IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
SOUTHERN DIVISION
CHAMBER OF COMMERCE OF
THE UNITED STATES OF AMERICA
1615 H Street, NW
Washington, DC 20062;
ASSOCIATED BUILDERS
AND CONTRACTORS, INC.
4250 N. Fairfax Drive, 9th Floor
Arlington, VA 22203;
SOCIETY FOR HUMAN
RESOURCE MANAGEMENT
1800 Duke Street
Alexandria, VA 22314;
AMERICAN COUNCIL ON
INTERNATIONAL PERSONNEL
1101 15th Street, NW, Suite 750
Washington, DC 20005; and
HR POLICY ASSOCIATION
1100 13th Street, NW, Suite 850
Washington, DC 20005;
Plaintiffs,
vs.
MICHAEL CHERTOFF
In his official capacity as
Secretary of Homeland Security
Department of Homeland Security
245 Murray Drive, SW
Washington, DC 20528;
ALBERT A. MATERA
In his official capacity as Chairman
of the Civilian Agency Acquisition Council
1800 F Street, NW
Washington, DC 20405; and
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Case 8:08-cv-03444-AW Document 1 Filed 12/23/2008 Page 1 of 28
2
UNITED STATES OF AMERICA;
Defendants.
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COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
Plaintiffs Chamber of Commerce of the United States of America; Associated Builders and Con-
tractors, Inc.; Society for Human Resource Management; American Council on International Personnel;
and HR Policy Association (collectively, “Plaintiffs”) file this Complaint for Declaratory and Injunctive
Relief against Defendants Michael Chertoff, Secretary of Homeland Security; Albert A. Matera, Chair-
man of the Civilian Agency Acquisition Council; and the United States of America (collectively, “De-
fendants”), in support of which Plaintiffs allege as follows:
PR