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In multiple-party popular primary elections, crossover voting refers to a behavior in which voters who normally participate in the primary of one party instead vote in the primary of another party. The behavior typically happens when the nominee of the one party is a foregone conclusion or when a candidate in the other party's primary has an appeal to the voters in the one party, although the motives are sometimes impure. Thus crossover voting has been used by voters to cast in the party a voter is opposed to in order to nominate a candidate which can be more easily beaten by the candidate the voter actually supports. An example is East Tennessee Republicans who, having already settled on their 1966 U.S. Senate nominee as Howard Baker, proceeded to vote in the Democratic Primary for challenger Frank G. Clement, who ousted the incumbent Ross Bass in that Democratic Primary; then the Republican voters got behind Baker and voted him while the Democrats were in disarray. Some consider crossover voting to be a form of electoral fraud. Also, conservative American radio host Rush Limbaugh popularized crossover voting in the country when he suggested that Republicans vote as Democrats in the 2008 United States presidential election, in order to cause polemic inasmuch as Barack Obama was the likely Democratic opposition to John McCain in the general election. He did this in response to observation of the fact that many Democrats and Independents had crossed over to vote in the Republican primaries which, according to him, resulted in John McCain's nomination.