Former Trump attorney Cleta Mitchell and her network of election conspiracy theorists are secretly backing a new project to allow MAGA activists to generate mass voter challenges.

The project, “Eagle AI,” looks to fill the void left by Mitchell and her network’s successful campaign to pressure state officials to cut ties with the bipartisan Electronic Registration Information Center, better known as ERIC.

As NBC News first reported, based on material provided by Documented, Eagle AI draws from public data sources like voter files and newspaper obituaries to build a dashboard for activists to conduct their own “list maintenance” and generate potentially thousands of challenges to voter eligibility with a few clicks.

The resulting flood of conspiracy-driven voter challenges, drawn from questionable data, could inundate overworked and under-resourced election offices and lead to eligible voters being purged from the rolls. In many states, challenged voters will have to jump through additional hoops to have their vote counted.

The project is being deployed through Mitchell’s “Election Integrity Network” (EIN). Activists affiliated with EIN in states like Georgia, North Carolina, and Florida are already testing the Eagle AI system, and setting up meetings with election officials to normalize the program and encourage them to accept voter challenges generated by the platform. Platforms will also be rolled out soon in Arizona, Nevada and Texas.

Eagle AI’s funding sources are murky, but a planning document co-authored by Mitchell show plans to receive private donations from sources including Donors Trust, known as the “dark money ATM of the right.” A legal firm associated with Mitchell also set up Eagle AI's tax-exempt arm, "Valid Vote," which told the IRS that it plans to raise $2.1 million in advance of the 2024 election.

Mitchell is guiding the Eagle AI project, including providing legal advice and developing strategy. Also consulting on the project is Jason Frazier, who has filed thousands of voter challenges in Georgia and was recently rejected from a seat on the Fulton County elections board.

    ERIC Out, Eagle AI In

    Throughout 2022 and 2023, Mitchell and her allies played a central role in coordinating attacks on ERIC, which helps election officials to confidentially compare data between states to keep voter rolls clean.

    ERIC allows election officials to identify, for example, when a person voted or registered in another state, or had died in another state. ERIC draws from an array of up-to-date data sources securely provided by states to reduce the chance of "inaccurately flag[ging] voters who shared, say, the same name and birthdate, but were actually different people," as VoteBeat has described.

    ERIC was an uncontroversial program until 2022, when it got pulled into the flurry of conspiracy theories that festered after the 2020 election. Former President Trump, for example, began to falsely claim that ERIC "pumps the rolls" for Democrats because member states must remind eligible voters how to register.

    As NPR reported, based on material provided by Documented, Mitchell played an important role in the campaign to pressure states to cut ties with ERIC: she held an anti-ERIC briefing in June 2022 for Secretaries of State in Washington, D.C., elevated fringe anti-ERIC researchers to the national stage, and her “Election Integrity Network” of state election denier coalitions drove the anti-ERIC campaign forward in key states. Nine Republican-led states have since left ERIC.

    But the states that left ERIC didn’t have a plan to replace it. Mitchell and her EIN then sought to fill that void with “Eagle AI.”

    "I think that probably we could get some of the secretaries of state who have withdrawn from ERIC to take a look at this," Mitchell said of Eagle AI in March 2023, following a demonstration of the software to an EIN working group. "You know, I think that they're looking for an alternative."

    Eagle AI told Georgia's elections board in May 2023 that it had been offered introductions to secretaries of state in Florida, Alabama, Louisiana, Missouri and West Virginia, according to records obtained by Documented. Each of those states had recently withdrawn from ERIC.

    Voter Challenges at the Click of a Button

    “Eagle AI” was developed by a retired Georgia physician named Rick Richards and his son, John. Neither appear to have any background in election administration.

    The associated software draws from public voter registration data, business records, the “True NCOA” change of address database, newspaper obituaries, "Google scrapes" and other data from unspecified sources to build a dashboard for grassroots activists to conduct their own “list maintenance.” The software also interfaces with the controversial Dick Uihlein-backed “VoteRef” to identify potential cross-state moves.

    Eagle AI allows EIN's volunteers to generate potentially thousands of voter challenges with a few clicks, based on their personal suspicions and a database that is totally opaque to anyone outside of the licensed user base.

      Blake Evans, Georgia’s elections director, told NBC News that “EagleAI draws inaccurate conclusions and then presents them as if they are evidence of wrongdoing.”

      In a March 2023 demonstration to an EIN coalition, Richards showed how the platform can auto-fill voter challenge forms, attach supporting material, and then time the submission until ten days before the election board's next meeting.

