WEST VIRGINIA LEGISLATURE PASSES BALLOT ACCESS BILL

On April 11, the West Virginia legislature passed HB 2981, which makes two improvements in the ballot access laws for minor party and independent candidates. The bill lowers the number of signatures from 2% of the last vote cast for that office, to 1%. Also it moves the non-presidential petition deadlines from mid-May to August 1. Governor Joe Manchin’s office has indicated informally that the Governor expects to sign the bill when it reaches him.

There are no statewide offices on the West Virginia ballot in 2010; the most important office up is U.S. House. But for 2012, the number of signatures for president will now be 7,134 signatures, instead of 14,268.

Importance of the Deadline Change

West Virginia was the first state in the nation to impose an independent candidate petition deadline as early as the spring of an election year. That action was taken in 1919, and it has plagued minor party and independent candidates for 90 years. The 1919 legislature moved the deadline, in presidential election years, from October to May.

On July 4, 1924, U.S. Senator Robert La Follette announced that he would run for president as an independent, with the label "Progressive." West Virginia was the only state in which his ballot position was threatened because he had missed a deadline. The Secretary of State at the time, Houston G. Young, simply said the law wasn’t clear and accepted the La Follette petitions anyway. See the New York Times, July 19, 1924, page 2. Young said, "It will be up to someone else to get their names off." The Attorney General, E. T. England, said, "No decision had been asked for and until one is requested, none would be given." So, La Follette appeared on the ballot despite having missed the deadline.

Nevertheless, the early deadline remained on the statute books. In 1937 the deadline problem was made even worse by a new law that said a declaration of candidacy must be filed 30 days before the petition deadline. Between 1937 and 1979, no minor party or independent candidates for any statewide office were able to qualify in West Virginia, except for two presidential candidates, Henry Wallace in 1948, and George Wallace in 1968. Both men had started their campaigns in the odd year before the election year, so they were prepared for West Virginia’s early deadline.

In 1983, the U.S. Supreme Court ruled that early deadlines for independent presidential petitions are unconstitutional, so in 1984 the Secretary of State accepted petitions until September 1, ignoring the statutory deadline. In 1986 the legislature moved the presidential petition deadline to August 1, but did not relax the deadline for candidates for other office. Lawsuits to overturn the May petition deadline were filed by the Socialist Workers Party in 1988, and also by the Libertarian Party in federal court in 1992, and by the Libertarians in state court in 2004, but all three lawsuits lost.

The May petition deadline for office other than president has had a devastating effect on the ability of minor parties to get gubernatorial candidates on the ballot. In 1992, the Libertarian Party qualified for president, but not for its gubernatorial candidate, Karl Hess. In 1996, the Reform Party got its presidential candidate on the ballot, but not its gubernatorial candidate, Floyd Fullen. In 2004, the Libertarian Party got its presidential candidate on, but not its gubernatorial candidate, Simon McClure. And in 2008, the Constitution Party’s presidential candidate qualified, but its gubernatorial candidate, Butch Paugh, did not.

Reduction in Signatures

The decrease in the number of signatures from 2% of the last vote to 1% is also very helpful. West Virginia required 1% petitions between 1932 and 1999, but doubled that to 2% in 1999. The reason the legislature doubled the petition requirement in 1999 was that it was simultaneously making it legal for primary voters to sign an independent or minor party petition. The ban on both voting in the primary and signing a petition had existed since 1915.

The only 2% presidential petitions that ever succeeded in West Virginia were the 2004 Nader and Libertarian presidential petitions, and the 2008 Nader and Constitution Party presidential petitions. In 2000 the 2% requirement was enjoined (for 2000 only) by a court on the grounds that the 1999 change from 1% to 2% violated due process, because the increase went into effect in the middle of the 2000 petitioning period.

West Virginia ballot access laws are still far from ideal. West Virginia is one of eleven states in which it is impossible for a group to become a qualified party in advance of any particular election. Most states have a procedure (usually a petition, or a registration drive) that makes it possible for a group to turn itself into a qualified party, any time it wishes. But in West Virginia and ten other states, there is no such procedure. Instead, a group must get its nominee on the ballot for some particular office, and then hope that nominee polls enough votes to satisfy the vote test. Only then does it become a qualified party. The West Virginia vote test is 1% for Governor.

