1 

FEDERAL ELECTION COMMISSION

1050 FIRST STREET, N.E.

WASHINGTON, D.C. 20463

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ) 

 ) MUR 8082 

Unknown Respondents, et al. ) 

) 

STATEMENT OF REASONS OF CHAIRMAN SEAN J. COOKSEY 

AND COMMISSIONERS ALLEN J. DICKERSON AND JAMES E. “TREY” TRAINOR, III

INTRODUCTION

The Federal Election Campaign Act requires that the Commission first 

determine if there is “reason to believe” (“RTB”) a violation has occurred before 

opening an investigation.1 That standard “is no rubber stamp.”2 As the Commission 

explained nearly a quarter century ago, we may not find reason to believe based upon 

“mere speculation” or conclusory statements in a complaint, “especially when 

accompanied by a direct refutation.” 3 Rather, “[t]he Commission may find ‘reason to 

believe’ only if a complaint sets forth sufficient specific facts, which, if proven true, 

would constitute a violation of” the Act.4 We are forbidden from invoking the powers 

of the federal government based on drive-by analysis or mere insinuation. 

In this Matter, the Office of General Counsel (“OGC”) nevertheless urged the 

Commission to find RTB against a handful of now-defunct organizations on the theory 

that they served as pass-through entities for one or more Unknown Respondents.5

1 52 U.S.C. § 30109(a)(2). 

2 Statement of Reasons of Vice Chair Dickerson and Comm’r Trainor at 3, MURs 7427 et al. (Nat’l Rifle 

Ass’n), Dec. 23, 2021. 

3 Statement of Reasons of Comm’rs Mason, Sandstrom, Smith, and Thomas at 2-3, MUR 4960 

(Clinton), Dec. 21, 2000.

4 Id. at 1.

5 First Gen’l Counsel’s Report (“FGCR”) at 46-47, MUR 8082 (Unknown Respondents), Sept. 29, 2023.

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But “the Act does not permit us to proceed on an ‘RTB-of-the-gaps’ approach to law 

enforcement.”6 Because the evidence for the wide-ranging conspiracy the Complaint 

alleges is exceedingly thin, and because it is rebutted by numerous categorical 

denials, many of them sworn under penalty of perjury, we voted to dismiss the 

Complaint.7

I. While the Complaint alleges a wide-ranging conspiracy to engage 

in a conduit contribution scheme, the Office of General Counsel 

correctly recommended against finding reason to believe that 

central figures identified in the Complaint violated the law.

The complaint in this Matter largely relies on press characterizations of a pitch 

memo and accompanying chart allegedly emailed by Jeff Pitts, a Florida political 

actor and the chief executive officer of Matrix, LLC. The relevant press reports

included an image of the chart but not the accompanying memo.8

The chart shows how funds could flow from initial contributions by Florida 

Power and Light (“FPL”), through intermediary entities, and ultimately to three 

different nonprofit corporations—one of which, labeled “Fed Promise” (and bearing 

the cautionary note “Waiting on lawyers”), seemed to be directed toward federal 

activity.9 The other two organizations were, similarly, directed toward Florida state 

and local elections.10

6 Statement of Reasons of Vice Chair Dickerson and Comm’r Trainor at 10, MURs 7427 et al. (Nat’l 

Rifle Ass’n), Dec. 23, 2021.

7 Dem. Cong. Campaign Comm. v. Fed. Election Comm’n, 831 F.2d 1131, 1135 (D.C. Cir. 1987) (“The 

Commission or the individual Commissioners” must provide a statement of reasons why the agency 

“rejected or failed to follow the General Counsel’s recommendation”).

8 FGCR at 34. 

9 Complaint at 15, ¶ 33.

10 Id. 

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As the Complaint itself concedes, this precise scheme was never put into 

effect.11 Instead, the Complainant created an entirely new theory. Given its 

complexity, the Complaint includes a helpful chart explaining its view of a potential 

conspiracy to violate campaign finance rules.12 

11 Id. at 19, ¶ 41 (“[D]uring the 2020 election the Unknown Respondents...appear to have used a 

version of the funding structure laid out in the Pitts Memo”) (emphasis supplied). 

