two-party domination. Although this "law" is just an empirical observation rather than a mathematical certainty, it is generally supported by the evidence. Due to the especially deep impact of strategic voting in such a method, some argue that systems with three or more strong or persistent parties become in effect forms of disapproval voting, where the expression of disapproval in order to keep an opponent out of office overwhelms the expression of approval to elect a desirable candidate. Party-list proportional representation The presence of an electoral threshold (typically at around 5% or 4%) can lead to voters voting tactically for a different party to their preferred political party (which may be more hardline or more moderate) in order to ensure that the party passes the threshold. An alliance of parties can fail to win a majority despite outpolling their rivals if one party in the alliance falls beneath the threshold. An example of this is the 2009 Norwegian election in which the right-wing opposition parties won more votes between them than the parties in the governing coalition, but the narrow failure of the Liberal Party to cross the 4% threshold led to the governing coalition winning a majority. This effect has sometimes been nicknamed "Comrade 4%" in Sweden, where the electoral threshold is 4%, particularly when referring to supporters of the Social Democrats who vote tactically for the more hardline Left Party. In the 2013 German federal election, the Free Democratic Party got only 4.8% of the votes so did not meet the 5% threshold. The party did not win any directly elected seats, so for the first time since 1949 was not represented in the Bundestag. Hence their ally the Christian Democratic Union had to form a grand coalition with the Social Democratic Party. In several recent elections in New Zealand the National Party has suggested that National supporters in certain electorates should vote for minor parties or candidates who can win an electorate seat and would support a National government. This culminated in the Tea tape scandal when a meeting in the Epsom electorate in 2011 was taped. The meeting was to encourage National voters in the electorate to vote "strategically" for the ACT candidate; and it was suggested that Labour Party voters in the electorate should vote "strategically" for the National candidate as the Labour candidate could not win the seat but a National win in the