The only parties besides the two major parties that have been qualified parties in the last 70 years have been the Mountain Party, continuously since 2000, and the Libertarian Party between 1996 and 2000.

On April 20, the Oklahoma Senate unanimously passed HB 1072, which lowers the petition for a previously unqualified party from 5% of the last vote cast, to 3% of the last gubernatorial vote.

The bill had previously passed the House, but the House version was 5% of the last gubernatorial vote. Therefore, the bill must go to a conference committee in early May.

The existing Oklahoma law requires 73,134 signatures for a party in 2010, a higher number of signatures than that of any state except for California (88,991 registrations) and North Carolina (85,379 signatures).

If the Oklahoma bill becomes law at 3% of the last gubernatorial vote, the 2010 and 2012 requirement will be 27,794 signatures. Oklahoma would still have the highest percentage of any state for a mandatory petition to recognize a party (except that Oklahoma would be tied with Alabama, which also requires 3% of the last gubernatorial vote).

If the Oklahoma bill becomes law at 3%, no state will have a mandatory statewide ballot access petition for either minor parties or independents greater than 3% of the last gubernatorial vote. That would be the first time since 1921 that no state had a statewide mandatory petition in excess of 3% of the mid-term vote. Nevada had a 10% petition between 1921 and 1925, and a 5% petition between 1925 and 1987.

The April 1 B.A.N. had reported that the Pennsylvania Supreme Court had agreed to re-hear the Green Party 2006 case on whether the party’s candidate for U.S. Senate must pay the costs of removing him from the ballot. On April 16, the Pennsylvania Supreme Court said it would also re-hear the similar case for Ralph Nader that originated in 2004.

On April 22, Ohio Secretary of State Jennifer Brunner released her ideas for election law changes. For the petition to qualify a party, she recommends a requirement of one-fourth of 1% of the last gubernatorial vote. For 2010, that would be 10,057 signatures. She also recommends a new vote test, that a party remain on the ballot if it had received at least 1% for any statewide race at either of the last two elections.

However, she recommends keeping a very early petition deadline for new parties, of 90 days before the primary. This is because the Ohio Constitution says that all qualified parties must nominate by primary. The Ohio primary in presidential election years is in March, so the deadline in presidential years would be in December of the year before the election. In midterm years the primary is in May, so the deadline would be in February.

Her report has a footnote, "There has been some discussion of modifying the Ohio Constitution to allow nomination via convention for minor and intermediate parties. This very significant change in elections procedure requires greater study before the Secretary of State can make a final recommendation for or against altering the Ohio Constitution."

No legislator has yet introduced a bill on this subject.

On April 21, the Constitution, Green and Libertarian Parties finally filed the federal lawsuit against Pennsylvania that has been planned for two years. Constitution Party of Pennsylvania v Cortes, 09-1691, eastern district. The case was assigned to Judge Thomas Golden, a Bush Jr. appointee. The case attacks the unique Pennsylvania practice of charging candidates for the costs of removing them from the ballot, if their petitions are shown not to have enough valid signatures.

Ever since the U.S. Supreme Court invalidated poll taxes in 1966, there has been a presumption that states cannot require voters to pay money in order to engage in electoral activity. This principle is based on the Equal Protection Clause.

In 1972 the U.S. Supreme Court invalidated Texas mandatory filing fees for candidates (amounting to as much as $8,000), even though the plaintiff-candidates were not indigent. In 1974 the Court invalidated mandatory California fees (of as much as $700) for candidates, at least for candidates who couldn’t afford them. In 1994, a U.S. District Court invalidated North Carolina’s 5 cents per signature fee for checking ballot access signatures for new parties, and in 1992 the 11^th circuit invalidated Florida’s 10 cents per signature fee for checking signatures. In 1995, the 8^th circuit ruled that states can’t force parties to pay for the costs of their primaries, if the state mandates that parties nominate by primary.

Logically, therefore, one can argue that Pennsylvania can’t charge candidates for the costs of checking their signatures. Pennsylvania began this practice in 2004, when it said Ralph Nader had to pay court costs of over $80,000, since the outcome was that he didn’t have enough valid signatures. Pennsylvania did this again in 2006, concering the the Green Party’s statewide petition, and again the costs were over $80,000.

