RAJ ABHYANKER
1580 West El Camino Real Suite 10
Mountain View, California 94040
(408) 398-3126
December 5, 2025
City of Menlo Park
City Manager’s Office
Justin Murphy
701 Laurel St, Menlo Park, CA 94025
jaherren@menlopark.gov
jicmurphy@menlopark.gov
city.council@menlopark.gov
Subject: Request for Public Records under the California Public Records Act
Dear Public Records Coordinator,
Pursuant to the California Public Records Act (Gov. Code §§ 6250–6270), I
respectfully request the following records limited to calendar years 2024
and 2025.
I respectfully request access to the records described below for the
purpose of evaluating procurement transparency, cybersecurity
considerations, and market competition in law-enforcement body-camera
systems used within Santa Clara County.
This request is narrow, targeted, and limited to existing records already
maintained by the agency. To keep this simple and easy to fulfill, I am
requesting only records already maintained by your agency relating to the
procurement and use of Axon Body 4 cameras by police and law enforcement.
Please provide the following records, for the period January 1, 2024 to
present:
1.
Please provide the current contract between your police department and
Axon Enterprise, Inc., including all amendments, renewals, pricing
schedules, and Statements of Work for calendar years 2024 and 2025.
2.
Please provide any records showing whether Axon disclosed to your police
department that the Axon Body 4 camera contains a cellular or IoT module
manufactured by Quectel Wireless Solutions, and any records discussing the
United States Department of Defense designation of Quectel as a Chinese
military company. If no such records exist, please confirm this in writing.
3.
Please provide all records identifying the manufacturer of the Axon Body
4 cellular or IoT module.
4.
Please provide all Axon statements or materials referencing
cybersecurity, data security, supply-chain security, or foreign-vendor risk
for Axon Body 4.
5.
Please provide all documents Axon provided to your agency describing
Axon Body 4 hardware, components, cellular modules, radio modules, or
security architecture.
6.
Please provide all records discussing whether https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fEvidence.com&c=E,1,kudY-5oj0KCpKO2Nq_PLsxQMQ8QPt9fi_0s9RTPWHhIGboLloAKBlY94un-UIYOhSSoovcMe4um8uwxd-pUYjb-OVcqnpE2nR1xNcqqkYraEyceMVX8qXw,,&typo=1 is
interoperable with non-Axon body-camera systems.
7.
Please provide all records discussing whether https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fEvidence.com&c=E,1,TvFPYkSqcD-j-ESjRBtXjnqPtAXUptFtjEgqnhSCrBf6RhPUUJ8OPV6bZUghU11MQauRTDrZWHsrRAUlplSaEsF22wDro3KAY-iJ5Wwf7DjylC8y&typo=1 limits your
agency’s ability to adopt competing body-camera vendors.
8.
Please provide all records reflecting your agency’s evaluation of
alternative body-camera vendors and any technical, contractual, or
interoperability limitations encountered.
9.
Please provide any records discussing whether new information about Axon
Body 4 component origins or security designations could affect procurement
or vendor-selection decisions.
10.
Please provide all communications between your agency and Axon from
January 1, 2024 to the present relating to procurement, renewal, upgrades,
security issues, or deployment of Axon Body 4 cameras..
Ideally, I request production in bulk, electronically stored information
(ESI) format, in the form of a .PST file. If this format is
unavailable, I am willing to gain receipt of the production in any format
that is available.
Arguments for the Need under CPRA
This request is made in furtherance of transparency in public safety
procurement and technology oversight. California law enforcement agencies
rely heavily on vendor disclosures to evaluate cybersecurity risks,
supply-chain integrity, wireless component origins, and system
interoperability. Access to the requested records will allow the public to
understand what information Axon has provided to agencies about Axon Body 4
hardware, including any representations related to cybersecurity, vendor
risk, and the use of foreign-manufactured cellular modules.
The information requested is squarely within the scope of the California
Public Records Act, which exists to ensure that matters of public
expenditure, public safety, and contracting practices remain open to public
review. Because Axon Body 4 systems are purchased with public funds and
used in core public-safety functions, the public has a strong interest in
understanding the technological and risk information considered by agencies
during procurement and deployment.
Potential Benefits to Police Departments
The records requested may help police departments better assess the
completeness and accuracy of vendor disclosures, identify potential
cybersecurity or supply-chain risks, and evaluate whether current systems
meet agency expectations for reliability and transparency. By examining how
Axon has described Axon Body 4 hardware and its wireless components,
agencies may gain additional insight relevant to maintenance, upgrades, and
long-term risk management.
These records may also help departments understand whether https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fEvidence.com&c=E,1,9Sc5UZOnVoX34dnFT8_SImsRN5jgnpO6PfXxhmfZMsOhnf90G5r2LbkylKNrxMaMtIgAxCGaGqlVMghozcnHi9AgMrBeKz721WvpE1vsXqH56Tnu&typo=1
interoperability limitations affect their ability to evaluate or adopt
competing technologies. That information supports informed procurement
planning, reduces vendor lock-in risk, and strengthens the department’s
ability to negotiate favorable contract terms in the future.
Broader Implications
The information requested has significance beyond a single department.
