The comments are here. Bob Bauer’s reply is here. UPDATE: Trevor Potter of the Campaign Legal Center writes:

Actually, what Bob Bauer has up is Friday’s DRAFT of potential Comments From the Legal Center, Democracy 21, and the Center for Responsive Politics. It was provided to an outside organization at their request Friday, and has, rather strangely, turned up on the web. When the actual comments are finished and filed today, we will post.

I’ll link here to the final comments when the CLC posts them.