To:    Dr. Christine C. Boesz
          National Science Foundation
          Office of Inspector General
          4201 Wilson Boulevard
          Arlington, VA 22230

Date:  February 2, 2006

Re:    Award Number 0524252; A Center for Correct, Usable, Reliable, Auditable, and Transparent Elections (ACCURATE)

Dear NSF Inspector General Boesz,

This letter is being submitted in order to apprise you of what I believe to be serious improprieties, including plagiarism, related to the $7.5M NSF-funded Cyber Trust program grant, currently called “ACCURATE” (which I will instead refer to as the “Center”).

My claims regarding this matter are as follows:

1. A substantial amount of material that the Center team members knew I created was used, without my knowledge or permission, in the documents and presentations submitted to the NSF for consideration in the awarding of this grant. These materials include the “ACCURATE” acronym (and its expanded form) used to name the Center, as well as certain of my word-for-word text and research methodologies.

2. My original works were misappropriated by the Center from my prior NSF submission materials, for which it had been previously explicitly agreed (in writing) among the co-PIs (including some current members of the Center) that I would receive particular percentage shares if a grant was awarded.

3. The awarded proposal failed to attribute the appropriated materials to my authorship, and I was not provided with any financial consideration, even though it was understood that I was willing and able to perform a number of the Center’s specified project tasks.

4. The Center’s director, Johns Hopkins University’s Avi Rubin:
       a. led me to believe that the research group had disbanded;
       b. misrepresented my interest in the submission of re-proposals of my materials; and
       c. mischaracterized my work as either non-proprietary,
           or as having been excised from the Center’s NSF submission,
           when neither was the case.

5. Following my initial communication to the Center requesting acknowledgement along with remuneration, my name was placed (without permission) on the home page of the Center’s Website, making it seem as though I had agreed to grant the use of my work, and further implying that I was endorsing the Center’s work.  

6. Attempts to resolve this matter, conducted between my attorney, Ron Weikers, and Johns Hopkins University’s General Counsel, Frederick Savage, have been futile, and the Center continues to use my personal name and work without my permission.

Attached herein is supporting documentation, along with a footnoted narrative in order to assist your reading of these materials. I have notified the Center of my intention to submit this information to your Office and would appreciate your consideration of this matter for investigation. Please keep me informed as to the status of this request. I would be available to communicate further with your office should you need additional information, or if you would like to discuss possible remedies.  


Rebecca Mercuri, Ph.D.

Supporting Materials (listed chronologically)

Grant proposal submission to the National Science Foundation from Peter Neumann and Rebecca Mercuri, “ITR: Integrity and Accountability in Electronic Election Systems,” December 12, 2002. Available from NSF as 02-168. NSF2002.pdf
Electronic mail from Peter Neumann to Rebecca Mercuri (and others), “Re: Invitation to NSF Digital Government Review Panel January 15-16,” December 21, 2002, 2:39PM. InvitationToPanel.txt

Cyber Trust Center grant proposal submission to the National Science Foundation, “Collaborative Research: A Center for Correct, Usable, Reliable, Auditable and Transparent Elections (ACCURATE),” March 31, 2004. Available from NSF as Number 0433606. nsf2004.pdf

Rebecca Mercuri’s Statement of Work, submitted via electronic mail to SRI’s Peter Neumann, Donna Linné, and Alicia Sicilliano, March 30, 2004. WorkStatement2004Email.pdf

Rebecca Mercuri’s editing comments to the 2004 NSF Center proposal draft, submitted via electronic mail to the entire group of co-PIs (using the e-mail group alias and also cc’d to SRI’s Peter Neumann and Drew Dean, March 30, 2004. Comments2004Email.pdf

Peter Neumann’s acknowledgement of Rebecca Mercuri’s contributions to the 2004 NSF Center proposal, submitted via e-mail to Rebecca Mercuri, Douglas Jones, and Drew Dean, March 30, 2004. YourCommentsEmail.txt

Electronic mail message from Rebecca Mercuri, to Neumann, Dean, Dill, Rubin, Wagner and Wallach, creating the ACCURATE name and acronym for the center, January 14, 2004. AcronymEmail.pdf

NSF reviewer comments on 2004 ACCURATE proposal (number 0433606), from Carl Landwehr to SRI, September 15, 2004.  Reviews.pdf

Awarded NSF Cyber Trust Center grant proposal, February 2005. Available from NSF as Award Number 0524252, from the Center at <>. prop2005.pdf

Rubin, Jones, Wagner, Dill, Mulligan, Byrne, Wallach, and Neumann, “ACCURATE Slide Bundle,” presentation for NSF Cyber Trust grant review, May 2005. From the Center at <>. site-visit-may2005.pdf

Table comparing a sample of passages in the 2005 proposal, to text that was certifiably contributed by Rebecca Mercuri to the 2004 proposal. Comparisons.doc

Spreadsheet prepared by Rebecca Mercuri containing names and contact information for co-PIs and affiliates listed in the 2002, 2004 and 2005 NSF grant proposals. GrantParticipants.pdf

Electronic mail message from Rebecca Mercuri to Peter Neumann, Avi Rubin and Drew Dean, regarding the unauthorized use of Mercuri’s work in the 2005 NSF Center proposal, September 6, 2005. MyIntellectualProperty.eml

Correspondence between Attorney Ronald Weikers, representing Rebecca Mercuri, with ACCURATE Center Directors Aviel Rubin and Daniel Wallach, and their counsel, Attorney Frederick Savage. [a] 092005Letter.pdf September 20, 2005; [b] 100505.doc October 5, 2005; [c] 101405.doc October 14, 2005; [d] fgs103105.doc October 31, 2005; and [e] 110405.doc November 4, 2005.

Web home page of (and, December 29, 2005. ACCURATEVotingCenter.pdf