12 Complaint at 21, fig. 2. 

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It goes without saying that this chart is not, itself, evidence of anything. It is 

merely a demonstrative exhibit created by the Complainant. Nevertheless, it is worth 

noting that, of the eleven named organizations in the Complainant’s diagrammed 

conspiracy, eight have seemingly sprouted anew and have no basis in the chart 

allegedly shopped around by Pitts.13 Key players, including Florida Power and Light 

and Fed Promise, among others, are nowhere to be found. Only three organizations 

from the original reporting, marked in orange, find a place in the Complaint’s 

refashioned scheme.

The most notable change is at the top: Florida Power and Light has been 

replaced by unspecified “Sources of Funds”—the titular “Unknown Respondents” in 

this Matter. The Complaint does not absolve FPL, but neither does it insist that FPL 

is the “original source” of the contributions made at the bottom of the chart.

As it happens, this is for good reason. Florida Power and Light filed a lengthy 

response, including an affidavit from Eric Silagy, “the former chairman, president, 

13 Commission staff nevertheless named groups from the Pitts chart as respondents, such as SUN 

Marketing and Advertising. Tim Fitzpatrick, the sole member of SUN Marketing and Advertising, 

filed a response with the Commission stating that it “did not make any payments or contributions to 

any political candidates, political campaigns, political action committees[,] or to any 501(c)(4) entity.” 

Fitzpatrick Resp. at 1. This statement is unrebutted in the record before us.

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and chief executive officer” of the company who “oversaw all aspects of FPL’s 

operations, including its government affairs and political activities throughout 

2020.” 14 Mr. Silagy categorically denied “direct[ing] any of the nonprofit 

organizations to make any contribution of FPL funds to any of the federal PACs,” 

“enter[ing] into an agreement with any of the nonprofit organizations to earmark any 

contributions from FPL to the federal PACs,” “exercis[ing] control over how the 

nonprofit organizations used any FPL contributions,” or “authoriz[ing] any other FPL 

employee” to do the same.15 For good measure, Mr. Silagy also denied “aware[ness] 

of any other FPL employee engaging in any of the activities described.”16 Despite 

OGC’s quibbles,17 Mr. Silagy’s affidavit is unrebutted, and OGC does not recommend 

RTB as regards FPL.

Without reason to believe that FPL served as the source of funds involved in 

the alleged conduit scheme, the Complaint runs into an obvious problem. Where did 

the funds behind this intricate conspiracy originate? The best answer we receive is 

the bare assertion that Matrix “pitched the...plan” to other potential funders and that 

one or more of those unidentified persons presumably agreed to break the law.18 

But there is no evidence whatsoever for that assertion. The next best thing is 

a single quote, which OGC mentions almost in passing, noting that an FPL 

spokesperson stated his “understand[ing]” that “Matrix created a proposal to fund 

their clients’ communication and outreach activities during 2020.”19 That statement 

cannot possibly bear the weight thrust upon it. The italicized word – emphasis added 

by OGC – is the thin reed upon which the Complaint’s elaborate structure is based.

A spokesperson’s “understanding” is the remotest of hearsay, and even if Matrix 

created a proposal, and even if it was shared with other clients – none of which the 

spokesperson actually said – that provides no basis beyond bare speculation for 

believing some other entity stepped into FPL’s shoes. And if Matrix didn’t pitch the 

plan to others, the Complaint falls apart. 

So much for the source of funds. What of the contributions eventually made, 

the bottom of the Complaint’s explanatory flowchart? 

14 Silagy Decl. at 1, ¶¶ 1, 4. 

15 Id. at ¶ 5

16 Id. 

17 FGCR at 41-42.

18 FGCR at 10.

19 Id. (emphasis in original).

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There is no allegation that any of those contributions was itself unlawful. Each

contributor had the acknowledged First Amendment right to make contributions to 

fund independent expenditures in federal campaigns.20 The legal question is whether 

these contributions were in fact made by others, using the titular contributors as 

mere conduits. The fact that the contributions were made tells us nothing on that 

score. In any event, the various recipient committees also filed responses, each of 

which disclaimed any role in any conspiracy to evade the federal disclosure laws. 21

Nothing in the record before us contradicts these responses.