Nader and the Greens have tried to persuade state courts that the U.S. Constitution forbids imposition of these costs, but the state courts ignore the argument and do not even discuss it in their opinions. The recent willingness of the Pennsylvania Supreme Court to reconsider these fees is based on recent evidence of law-breaking by the people who challenged the Nader and Green petitions. There is no sign that the Pennsylvania Supreme Court is any more interested in the constitutional argument than it had been in the past.

The lawsuit also challenges the failure to tally write-in votes, and the 15% registration test for a party to be on the ballot automatically.

Since the April 1 B.A.N., bills to establish the National Popular Vote Plan for presidential elections have passed the Washington legislature, the Nevada Assembly, and the Rhode Island Senate Judiciary Committee. However, the Arkansas bill that had passed one house failed to pass in the other house before the legislature adjourned.

Delaware: B.A.N. recently learned that in 2008, a law was passed that creates a write-in declaration of candidacy procedure. These laws say that write-ins are only tallied for candidates who file a declaration of write-in procedure, in advance of the election. Delaware is the 36^th state to have such a law. The new law is found in section 3401 of the election code. The deadline for the declaration is September 30.

Maine: most of the contents of LD 547 (the bill to improve conditions for write-in candidates) have been amended into LD 1169, the Secretary of State’s election law bill. LD 1169 is still in committee because other election law amendments are still being added to that bill.

Alabama: HB 711 has passed the House and the Senate policy committee. It would let overseas absentee voters use the internet to vote. Terminals would be set up in places like large U.S. military bases in Germany and Okinawa.

California: AB 1121 would let ten general law cities or counties use Instant Runoff Voting for their own elections. The bill does not specify which ten jurisdictions; it would be up to various counties or cities to volunteer. It passed the Assembly Elections Committee on April 21.

AB 1396 would repeal the election laws that tell the Democratic Party how to organize itself. It has its first hearing on May 5 in the Assembly Elections Committee.

Illinois: HB 723 passed the House on April 2. It virtually ends the ability of qualified parties to nominate by committee, after the primary, in cases in which no one had run in that party’s primary. The bill would still allow the practice, but would require candidates nominated by committee after the primary to submit a petition of 5% of the last vote cast (or 25,000 signatures, whichever was less). Already Illinois legislative races have only one person on the general election ballot in about half the races, and this bill, if enacted, will shrink the number of candidates even further.

Even the Democratic and Republican Parties nominate many candidates by committee after the primary. The bill also hurts the Green Party, the only other ballot-qualified party.

Minnesota: SF 1820 and HF 2052 would set guidelines for cities and counties that wish to use Instant Runoff Voting for their own elections.

New Hampshire: on April 22, the legislature passed HB 35, to eliminate the vice-presidential primary. No other state has a vice-presidential primary. Generally, no one who really has a chance to be chosen by a major party for vice-president ever files in this primary.

New Mexico: on April 7, Governor Bill Richardson signed SB 3, which repeals the requirement that candidates for partisan county office, or for state executive positions that are elected in districts, need any signatures to get on the primary ballot.

North Carolina: on March 19, Senator Jim Jacumin (R-Connelly Springs) introduced SB 731. It reduces the number of signatures for a new party, and a statewide independent, from 2% of the last gubernatorial vote, to 10,000 signatures.

Oklahoma: both houses of the legislature have passed bills making it easier for initiatives to get on the ballot. However, both need to go to conference committees. SJR 13 lowers the number of signatures for initiatives in midterm years. SB 852 expands the petitioning period from 3 months to one year.

Oregon: on March 31, the House passed HB 2414 by a margin of 52-8. It legalizes fusion. A candidate nominated by two parties would have both party names, separated by a comma, after his or her name on the ballot. However, there would be only one checkbox, so the voter could not choose which of the two parties to support.

Pennsylvania: the ballot access improvement bill in the Senate, SB 252, has not made any headway because Senator Charles McIlhenny (R-Doylestown), chair of the State Government Committee, has not scheduled a hearing for the bill. Activists are working hard to persuade him to hold such a hearing.

South Carolina: bills to make ballot access much more difficult for independent candidates are pending in each house. They are HB 3746, which passed the House Judiciary Committee on April 22, and SB 590. They would make it illegal for primary voters to sign for an independent candidate; they would make it illegal for newly-registered voters to sign for an independent candidate; and they would require independent candidates to file a declaration of candidacy in February.

