B-212235 May 23, 1984

B-212235 May 23, 1984

The Honorable Don Bonker Chairman, Subcommittee on International Economic Policy and Trade Committee on Foreign Affairs House of Representatives

Dear Mr. Chairman:

We refer to our letter to you, B-212235, November 17, 1983, that responded to your request for a ruling on whether an article published in the Commerce Department's May 30, 1983, issue of Business America violated statutory restrictions against lobbying with Federal funds. We concluded that it did constitute a violation.

You also requested us to determine who was responsible for the publication of the article. We reported that we had spoken informally with Mr. Douglas F. Carroll, the editor of the periodical, who indicated that he submitted that issue to Assistant Secretary for Trade Administration, Mr. Lawrence J. Brady and that Mr. Brady had approved publication of the issue containing the prohibited material. On the basis of Mr. Carroll's statement, we concluded that it appeared that Mr. Brady was responsible.

We have subsequently determined that Mr. Brady was not responsible for the publication. Accordingly, we want to correct the record to reflect that Mr. Brady was not responsible. The Department of Commerce determined that Ms. Paige Sullivan, the author of the article, Mr. Douglas Carroll, the editor of the periodical and Ms. Bonnie Whyte, the Director of Public Affairs for the International Trade Administration, shared responsibility for the publication of the article.

Sincerely yours,

Harry R. Van Cleve Acting General Counsel