David C Vigilante
CNN
Worldwide

June 10. 2020

Sent Via Electronic Mail

Donald J Trump for President, Inc

Re: CNN POLL

Dear Ms. Ellis,
This responds to your letter dated June 9, 2020.

To my knowledge, this is the first time in is 40 year history that CNN
had been threatened with legal action because an American politician or
campaign did not like CNN's polling results.

To the extent we have received legal threats from political leaders in
the past, they have typically come from countries like Venezuela or other
regimes where there is little or no respect for a free and independent
media.

CNN is well aware of the reputation of John McLaughlin and McLaughlin 
Associates. In 2014 his firm famously reported that Eric Cantor was
leading his primary challenger Dave Brat by 34 points only to lose by 11
points -- a 45 point swing. The firm currently has a C/D rating from
FiveThirtyEight.

In any event, McLaughlin was able to evaluate and criticize CNN's most
recent poll because CNN is transparent and publishes its methodology
along with its polling results. Because of this, McLaughlin was free to
publish his own critique of CNN's analysis and share his criticisms
across the U.S. media landscape. That's how free speech works. It's the
American way.
Your letter is factually and legally baseless. It is yet another bad
faith attempt by the campaign to threaten litigation to muzzle speech it
does not want voters to read or hear. Your allegations and demands are rejected in their
entirety.

Very Truly Yours,

David C. Vigilanta

cnn.com