Texas: the ballot access bill, HB 820, has a hearing on April 27. The bill reduces the number of signatures for minor parties and independent candidates.

Utah: on March 24, Governor Jon Huntsman signed SB 27 into law. Among other things, it ends the law that requires independent presidential candidates to submit their signatures in person. Also it establishes an August 15 deadline for independent presidential petitions. The old deadline had accidentally been repealed in 1994, but the Elections Office had been accepting such petitions up until September 1, in the absence of a valid law.

Washington: on April 22, the legislature passed HB 1517. It lets ex-felons who still haven’t finished paying off any fines or restitution payments register to vote.

Gur Bligh has published "Extremism in the Electoral Arena: Challenging the Myth of American Exceptionalism" in the Brigham Young University Law Review, no. 5, 2008. The 74-page article has some original and important ideas about U.S. election law.

The United States prides itself on its legal protection for the expression of all ideas, even unpopular ideas. However, Bligh points out that the U.S. is actually less permissive than the ordinary democratic nation, when it comes to letting unpopular ideas circulate in election campaigns. The U.S. restricts unpopular ideas in election campaigns by (1) making ballot access and debate access difficult for minor parties and independent candidates; and (2) by permitting the two major parties to exclude such candidates from major party primaries, based on their ideas.

The article quotes Erwin Chermerinsky on viewpoint neutrality: "The Court’s conclusion that the government’s decision (upholding exclusion of an independent candidate from a debate sponsored by public TV) was viewpoint neutral was essential to the result. But what causes a candidate to be from a minor, rather than a major, party? The answer, of course, is that a minor party candidate’s views are favored by a much smaller percentage of the population than those of a major party candidate. From this perspective, choosing whom to include in a debate based on whether they are from a minor or a major party is all about viewpoint."

Many observers of politics believe that anyone can run in a major party primary. This is not true, as Bligh shows. The article deserves to be widely read.

Bills in Congress for public funding of congressional candidates are S752 and HR1826. They treat all candidates equally, regardless of party.

During the summer of 2008, Senator John McCain seriously considered asking Senator Joe Lieberman to be his running mate, although ultimately Governor Sarah Palin was chosen. During April 2009, the head of John McCain’s search committee for vice-president said that a major reason Lieberman wasn’t chosen was that West Virginia would not have permitted Lieberman’s name to appear on the ballot, since Lieberman was a registered Democrat.

The head of John McCain’s search team, A. B. Culvahouse, is a prominent attorney in Washington, D.C. He was President Reagan’s attorney while Reagan was president. Culvahouse made statements both in an e-mail interview of April 14 with a student, Cadet Robert G. Hall of West Point, and in a talk to a group of Republican Party attorneys that was broadcast on C-SPAN on April 17. In the Hall interview, the question put to Culvahouse was, "What played the largest role in Senator McCain’s preference of someone else as his vice presidential nominee over Senator Lieberman: a desire to reunite the Republican Party, ballot balancing, concerns of a presidential succession, or something else?" Culvanhouse’s answer was, "The ballot access issue was very problematic."

West Virginia law, sec. 3-5-7(6), says that someone running in a primary election, or petitioning for the general election, must sign a form that says the candidate "is a member of the party and affiliated with that political party, as evidenced by the candidate’s current registration as a voter affiliated with that party, and that the candidate has not been registered as a voter affiliated with any other party for a period of 60 days."

However, West Virginia has never applied this law to presidential or vice-presidential candidates in November. Such candidates don’t even fill out a declaration of candidacy form.

Many presidential and vice-presidential candidates have appeared on the West Virginia November ballot since this law was enacted in 1991, who could not have complied with the law if it did pertain to them. Candidates such as Al Gore, George H. W. Bush, George W. Bush, Ross Perot, Harry Browne, and Bill Clinton lived in states in which the registration form doesn’t ask about party membership (Arkansas forms do ask, but they didn’t ask in the 1990’s).

Also, candidates that do live in states with voter registration have appeared on the West Virginia ballot even though their registration didn’t match their party label. John Hagelin was a registered independent but he appeared on the West Virginia ballot as the Natural Law Party nominee in 2000. Ralph Nader was a registered independent but he appeared on the West Virginia ballot in 2000 as the Green Party nominee. Cynthia McKinney and Rosa Clemente were registered Greens but they appeared on the West Virginia ballot as Mountain Party nominees.

