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.
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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
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(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
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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,
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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)