engage in protest actions designed to force powerful groups to respond to their demands, protest is only one aspect of the activity of organizing groups. To the extent that groups' actions generate a sense in the larger community that they have "power," they are often able to engage with and influence powerful groups through dialogue, backed up by a history of successful protest-based campaigns. Similar to the way unions gain recognition as the representatives of workers for a particular business, community organizing groups can gain recognition as key representatives of particular communities. In this way, representatives of community organizing groups are often able to bring key government officials or corporate leaders to the table without engaging in "actions" because of their reputation. As Alinsky said, "the first rule of power tactics" is that "power is not only what you have but what the enemy thinks you have." The development of durable "power" and influence is a key aim of community organizing. "Rights-based" community organizing, in which municipal governments are used to exercise community power, was first experimented with by the Community Environmental Legal Defense Fund (CELDF.org) in Pennsylvania, beginning in 2002. Community groups are organized to influence municipal governments to enact local ordinances. These ordinances challenge preemptive state and federal laws that forbid local governments from prohibiting corporate activities deemed harmful by community residents. The ordinances are drafted specifically to assert the rights of "human and natural communities," and include provisions that deny the legal concepts of "corporate personhood," and "corporate rights." Since 2006 they have been drafted to include the recognition of legally enforceable rights for "natural communities and ecosystems." Although this type of community organizing focuses on the adoption of local laws, the intent is to demonstrate the use of governing authority to protect community rights and expose the misuse of governing authority to benefit corporations. As such, the adoption of rights-based municipal ordinances is not a legal strategy, but an organizing strategy. Courts predictably deny the legal authority of municipalities to legislate in defiance of state and federal law. Corporations and government agencies that initiate legal actions to overturn these ordinances have been forced to argue in opposition to the community's right to make governing decisions on issues with harmful and direct local impact. The first rights-based municipal laws prohibited corporations from monopolizing horticulture (factory farming), and banned corporate waste dumping within municipal jurisdictions. More recent rights-based