Accurate understanding of component origins, cybersecurity representations,
and interoperability constraints is essential to all California agencies
evaluating body-worn camera solutions. Public access to these records can
inform statewide policy discussions about public-safety technology
procurement, foreign-vendor risk, and the impact of proprietary
evidence-management ecosystems on competition and innovation.
These issues affect not only police departments but also city management,
IT divisions, procurement offices, and community stakeholders concerned
with privacy, data security, and responsible use of public funds.
Ethical and Legal Considerations
The request adheres strictly to the California Public Records Act and seeks
only records directly relevant to public procurement, vendor
communications, and technology risk assessment. No confidential officer
information, operational tactics, or sensitive investigative data is
sought. The CPRA requires disclosure of contracts, vendor representations,
technical materials provided to agencies, and communications relating to
public procurement.
The requested records concern matters already shared with government
agencies by a commercial vendor. Disclosing such records promotes
transparency and accountability without compromising officer safety or
personal privacy.
Public Benefits
Public access to these records promotes transparency in law-enforcement
procurement, ensures accurate public understanding of the technologies used
in local policing, and informs taxpayers about the systems purchased with
public funds. The public has a substantial interest in knowing whether
vendors fully disclosed component origins, cybersecurity risks, and
interoperability limitations when selling critical technology to local
agencies.
These records will help the public understand how procurement decisions are
made, how risks are evaluated, and whether agencies have the information
necessary to make well-informed decisions about public-safety technology
and data-management platforms.
Feasibility and Privacy
The request is narrowly tailored to records that agencies routinely
maintain, including contracts, vendor communications, technical documents,
and procurement correspondence. These materials are typically stored
electronically and can be located through standard email and document
searches.
No personal identifying information, officer personnel data, or
confidential investigative material is being requested. Any such
information may be redacted consistent with CPRA exemptions. This request
minimizes administrative burden and is designed to allow straightforward,
good-faith compliance using readily accessible records.
Commitment to Cover Costs:
I understand that gathering and providing these records may require
dedicated city resources. I am committed to covering the reasonable costs
associated with fulfilling this request. I believe the investment in
obtaining this information is justified by the substantial public interest
and potential benefits outlined above.
In my experience as both a software developer and a California licensed
attorney, I understand that obtaining the requested records may not be as
difficult of a task as it may initially seem. Often, city IT departments
efficiently maintain such records, typically in Microsoft Outlook .PST
files on Microsoft Enterprise servers. To facilitate the production of
these records in a manner that is both efficient and secure, I am willing
to enter into a limited scope services and confidentiality agreement with
the city. As a licensed attorney, I am acutely aware of and committed to
upholding the privacy and confidentiality standards set forth by the city
and the legal profession. This commitment, coupled with my technical
expertise, ensures a responsible handling of the records in accordance with
all applicable regulations and city policies.
Request for Meeting:
I would welcome the opportunity to speak briefly with the appropriate
member of your department or procurement team to better understand how Axon
Body 4 systems were evaluated and what information was considered during
the procurement process. This includes whether technical or
security-related disclosures from Axon played a role in your agency’s
decision-making.
In particular, I would appreciate the chance to discuss one important
public-interest question:
If your agency had known that the Axon Body 4 camera used a cellular or IoT
module manufactured by a company later designated by the United States
Department of Defense as a Chinese military company, would that information
have affected your agency’s evaluation of Axon or consideration of
alternative body-camera vendors?
This is not a request for confidential operational information, but rather
an effort to understand how vendor disclosures align with the information
necessary for informed public procurement. If a short meeting is possible,
please let me know whom I should contact to schedule it.
Request for Detailed Position Statement:
If your agency denies any portion of this request, or if responsive records
do not exist, I respectfully request a detailed written position statement
explaining your agency’s position of the following question:
Whether information that the Axon Body 4 camera uses a cellular or IoT
module manufactured by a company designated by the United States Department
of Defense as a Chinese military company would have affected your agency’s
procurement evaluation, vendor selection, or consideration of alternatives.
If your agency determines that this information would not have affected
procurement decisions, please explain the basis for that determination. If
the information would have been relevant or material, please state that as
well.
A written explanation will help ensure that the public record accurately
reflects the considerations that inform the adoption of body-worn camera
systems and related evidence-management platforms. It will also help
clarify whether the existence or absence of certain vendor disclosures
played any role in your agency’s procurement process.
Conclusion:
In closing, I respectfully request your cooperation in fulfilling this
request. I am open to discussing this further and finding a mutually
agreeable way to proceed. Your assistance in this innovative endeavor will
not only benefit our community but also set a precedent for the use of
technology in enhancing municipal governance.
Thank you for considering this request. I look forward to your response and
am available for any further discussions or clarifications needed.
Contact and Response:
Please let me know the estimated cost of fulfilling this request in
advance. If certain records are exempt from disclosure, I request that you
provide a written explanation and release all segregable portions of
otherwise exempt material.
I look forward to your prompt response within the 10-day window as
stipulated by the CPRA. Should you need any clarification regarding my
request, please contact me at 408-398-3126 or raj@legalforcelaw.com.
Sincerely,
Raj Abhyanker, Esq.
