Penn did write a memo in 2007 saying that Obama’s foreign background could present a weakness for him, and Clinton should emphasize her middle-class Midwestern upbringing.
"His roots to American values and culture are at best limited," the memo says. "I cannot imagine America electing a president during a time of war who is not at his center fundamentally American in his thinking and values."
But it does not say that Obama was foreign-born. No evidence has been uncovered to link the idea of birtherism to the Clinton campaign.
In 2015, Clinton told Don Lemon the claims that she and her campaign started the Obama birther attacks were "ludicrous and untrue."
There have been several reports linking the first major instance of floating the theory to Clinton's supporters.
In 2008, the fact-checking website Factcheck.org said the idea of “birtherism” could originally be traced to Clinton’s diehard supporters, as it became clear she was going to lose the nomination.
But Clinton’s supporters aren’t the same thing as her campaign.
“There is no record that Clinton herself or anyone within her campaign ever advanced the charge that Obama was not born in the United States,” Politifact, another fact checking website, wrote last September following Trump’s tweet that Clinton started the birther movement and was "all in" on the movement.
Politifact rated this claim false.