This leaves us with the middle of the chart, which names six entities. The first, 

and one of the few organizations named in both the original press reports and the 

Complaint, is Let’s Preserve the American Dream (“LPAD”). The Complaint suggests 

that LPAD served as a conduit whereby unknown parties provided it with funds 

earmarked for eventual political contributions, and that it in fact gave $1,115,000 to 

Grow United, Inc. and $26,000 to Broken Promises toward that end. LPAD filed a 

response stating the obvious: while “some of the nonprofit organizations identified in 

Mr. Pitts’ memo eventually made contributions to certain political committees, that 

does not show that a plan resembling the one detailed in the flowchart was ever put 

into effect...the Complaint presents no evidence that the contributions at issue in this 

20 SpeechNow.org v. Fed. Election Comm’n, 599 F.3d 686 (D.C. Cir. 2010) (en banc).

21 Resp. of Concerned Conservatives, Inc. at 1-2 (“If read devoid of speculations and legal conclusions, 

the Complaint demonstrates that the Respondents followed the law and Commission regulations. The 

Respondents received a $20,000 contribution from Broken Promises—a small portion of the $509,357 

the Respondents raised in the 2020 cycle. There was and still is nothing suspicious about the 

contribution”); Resp. of South Fla. Residents First (“SFRF”) at 1 (“SFRF had no knowledge or reason 

to believe that Stand Up for Justice’s contribution was from anyone other than Stand Up for Justice”); 

Resp. of Senate Leadership Fund at 2 (“Senate Leadership Fund is not referenced in any way in this 

flowchart...CREW presents no evidence suggesting that Senate Leadership Fund had any knowledge 

of the scheme CREW alleges or that Senate Leadership Fund had any reason to doubt the ‘true source’ 

of the contribution it received from Florida Promise, Inc.”); Resp. of Am. Valor PAC at 1-2 (“Instead, 

the Complainant makes conclusory statements that the AVP knew that Center for Advancement of 

Integrity & Justice’s contribution was in the name of another without providing any reasoning or 

support for that statement. The reason they cannot provide such evidence is because AVP had no 

knowledge or reason to believe that Center for Advancement of Integrity & Justice’s contribution was 

from anyone other than Center for Advancement of Integrity & Justice”); Resp. of Conservative Action 

Fund (“CAF”) (f/k/a Wingman PAC) at 1 (“The Complainant’s allegations, as applied to CAF, are 

meritless, as CAF had no knowledge, nor any reason to believe, that Grow United’s contribution was 

made on behalf of anyone other than Grow United”); Resp. of Abby Dupree (“Ms. Dupree was not aware 

of who contributed to Grow United, Inc., nor was the investigation of same part of her duties or

responsibilities as treasurer for Wingman PAC. Ms. Dupree was not involved in the creation of Grow

United, Inc., did not assist in soliciting funds on Grow United, Inc.’s behalf nor did she serve in any

executive or administrative role whatsoever for that entity”) 

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[M]atter were made as part of a collaborative scheme to evade federal disclosure 

requirements.”22 

Having articulated the central problem with the Complaint, LPAD went 

further, informing the Commission that “[a]s a matter of course, whenever it has 

received donations, LPAD confirms in writing that any decisions concerning the 

disposition of the funds are left solely to LPAD’s discretion” and “[l]ikewise, whenever 

LPAD has donated to other organizations (including when it made the two donations 

identified above), a contemporaneous assurance letter confirms that the recipient is 

vested with sole discretion over the use of the donated funds.” 23 Additionally, Ryan 

Tyson, the executive director of LPAD (who is obliquely mentioned in the Pitts chart), 

filed a sworn statement with the Commission affirming that practice, and stating 

that “LPAD had no involvement in the alleged scheme detailed in the Complaint, nor 

do I have any reason to conclude that any plan like the one proposed by Mr. Pitts was 

ever implemented.” 24 Nothing before us contradicts Mr. Tyson’s sworn statement.25

To summarize, the Complaint is premised upon press reports asserting a wideranging conduit-contribution scheme. But upon review of the evidence, the Office of 

General Counsel correctly declined to recommend RTB against two of the central 

figures in the allegations – including the originally-reported source of the funds 

contributed, and the principal conduit alleged in the original press reporting. 

