Filing Summary

This filing is the Plaintiffs’ memorandum of law opposing the Defendants’ motions to dismiss. The Plaintiffs repeat the factual allegations from their second amended complaint and make legal arguments to rebut those raised by the Defendants.

Key Points

• The Plaintiffs continue to point to statements appearing in different NRA communications that suggest donations will be used for the NRA’s gun advocacy. (Pg. 6–7.)
• The Plaintiffs make the same basic allegations to support their contention that “[l]arge portions of [donations] went astray to unrelated third parties.” (Pg. 8.)
• The Plaintiffs argue that they do have standing to sue the NRA and NRA Foundation and that the law cited by the Defendants does not apply to suits brought against not-for-profit corporations. (Pg. 12.)
• The Plaintiffs also argue that New York courts have permitted donors to sue charities for fraudulent inducement of donations. (Pg. 11.)