Reference: FEC Letter February 25, 2014 
Re: C00428516 

I have received your February 25 2014 letter regarding our July-December 2013 report. I am not aware of your calculations nor calculations technique, so I don''t know how any variance is possible.

I am not aware of any errors of any kind. We operate on a cash accounting basis and recognize revenues when either autotransferred via a internet portal or when they are physically deposited. Federal reports are run per manadated schedule.

We utilize a automated accounting system called Compelte Campaigns. It is a closed system that carries a cycle to date and a year to date field. Therefore, any filing has an automatically corrected and updated year to date field. Therefore, there cannot be any reporting that moves from one cycle to another, requiring an amended report. 

I am not aware of any bank delays or technology issues that would cause revenues to wash from one reporting period to another. Therefore, I deny that any revenues or expenses are not correct in any period. They are correct per my knowlewdge and belief.

Therefore, I have no logical or legal basis to change any report since I have no reasonable basis to do so. 

Since every FEC report has a year to date column, I maintain that the year to date column will always be right and self correcting.   

Accordingly, I have no logical basis to make any amendments.

John A. Gordon
619 379-5561 (voice)
email: jgordon@pacificmanagementconsultinggroup.com