The Myers campaign challenges the validity of these criteria on the grounds that they either failto provide concrete thresholds for their metrics, or they cannot be proven in this case all. Wecontend that WFAA has arbitrarily chosen the candidates and even altered its criteria after thefact to accommodate a particular candidate. Below is our discussion of each item individually.Polls - Independent public opinion polls cannot be a valid metric because WFAA has notproduced evidence of any independent public opinion polls regarding this race. There were anumber of polls conducted specifically for individual party primaries, or before any partynominated any candidate. It is our contention that WFAA could not and did not use polls to maketheir candidate selection because none were available regarding the general election candidates.Therefore no candidate can be said to have met the 15% they claim to require.Contributions - WFAA has provided no guidance on what constitutes “substantial” contributions.The lack of a specific threshold renders this criterion meaningless. Where WFAA has failed, theFederal Elections Commission has succeeded in providing a universal, measurable, andverifiable standard of $5,000 to define individuals as “candidates”. John Jay Myers has met thisobjective standard by raising over $5,000 by the end of the second quarter (this is the lastpublicly available report). To date, John Jay Myers has raised over $12,000 (to be reported at theend of the third quarter).Prior Elections - Ted Cruz has never run for elected office, while Paul Sadler has. Both wereinvited. No candidate has run for statewide election before. The inconsistent application of thiscriterion suggests a partisan bias. There is also no standard for what constitutes “substantial”results.Election Night Returns - WFAA is claiming clairvoyance when making decisions based on futuremedia coverage. They do not know what will be reported on any other station, and they couldonly know what will be reported on their own station if they have already decided whom toinclude, or exclude. It can only be known that all qualified candidates for the ballot, includingJohn Jay Myers, will be reported by the Texas Secretary of State and the county elections offices.News Coverage - If every news station only covered candidates who had previously beencovered by other stations, there would be no political news. Not only is this a self-fulfillingexcuse to include only their favorites, but it also lacks any means to prove or disprove it. There isno number of articles, size or number of media outlets, nor any other measurable way to meetthis requirement.As further evidence of inconsistent, arbitrary, and biased criteria, here is the full text of aSeptember 12 article about a John Jay Myers protest of his exclusion from the debate. This canbe found online here:http://www.wfaa.com/news/politics/Libertarians-protest-exclusion-from-Belo-Debate-169535156.html?fb_comment_id=fbc_282598475187311_1258445_282643295182829#f27f90df2d733a6DALLAS — Carrying signs saying "Let us debate" and "Let the candidatespeak," a handful of people supporting the Libertarian candidate for U.S. Senateprotested Wednesday outside the WFAA studio in downtown Dallas.