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)."