: suriya@fairstartmovement.org
Phone: 516 – 725 – 3157
Organization: Fair Start Movement / TruthAlliance.global
February 11, 2026
The Honorable Phil Weiser
Office of the Attorney General
State of Colorado
Colorado Department of Law
1300 Broadway, 10th Floor
Denver, Colorado 80203
Re: Request for Attorney General review and investigation concerning University of Denver
Sturm College of Law animal-law programming “impact/public benefit/liberation”
representations and donor-restricted funds governance (Total Liberation Colorado packet)
Dear Attorney General Weiser,
This letter is submitted as part of the Total Liberation Colorado (TLC) packet and requests
counsel review and Attorney General attention to an institutional complaint already submitted to
the University of Denver Sturm College of Law. The complaint concerns animal-law
programming and affiliated advocacy that publicly describes “impact,” “public benefit,” and
“liberation,” and raises governance and public-reliance issues where those public-facing
representations are made without baseline disclosure and where donor-restricted funds
governance is disputed. While we do not represent the funders in any capacity, given our role in
recruiting them for Sturm, we are communicating information they shared with us.
The Attorney General’s role is materially different from the University’s role. The University is
the institution whose public representations, donor-restricted funds governance, and internal
review mechanisms are at issue. The Attorney General is the State’s recognized protector of
charitable interests and charitable assets, with statutory and common-law authority regarding
trusts established for charitable, educational, religious, or benevolent purposes.
Factual Posture – Institutional complaint already filed
FairStartMovement.org and TruthAlliance.global have filed an institutional complaint with the
University of Denver Sturm College of Law requesting a written response and internal review
regarding: (a) how animal-law programming and affiliated advocacy assess and publicly
represent impact; and (b) whether public-facing claims distinguish program outputs from net
outcomes once baseline variables and modeling limits are disclosed.
Core disclosure issue (baseline disclosure and net-outcome implication)
The unifying issue is baseline disclosure: whether public impact language implies net
benefit without stating the baseline, disclosing modeling limits, and separating outputs
Total Liberation Colorado (TLC) Packet
Attorney General Complaint
1
(activities performed) from net outcomes (net effects once baseline variables are
counted).
For TLC purposes, this is operationalized as an “XYZ” minimum disclosure check:
X: the public claim of value and impact
Y: birth inequity impacts during the value assessment and impact reporting,
relative to children’s rights and political equity standards
Z: the actual value and impact, on balance in the key context, accounting for the
correct baseline Y
The point is not that any single program controls macro drivers. The point
is that solicitations should not imply a substantiated net-outcome claim if the
program is not stating its baseline, disclosing modeling limits, and separating
outputs from net outcomes in solicitation-facing materials and incorporated
public-facing materials.
Donor-intent dispute requiring a remedy the Attorney General is positioned to
supervise
Fair Start states that a donor who supported the originally contemplated upstream
baseline-disclosure work requested return of funds after the upstream framework was not
implemented, and that return was declined. The institutional complaint requests written
confirmation of: the request, the gift-instrument terms, the decision authority, and the
policy/legal basis for denial, and requests a remedy in one of these forms:
A) return of funds (with a closing accounting), or
B) restricted reallocation into a segregated account used only for the upstream
baseline-disclosure work originally contemplated (disclosure template adoption;
internal review and correction/disclaimer of public statements implying net
outcomes without disclosure; publication of a short standards memo describing
the baseline used going forward), or
C) escrow pending completion of the internal review and any required
oversight/notice steps.
Fair Start states the baseline-disclosure dispute is inseparable from donor intent,
charitable-asset governance, and reliance because at least one donor has stated, “When I
Total Liberation Colorado (TLC) Packet
Attorney General Complaint
2
made my gift to Sturm in 2022, it was my understanding that it would be used for an
ecocentric baseline,” and Fair Start further states that since January 2023 funders and
institutional stakeholders have “doubled down on the anthropocentric standard,” creating
a material mismatch between what was reasonably understood to be funded and what
baseline governed “impact/public benefit/liberation” representations. Anthropocentrism
is human-centered valuation; ecocentrism recognizes intrinsic ecosystem and nonhuman
value, and Fair Start’s position is that baseline choice (including any turn to
animal-centric and human-centric systems) must be stated with modeling limits because
it determines whether outputs are being narrated as net outcomes and can induce
downstream harm when the public relies on implied net benefit.
Funding for this effort rests on a simple premise: the baseline must be explicitly defined,
measured, and audited against collective-action incentives (donors, funders, government
dollars, students, voters, consumers, and future generations), with particular protection
for those most likely to absorb harm when claims outpace evidence, including protected
classes under civil-rights and anti-discrimination law.
Fair Start states return requests have been made and should be treated as a reliance signal,
including Frank (A. F. Rothschild, PhD, Director, Center for Contemporary Equine
Studies) stating the institution should “either return CCES’s grant or implement our
funding for the designated purpose stated in our Agreement with DU Sturm, as
promised,” and requests a written remedy of return, restricted reallocation to the
designated baseline purpose, escrow pending review, or a functionally equivalent
integrity remedy.