The chart below lists each state, and tells the most recent year when that state’s legislature voluntarily made a significant improvement in the ballot access laws for minor parties or independent candidates. "Voluntarily" means the legislature passed a bill, even though no court had struck down a previous law.

The vast majority of states have voluntarily improved some aspect of the ballot access laws during the last 25 years, which should give hope to activists working for better laws.

Not all of the improvements listed in this chart are necessarily still in effect. Some of them were repealed. For instance, the Illinois 1927 improvement was repealed in 1931. Also at least one of the improvements (the Alabama example in 1977) was an accident, caused by an error in drafting a bill. However, Alabama didn’t change it for five years.

STATE	YEAR	WHAT WAS THE IMPROVEMENT?
Alabama	1977	Eliminated the petition requirement for new parties to get on the ballot
Alaska	1997	Added an alternate registration test for parties to remain ballot-qualified, besides the vote test
Arizona	2006	Decreased the number of signatures for a new party in mid-term years
Arkansas	2009	Expanded the petitioning period for new parties and independent candidates from 60 to 90 days
California	1976	Eased the independent candidate petition requirements
Colorado	1998	Eased the definition of political party, from 10% vote for Governor, to having 1,000 registrants
Conn.	1994	Eased the number of signatures for a statewide minor party or independent candidate
Delaware	1978	Eased the new party procedures from a 1% petition, to having registration of one-twentieth of 1%
D.C.	1999	Said all qualified parties are also qualified to be on for president
Florida	1999	Eased the definition of party from a group with registration of 5%, to any group with officers
Georgia	1986	Created a 1% petition procedure for groups to be qualified (but only for statewide office)
Hawaii	1999	Lowered the party petition from 1% of the number of registered voters, to one-tenth of 1%
Idaho	1985	Decreased the party petition from 3% of the last presidential vote, to 2%
Illinois	1927	Eliminated the petition requirement for new parties to be on the ballot
Indiana	1977	Eliminated the need to notarize each signature on a ballot access petition
Iowa	1993	Lowered the petition for minor party and indp. candidates for U.S. House from 2% to 300 signatures
Kansas	1984	Lowered the petition for new parties from 3% of the last gub. vote, to 2%
Kentucky	2005	Eliminated the law that federal candidates must file a declaration of candidacy in April
Louisiana	2004	Eased the definition of political party from registration of 5%, to 1,000 registered members
Maine	1999	Eased the definition of political party, so that 5% vote test only needs to be met once every 4 years
Maryland	1998	Lowered the independent candidate petition from 3% of registered voters, to 1%
Mass.	1991	Lowered the minor party and indp. candidate petition from one-half of 1%, to 10,000 signatures
Michigan	2004	Eased definition of party, from 1% vote for candidate at top of ballot, to 1% for any statewide office
Minnesota	2002	Eased definition of party, so that 5% vote test only needs to be met once every 4 years
Miss.	- - -	never
Missouri	1993	Created a 10,000 signature petition procedure for a group to become a qualified party
Montana	1999	Lowered the party petition from 5% of the gubernatorial winner’s vote, to 5,000 signatures
Nebraska	1969	Eased ballot access for new parties from a meeting of 750 attendees, to a petition of 1% of gub. vote
Nevada	1999	Created a 250-signature petition procedure for statewide nominees of unqualified parties
N.Hamp.	1996	Created a 3% of the last gub. vote petition procedure for a group to become a party
N Jersey	1893	Eased the vote test for a party to remain on the ballot from 5% of the total Assembly vote, to 2%
N Mexico	1983	Lowered the minor party nominee petition from 3% of the last vote cast, to one-half of 1%
New York	1992	Lowered the statewide minor party & indp. candidate petition from 20,000 to 15,000 signatures
No. Car.	2006	Lowered the vote test for a party from 10% for President or Governor, to 2%
No. Dak.	2005	Expanded the vote test from 5% for President or Governor, to also several other statewide offices
Ohio	1929	Created a 15% of the last gub. vote petition procedure for a group to become a qualified party
Oklahoma	1924	Created a 5,000 signature petition procedure for a group to become a qualified party
Oregon	2001	Added an alternate registration test for parties to remain ballot-qualified, besides the vote test
Pennsyl.	1893	Eased the vote test for a party, from 3% of the top vote-getter’s total, to 2%
Rhode Is.	1994	Created a 5% petition procedure for a group to become a qualified party
So. Car.	- - -	never
So. Dak.	1993	Eased the vote test for a party from 10% for Governor, to 2.5%
Tennessee	2000	Let candidates who used the independent procedure have a party label, for the 2000 election only
Texas	1987	Expanded the vote test from 2% for Governor, to also 5% for any other statewide race
Utah	1983	Deleted the county distribution requirement for party petitions
Vermont	1977	Eliminated the mandatory petition for minor party nominees, if that party had 10 town committees
Virginia	1998	Lowered statewide minor party or indp. petition from one-half of 1% of registration., to 10,000
Wash.	2001	Eased the minor party or indp. presidential petition deadline from July to August
W. Va.	2009	Eased the minor party or indp. petition from 2% of the last vote, to 1%
Wisconsin	1983	Eased the party petition from one-sixth of voters in any 10 counties, to 10,000 signatures
Wyoming	1998	Eased the party petition from 8,000 signatures to 2% of the last U.S. House vote (about 4,000 sigs.)

