@rickhasen @AdamSerwer no idea (and probably silly to argue about) but Sunlight was using it as early as 2010 http://sunlightfoundation.com/blog/2010/10/18/daily-disclosures-10/ …
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@tjl@rickhasen@AdamSerwer another October 2010 Sunlight story used it in title: http://bit.ly/aC6f34
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