On 30 September 2009, Adalah sent a letter to the Employment Office , the Minister of Industry, Trade and Labor, and the "Faithful Work" Center demanding that an order be issued for the equal reimbursement of travel expenses incurred by all participants in the "Lights of Work" employment program (Wisconsin Plan) from East Jerusalem. Palestinian residents of East Jerusalem who participate in the plan are reimbursed NIS 80 or NIS 200 for travel expenses, whereas Israeli Jewish participants from West Jerusalem receive up to NIS 1,000. In the letter, sent by Adalah Attorney Sawsan Zaher, Adalah also demanded compensation for the East Jerusalem participants in the program for the previous period in which they received only partial reimbursement of their travel expenses.

In its response of 28 October 2009 , the Ministry of Industry, Trade and Labor (MITL) argued that residents of East Jerusalem received higher sums, on average, than those living in West Jerusalem, and that there was no intention to discriminate. However, an investigation carried out by the MITL had revealed that residents of East Jerusalem were required to pay a specific sum from their own pockets, a demand not made of residents of West Jerusalem.

“It has been decided that the payment of travel expenses will be made upon the submission of documentation for public transportation, and a revision will be made to the guidelines,” announced the MITL in its response. The ministry further stated that it would compensate residents of East Jerusalem who had not been reimbursed in full for their travel expenses for the previous period.

According to a report published in Ha’aretz on 7 September 2009, the authorities have asked Palestinian residents of East Jerusalem to present documentation to have their travel expenses reimbursed, while the Jewish residents of West Jerusalem were not required to do so. Further, the East Jerusalem residents are reimbursed after they have paid for travel associated their participation in the plan, while the West Jerusalem residents are given travel tickets before they travel, and without examination of the distance between their place of residence and the center at which the plan is being operated. The report also found that there are no specific instructions to govern the reimbursement of travel expenses; it is done arbitrarily and relates to the participant’s identity and whether he/she lives in East or West Jerusalem.

Participants in the Wisconsin Plan are recipients of income security allocations or those who request income security from the National Insurance Institute and who live in the area of operation of the plan, and have been referred to it. Participation in the plan is a condition of receiving income security. Participation affords the individual certain rights, including reimbursement of travel expenses, without a stipulation of the number of hours that he/she must work.

Adalah argued in the letter that awarding different travel reimbursement payments and conditions to Palestinian residents of East Jerusalem and other participants from West Jerusalem constitutes prohibited discrimination because it is based on the participant’s place of residence in Jerusalem and his or her national identity.

Adalah emphasized that participants in the Wisconsin Plan are job-seekers; they generally come from a poor socio-economic background and income security allocations are their only source of livelihood. The failure to reimburse their travel expenses in full puts a particular strain on them, and may force them to stop participating in the plan, which would result in their destitution, which constitutes a violation of their right to social security, as Attorney Zaher argued in the letter.