Systems shouldn’t teach, assume, or operationalize legal authority unless there is
measurable empowerment of the people subject to that authority. Otherwise, we’re just
automating “separate but equal” under a technological veneer.
Fair Start’s model in Denver is that we don’t build new institutions, we require existing
institutions to replace non-compliant parts. The same logic would apply to AI
governance. If the language doesn’t invert toward “no child worth more than another,” it
fails the baseline.
We propose a standardized reusable legal injunction mechanism triggered by
consumer-protection style action when a public-facing impact/benefit claim materially
implies net benefit without disclosing the baseline and model limits pushing institutions
and government to either prove benefit under a stated baseline or correct the claim.
Reliance and Governance Context (material to review)
Fair Start states that the upstream baseline-disclosure framework at issue was previously
developed and publicly articulated in collaboration with University sustainability leadership,
Total Liberation Colorado (TLC) Packet
Attorney General Complaint
3
including co-authored work involving university staff who were identified in public materials as
Clinical Professor and Faculty Director, Center of Sustainability, and that the staff member later
withdrew after attempted implementation with University stakeholders. Fair Start further states
that the dispute and the requested internal review should be analyzed as a governance and
reliance issue: the public is invited to rely on “impact/public benefit/liberation” narratives, while
the underlying baseline and modeling limits that determine whether outputs plausibly translate
into net outcomes are not disclosed.
Why Attorney General’s Office
Colorado recognizes and reaffirms the Attorney General’s powers regarding
charitable trusts and charitable interests – Colorado law expressly recognizes
and reaffirms that the Attorney General has powers conferred by statute and by
common law regarding trusts established for charitable, educational, religious, or
benevolent purposes. Colorado statutes also preserve the Attorney General’s
rights and powers with respect to any trust. Colorado appellate authority
describes the Attorney General as “the recognized protector of public interests in
charitable trusts,” and explains the enforcement structure that routes these
disputes to the Attorney General.
UPMIFA oversight features (restriction governance; notice to the Attorney
General in modification contexts) – If the disputed funds are governed as
donor-restricted institutional funds, Colorado’s UPMIFA framework provides
specific mechanisms for releasing or modifying restrictions and includes notice to
the Attorney General in court proceedings affecting restrictions, reflecting the
Attorney General’s participation interest where charitable restrictions are being
altered or addressed. The institutional complaint’s requested remedies (return,
restricted reallocation tied to the originally contemplated baseline-disclosure
work, or escrow pending review) are framed to align with orderly
restriction-governance analysis and documented authority, rather than informal
or discretionary handling.
Standing constraints and the enforcement gap the Attorney General fills –
Colorado appellate authority explains the structural point that private parties
commonly face standing barriers in charitable-trust enforcement and that the
Attorney General is positioned to act to protect the charitable interest. This
standing architecture is a principal reason this matter is properly routed to the
Attorney General for review and, where warranted, investigative action.
Consumer protection and public-reliance lens for materially misleading
“impact/public benefit” representations – Colorado’s Consumer Protection Act
includes deceptive trade practices such as false representations about
Total Liberation Colorado (TLC) Packet
Attorney General Complaint
4
characteristics, uses, or benefits and failures to disclose material information
known at the time of an advertisement or sale when intended to induce a
transaction. Separately, the Attorney General has statutory authority to
independently initiate actions to enforce state laws including the Colorado
Consumer Protection Act. In this matter, the relevant public-reliance concern is
whether institutional “impact/public benefit/liberation” representations invite
donor/student/public reliance while omitting baseline variables and modeling
limits that determine whether outputs plausibly constitute net outcomes.
Charitable representations and donor-protection context – Colorado’s
charitable solicitations framework reflects a public policy interest in protecting
the public from deceptive or fraudulent charitable solicitations and requires
registration and non-deceptive solicitation practices. While the TLC packet does
not presume a conclusion, it requests Attorney General review because the dispute
concerns donor-intent governance and public-facing representations tied to
charitable/educational programming where the public is asked to rely on
“impact/public benefit/liberation” framing.
Requests to the Colorado Attorney General (time-bound)
Intake and counsel routing (14 days), confirm in writing:
a. the office/division assigned for review; and
b. whether the Attorney General will request documents from the University
relevant to donor-intent governance and public-facing impact representations.
Donor-intent governance review and remedy pathway (30 days), request from the
University (and review for sufficiency):
a. the applicable gift instrument(s) and any written restrictions or purpose
language;
b. the return request(s) (date received; who submitted; what was requested);
c. the decision authority and documented policy/legal basis for denial (including
any UPMIFA analysis, to the extent applicable);
d. an accounting (amounts, dates received, restrictions, expenditures to date);
e. the University’s proposed remedy: return; restricted reallocation tied to the
originally contemplated baseline-disclosure work; escrow pending review; or a
documented alternative that is functionally equivalent in integrity terms.
