You may recall a 2009 Obama EPA memo, obtained for CEI in the “Richard Windsor” FOIA litigation, laying out the intended reframing of the climate campaign — the “shift from making this about the polar caps [to] about our neighbor with respiratory illness…”, acknowledged by the Obama EPA as necessary due to “climate change in the abstract [being] an increasingly – and consistently – unpersuasive argument to make.” This suit is a continuation of that.