On April 7, Illinois held an election for the U.S. House seat, 5^th district. The results: Mike Quigley, Democrat, 69.24%; Roseanne Pulido, Republican, 24.17%; Matt Reichel, Green, 6.60%. In November 2008, the vote had been: Dem. 73.94%, Rep. 22.04%, Green 4.02%.

Some minor party members were elected to non-partisan office on April 7:

Green winners in Wisconsin: Tony Palmeri and Bob Poeschel to the Oshkosh Common Council, Satya Rhodes-Conway to the Madison Board of Alderpersons, Marsha Rummel to the Dane County Council, and Jo Ellen Gramling was elected Town Clerk of Schleswig.

Green winner in Illinois: Bruce Samuels to the Oak Park Library Board.

Libertarian winners in Missouri: Mike Ferguson to the Grandview city council, and Robert Stephens to the Springfield city council.

New Jersey and Virginia elect their governors this year. In Virginia, the only minor party or independent candidate for Governor is Gail Parker of the Independent Green Party.

In New Jersey, the Libertarian, Socialist, and Socialist Workers Parties have nominees. Also one prominent independent candidate has announced: Christopher Daggett, a former regional director of the U.S. Environmental Agency under President Reagan.

On March 27, the Rhode Island media said that former U.S. Senator Lincoln Chafee will be an independent candidate for Governor in 2010. On April 10, California media reported that Guess Jeans founder Georges Marciano will run as an independent for California governor.

The Arizona Libertarian Party is mostly finished with a registration drive, so as to retain its spot on the ballot. Since it didn’t poll 5% for president in 2008, it must have registration of at least two-thirds of 1% by November 1, 2009. The party’s registration is now up to .65%, so it is almost finished. The Alaska Libertarian Party is also working to increase its registration for the same purpose. It has about 6,500 registrants, but needs 9,786 in order to remain on the ballot.

The Constitution Party is petitioning for party status in Wyoming. It has 300 signatures and needs 4,981 by June 1, 2010. The party has never been on the Wyoming ballot as a party before. The Constitution Party is also just launching its Arizona petition drive. It needs 20,449 signatures by March 2010. The Constitution Party is also about to start in Hawaii; it needs 692 signatures by March 2010.

On March 19, the Federal Election Commission ruled 5-1 that the Socialist Workers Party need not report its campaign contributors, or its expenditures. This new exemption from campaign reporting extends through the 2012 election. The SWP has enjoyed such an exemption continuously since the early 1980’s, on the grounds that the record shows that people identified as SWP supporters have been subject to severe harassment, both from government agencies and from members of the public.

Former U.S. House member Virgil Goode will be one of the speakers at the Constitution Party’s national committee meeting on June 11-13 in Newark, New Jersey. Goode represented Charlottesville, Virginia, first as a Democrat, later as an independent, and later still as a Republican. He was narrowly defeated for re-election in 2008.

---

SUBSCRIBING TO BAN WITH PAYPAL

If you use Paypal, you can subscribe to B.A.N., or renew, with Paypal. If you use a credit card in connection with Paypal, use richardwinger@yahoo.com. If you don't use a credit card in conjunction with Paypal, use sub@richardwinger.com.