Total Liberation Colorado (TLC) Packet
Attorney General Complaint
5
Public-reliance and impact-claim review (60 days), request that the University:
a. identify the specific public statements/materials most likely to imply net
outcomes without baseline disclosure;
b. submit those materials for counsel review; and
c. adopt a written disclosure template for future impact language that (i) states the
baseline, (ii) discloses modeling limits, and (iii) separates outputs from net
outcomes.
Enforcement
The TLC packet does not demand punishment for imperfection. It requests documented
governance, donor-intent compliance, and corrective disclosure so that public reliance is not
induced by net-outcome implications the institution is not substantiating. Fair Start states its
standards work is designed so organizations are not punished for imperfection, with an objective
of early alignment on a baseline (not “purity”) and a voluntary, pass/fail diagnostic standards
pathway that organizations can use to test whether their metrics and assumptions are structurally
coherent with their stated missions. This posture aligns with the Attorney General’s role as
protector of charitable interests and with the Attorney General’s authority to investigate and
enforce against materially misleading public representations when the facts warrant.
Attachments / packet materials referenced
Press release announcing TLC and summarizing the institutional complaint, including the
XYZ baseline-disclosure standard, donor-intent remedy request, and the requested
internal review.
Open letter to the University of Denver Sturm College of Law requesting time-bound
written answers, donor funds accounting, internal review, and adoption of an
impact-reporting disclosure template.
Copy of the Colorado Secretary of State complaint submission and supporting exhibits
(as included in the TLC packet).
Respectfully submitted,
Name: Suriya Khan
Email: suriya@fairstartmovement.org
Phone: 516 – 725 – 3157
Organization: Fair Start Movement / TruthAlliance.global
Total Liberation Colorado (TLC) Packet
Attorney General Complaint
6
REFERENCES
● Colorado Revised Statutes § 24-31-101 (Powers and duties of attorney general;
subsection recognizing/reaffirming AG powers re
charitable/educational/religious/benevolent trusts) (2024, as amended effective Jan. 1,
2025).
● Colorado Revised Statutes § 15-1-1005 (Rights and powers of courts and attorney general
not impaired).
● Colorado Revised Statutes § 15-1-1106 (Uniform Prudent Management of Institutional
Funds Act; release/modification of restrictions; notice/opportunity for Attorney General).
● Colorado Revised Statutes § 6-1-105 (Colorado Consumer Protection Act; deceptive
trade practices).
● Colorado Revised Statutes § 6-16-101 (Colorado Charitable Solicitations Act; short title).
● Colorado Charitable Solicitations Act, Title 6, Article 16, Colorado Revised Statutes
(compiled statutory PDF).
● Herbst v. University of Colorado Foundation, 2022 COA 38, No. 20CA2067 (Colo. Ct.
App. Mar. 31, 2022)
As the climate crises and inequality worsen, it’s crucial to look at the inaccurate public interest impact claims and business models that hid the horrors now unfolding.
Animal impact claims are often the most falsifiable, and culpable, in this regard.
If one were going to look for how the U.S. animal rights movement contributed to hiding of the polycrisis, as the movement became coopted by food investors, few would be as responsible as Rachel Atcheson.
A key aid to disgraced Mayor Adams, she has made wildly inaccurate claims about the environmental and other beneficial impacts of veganism, impacts that have been easily undone by child inequity and the disenfranchising growth that relies on it.
Despite all her talk, Atcheson’s impact on animal protection relative to the countervailing impacts of growth is negligible.
But why is she so problematic? The wealthy who threaten our future use people like Atcheson to hide the full negative impacts of their wealth, and in a place like New York City, that’s a big deal. In many ways she also represents how animal rights became monetized as a food industry, at a time when inequitable growth has put more animals into suffering than ever before, and New York is undergoing unprecedented inequality and commercialization. For people who want to on balance benefit animals, selling out is one of the worst things one can do.
Real animal activists could never compete against those, like Atcheson, who are willing to be part of a system that does more harm to animals than she does good. And they need not compete – because the model she uses is probably illegal.
Fair Start and TruthAlliance.global are now going beyond her claims, and asking whether she and Adams used an illegal business model to hide the worst impacts of the climate crisis, the decline of democracy, and vast inequity.
Our research shows equity fraud (the discounting of future lives, and disenfranchisement of persons of color in particular) has been the largest driver of the terrible harms caused by factory farm entities like JBS. The state’s recent settlement with JBS raises questions about the standards state officials use with regard to that driver.
Did Atcheson, a vocal animal rights activist and opponent of factory farming, use the same fundamental metric as JBS to exploit future children? Even as that drove more animals into suffering than her work took out? Time and further research will tell.
Take action: Urge Atcheson here to start the process of truth and admit that her work ignored inequitable growth in a way that did more harm than she did good. How much harm remains to be seen, but she can at least right now dispel any illusion of helping animals on balance or accurately accounting for inequity. In the future Fair Start activists will be testing her support for a preemptive legal standard that would reorganize basic entitlements to elevate animal protection, as well as other key values. That test will show whether she cares about animals, or is still shilling for food investors.
