Mass, Computer-Generated, and Fraudulent Comments

This project seeks to identify agency best practices for handling mass, computer-generated, and fraudulent comments in rulemakings. Treating each type of comment separately, it examines both the legal and practical issues associated with processing and responding to such comments. It also considers whether there are certain types of rulemaking proceedings where such comments are especially likely to pose particular problems; what remedies are available to agencies in handling such comments; and how agencies might promote transparency, integrity, and consistency in their procedures for addressing such comments.


Committee Chair
Cary Coglianese
Edward B. Shils Professor of Law
University of Pennsylvania Law School
Staff Counsel
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