chill political speech, the Court noted that disclosure of the advocates’ identity at the point of contact with voters could weaken the effectiveness of the speech: “[A]n advocate may believe her ideas will be more persuasive if her readers are unaware of her identity.” Id. at 342, 115 S.Ct. 1511; see also ACLU of Nev. v. Heller, 378 F.3d 979, 994 (9th Cir.2004) (“[F]ar from enhancing the reader’s evaluation of a message, identifying the publisher can interfere with that evaluation by requiring the introduction of potentially extraneous information at the very time the reader encounters the substance of the message.”). We have adopted the Court’s skepticism of an informational interest in the identity of the advocate at the point of contact with voters. See Heller, 378 F.3d at 995 (<HOLDING>); (WIN) Wash. Initiatives Now v. Rippie, 213
holding that a mere passing reference or even references however to a document outside the complaint does not on its own incorporate the document into the complaint itself citation omitted holding that an informational interest in allowing the public to evaluate the advocacy document is not sufficiently important to sustain compelled disclosure of an advocates identity on the document itself holding that in connection with a motion to dismiss the court may consider a document not attached to the pleadings where the plaintiffs claim depends on the contents of a document the defendant attaches the document to its motion to dismiss and the parties do not dispute the authenticity of the document even though the plaintiff does not explicitly allege the contents of that document in the complaint holding that an informational interest is not sufficiently important to sustain compelled disclosure of advocates identities during the circulation period holding that if a document falls within the scope of the public records statute then the presumption favoring disclosure applies