      "They click a button and then all of those challenges are automatically delivered to the board of election.”


      In many states, voter challenges may only be filed by residents of the relevant jurisdiction. But Eagle AI allows activists from across a state—or even around the country—to identify alleged problems with the voter rolls. Eagle AI then automatically populates the challenge forms, and a local volunteer emails the challenges to their local elections board. As The Guardian reported in February 2024, this challenge-by-proxy approach may violate Georgia law.

      Jason Frazier, who filed thousands of voter challenges in Georgia, has worked closely with Richards on the project. "We use Jason's algorithms to help develop some of these workspaces, and Jason is the one who has done the most work with this data," Richards told an EIN call in March, before inquiring about the status of the voter challenges he'd filed.

      Right Wing Dark Money Funding

      A June 2023 document drafted by Mitchell and Richards describes plans to raise “private contributions" for Eagle AI from sources such as Donors Trust, a conduit for right-wing funding that obscures the original source of the money.

      Megadonors such as Leonard Leo have funneled millions through Donors Trust, which raised over $1 billion in 2021. Michael Beckel, research director at Issue One, has called Donors Trust an “ATM for dark money groups.”

      Grants to Eagle AI from Donors Trust or other nonprofit sources, such as the Bradley Foundation—where Cleta Mitchell is a board member—won't be reported until tax filings become available several months later. Donations from individuals or for-profit corporations may never be disclosed.

      The financing will flow through Eagle AI and an associated 501(c)(3) nonprofit called “Valid Vote,” both of which were formed in Georgia in July 2022.

      Valid Vote told the IRS that it planned to raise $2.1 million in advance of the 2024 election.

      Firm Tied to Cleta Mitchell, and Paid by Trump, Managed IRS Application

      Valid Vote’s application for tax-exempt status has been managed by a firm associated with Cleta Mitchell and housed within the same right-wing entity that launched EIN.

      "Compass Legal Group" represented Valid Vote as it successfully sought tax-exempt status from the IRS in early 2023. Mitchell is one of the firm's beneficial owners, and described herself as affiliated with the firm in multiple matters before the Federal Election Commission.

      Compass Legal is the in-house legal compliance firm for the Conservative Partnership Institute (CPI), the $45 million institution that launched EIN and where Mitchell is a senior fellow. CPI is led by Mark Meadows, Trump's White House chief of staff who was indicted in Georgia for supporting the former president's efforts to overturn the 2020 election. In CPI's 2021 annual report, the organization described how it created Compass Legal to “[t]ake care of things like legal filings and help[ing] non-profits to comply with federal tax law."

      Compass Legal's address (including the address where it receives correspondence pertaining to Valid Vote) is the same as CPI's, 300 Independence Ave SE.

      Dozens of federal political committees have also reported payments to Compass Legal, including Trump's 2024 campaign and his Save America PAC.

      Activists to Election Officials: Eagle AI is "100% non-partisan"

      Eagle AI has been a central focus of Mitchell's EIN.

      Since at least March 2023, Richards has been giving demonstrations of the software to national EIN working groups and state coalitions. As the project has moved closer to deployment in key states, EIN activists have been staffing the in-state organizational structures.

      In states like Georgia, Florida, and North Carolina, EIN activists have been testing the functionality of the Eagle AI platform, as well as beginning to meet with state and county election officials to build support for voter challenges drawn from the project.

      Activists are instructed to tell election officials that EagleAI “is 100% non-partisan,” according to the June 2023 planning document drafted by Mitchell and Richards, and distributed to EIN activists.

      "Explain to them that you understand they are overwhelmed and that, as a good neighbor, you would like to help," the document states.

      When meeting with state election administrators who aren't "100% hostile to election integrity," Mitchell and Richards advise, "[t]he important point is to try to build a positive relationship, so the state doesn’t send out an advisory to the counties / local units telling them to stay away from you and your efforts."

      After Documented first exposed Eagle AI and its operations, states such as Nevada have sent out advisories warning municipalities about the group.

      Eagle AI Seeking Public Contracts, and Personally Identifiable Information

      In addition to helping activists file mass voter challenges, Eagle AI is also aiming to enter into taxpayer-funded contracts directly with counties and states and to obtain a wider range of personal data. (Notably, critics of ERIC previously feigned concern about sharing personal data with a private third-party group.)

      "We’re building this for three audiences," Richards told an EIN group in March 2023. "One is the citizen who wants to verify their state voter rolls, [a second audience is] counties who are getting 15,000 challenges on a spreadsheet and don’t know what to do with them, and then [third] we can also do it at the state level and basically do what ERIC is supposed to be doing but is not doing.”

