the committees "whisper in the ear" of negotiators. Michelle Ye Hee Lee, a fact-checker for The Washington Post, wrote that Warren used "misleading language" in describing the TPP. While Warren implied that "28 trade advisory committees were formed" specifically to influence the TPP, the advisory committees were actually created as part of the Trade Act of 1974; only the membership of the trade committees had changed during the Obama administration and the early phases of the TPP. Regarding Warren's claim that trade advisers secretly "whisper in the ear of our trade negotiators", Lee wrote: "while the direct meetings take place in private, committees still have to submit written reports to Congress and provide written recommendations and advice that are made public." Furthermore, Lee wrote, "it is true that industry representatives make up a large number of the total membership, but it is worth noting that there is a labor committee in the second tier, labor representatives in the first tier and that the industry groups have a narrow focus (to give technical advice)." In response to criticisms about transparency and the large representation from industry representatives, USTR announced it would create a Public Interest Trade Advisory Committee. Non-compete clause Dean Baker argued that Article 18.78, under which countries should ensure that they protect trade secrets and impose criminal procedures for violators, could be used to enforce non-compete agreements. Baker points out that California's success can partly be attributed to the fact that the state did not allow for the enforcement of non-compete agreements, making it easy for tech workers to quit their jobs and start to work for another company. Criticisms from politicians and activists In 2014, linguist and political activist Noam Chomsky warned that the TPP is "designed to carry forward the neoliberal project to maximize profit and domination, and to set the working people in the world in competition with one another so as to lower wages to increase insecurity." Senator Bernie Sanders (I-VT) argues that trade agreements like the TPP "have ended up devastating working families and enriching large corporations." See also Association of Southeast Asian Nations Regional Comprehensive Economic Partnership (RCEP - ASEAN plus 6) Combating Online Infringement and Counterfeits Act (COICA) Counterfeit Digital rights Trade Promotional Authority Foreign trade of the United States Free trade Free trade area Generic drug Indo-Pacific Economic Framework (IPEF) Non-tariff barriers to trade Office of the United States Trade Representative