      Eagle AI also initially claimed that it could help states and counties to "pre-screen incoming voter registration applications" to ensure a new voter was eligible. In March 2023, Richards said that Columbia County, Georgia was interested in using the software to screen new voter registrations.

      Richards has consistently acknowledged the shortcomings of the platform's activist-facing platform, which is built on incomplete and unreliable public data. Contracting with counties or states would give Eagle AI access to personally identifiable information—such as birth dates and citizenship data— “that we are told is available if we have a contract with the County or State,” he wrote in a May 2023 email to Columbia County officials. Obtaining such data, he wrote, "would improve accuracy and efficiency."

      "It would make our product and other people who are working it so much more effective if we just get the date of birth, for example, if we just get the real felon list," he told an EIN group in March 2023. "The major thing that I would like is access to the real data."

      However, even if Eagle AI did supplement its publicly-sourced data with birth dates, it would appear to suffer from the same weaknesses that plagued the failed Interstate Crosscheck System, which consistently produced false positives by relying on such limited data.

      Columbia County's Contract with Eagle AI for a "Nominal" Fee May Violate Georgia Law

      In December 2023, Eagle AI entered a contract with Columbia County, Georgia to review voter challenges and conduct list maintenance activities. The county is paying Eagle AI just $2,000 per year. By paying below market rate for Eagle AI's services, the county may be in violation of Georgia's so-called "Zuck bucks" ban on private election funding.

      In a March 23, 2023 demonstration to an EIN working group, Richards, described how he initially planned to offer Eagle AI's services without charge. Cleta Mitchell interjected to flag that providing such election-related services for free would violate the private funding ban—SB 222—which at the time had passed the Georgia senate and was pending in the House. EIN and its allies had been supporting the ban in response to "Zuckerbucks" conspiracy theories. Mitchell advised that Richards charge the county a small fee to “get past” the requirements of the legislation:

      “Because we are trying to get the billionaire left wing money and services out of county election boards. I think you're going to have to charge them something. $250. I mean, that way you get past, you get past the issue of the bill that the legislature is getting ready to pass in Georgia.”

      Richards acknowledged Mitchell’s concerns, and declared that “we can charge a nominal fee” to Georgia counties for use of Eagle AI.

      A “nominal fee” implied that Eagle AI would be charging Columbia County below market rate, an inference supported by Richards's later correspondence with Georgia officials.

      In a May 10, 2023 email to Georgia Secretary of State’s General Counsel, Charlene McGowan, Richards wrote that he had been planning on charging Columbia County just $1 per year, unless such a nominal charge would violate the private funding ban:

      “After discussions began with Columbia County, Georgia Senate bill 222 became law. Donations from nonprofit organizations are no longer allowed. Although I have offered Columbia County an EagleAI software subscription for $1 for the first year, further discussions have not been completed, e.g., what charges would be in order for EagleAI’s training, consultative services, software enhancements, tech support and subsequent year licenses, etc.

      EagleAI Network, LLC, is a Georgia for profit corporation. If there is a consensus that EagleAI Network’s offer of first year for $1 subscription would somehow be a violation of SB222, we can certainly charge more.”

      The next day, Georgia's State Election Board sent a letter to Columbia County cautioning that accepting Eagle AI's services may implicate the state's newly-enacted ban on private election funding.

      Mass Voter Challenge Protection Racket

      EIN activists have been enlisted into the effort to help Eagle AI land public contracts.

      When meeting with election officials, EIN activists are instructed to say that "The software is available to your County if they would like to use it directly, themselves."

      Ironically, Eagle AI's top selling point is that it will help counties process the mass voter challenges that it is also facilitating.

      "The software can ingest the challenges that come in from other sources, check them against the available data and assist the County employee in evaluating the challenges," activists are advised to tell county election officials. "Thousands of challenges based upon moves or mailability can be checked, validated or not in minutes." Richards has also described how he'd told a Georgia county that Eagle AI can help sort through voter challenges and assess which ones are "valid."

      Given that Eagle AI is designed for activists to manufacture voter challenges, Eagle AI is offering counties a "solution" to a problem that it helped create, a point made explicit by Richards in a March 2023 presentation to EIN activists:

      "We have found that some of these counties in Georgia don't like all these challenges and they are looking for a solution that they can hire and outsource their headache. So we'd rather keep the challenges going. They have ten days to respond in Georgia. So we keep the challenges going on, keeps the heat up. They know that they can't respond. So they're out looking for solutions, which we could be the solution