22 LPAD Resp. at 2. 

23 Id. at 4.

24 Tyson Decl. at 1-3. 

25 Despite not recommending RTB against LPAD, OGC attempts to jiu-jitsu exculpatory evidence 

submitted by a respondent to cast doubt on Mr. Tyson’s statement, pointing to testimony in another 

legal proceeding. FPL Resp. Ex. A. In that deposition, Mr. Tyson stated that Pitts referred him to 

Grow United when Tyson asked him about “‘social welfare groups that are interested in working on 

issues...purely on the center left spectrum and on issues that are center left.’” FGCR at 24. 

This is exculpatory for LPAD (and for Grow United and Pitts). Mr. Tyson’s statement undermines the 

allegation that LPAD sought to work with Grow United to back federal candidates, as opposed to 

merely engaging in issue speech activity outside the Commission’s jurisdiction. Id. at 24 (quoting 

Tyson Dep. at 17:10-14).

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II. Despite the lack of evidence indicating that the Complaint’s alleged 

conspiracy was put into effect, the Office of General Counsel 

recommended reason to believe against five now-defunct 

organizations. 

Despite recognizing the clear flaws in the Complaint’s speculative theory and 

declining to recommend RTB against its central players, OGC recommended RTB as 

to the other five Contributing Corporations detailed in the Complaint’s chart:26

Florida Promise, Inc.; the Center for Advancement of Integrity and Justice, Inc.

(“CAIJ”); Grow United, Inc.; Broken Promises; and Stand Up for Justice.

OGC principally relies upon the purportedly close relationship between these 

organizations and Matrix, as demonstrated through connections between Pitts and 

two men, Richard Alexander and Sean Anderson, affiliated with the Contributing 

Corporations. In its telling, “the five contributions” made by these corporations are 

“consistent with the conduit contributions proposed by Pitts and Matrix,” and “all 

five” of the corporations “appear to be controlled by or associated with Pitts and 

Matrix.” 27

It is not clear why these connections should matter. OGC’s theory hinges on 

the fact the organizations’ contributions are “consistent” with Pitts’ purported conduit 

scheme. But, as already explained, there is no evidence Pitts approached anyone to 

serve as the original source of the funds for that scheme, and no evidence anyone he 

may have approached agreed to participate.28 In other words, there is no evidence the 

scheme was carried out or that the “original funds” even existed. Without that crucial 

step, OGC’s theory is circular: Pitt’s connection to the alleged conduits is proof the 

original scheme was put into effect, but the evidence for these corporations being 

conduits is the existence of the scheme itself. OGC’s theory fails for this independent 

reason.

Moreover, OGC resists the obvious implication of the evidence before it: that 

Pitts and Matrix intended to comply with the law, sought legal advice to ensure they

did, and ultimately did not engage in a clearly unlawful conduit scheme contrary to 

that advice. By contrast with the complete lack of evidence supporting the 

26 FGCR at 46-47. OGC refers to these organizations as the “Conduit Corporations,” but that label 

stacks the deck (and begs the question). The issue is whether there is reason to believe they are 

conduits. 

27 FGCR at 5.

28 Except for FPL, which credibly denied the allegations against it and for which OGC concedes RTB 

does not currently exist.

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Complaint’s insinuations, the legal memoranda upon which it relies apparently 29

emphasized that the purported plan was to “develop a structure for funding 2020 

activities... where laws allow,” and to provide legal counsel concerning “the legalities

of using nonprofits to spend money on federal elections.” 30 There is no indication that 

counsel blessed an unlawful name-of-another scheme, and even the chart on which 

the Complaint heavily relies notes that any involvement with “Fed Promise” was 

“[w]aiting on lawyers.” 31 

OGC ties itself in knots, attempting to shift the burden by repeatedly 

suggesting that there is no evidence disproving a reading of Pitts’ chart as an 

unlawful contribution scheme (while failing to even address the chart itself 

referencing a need to consult with counsel).32 But the clear best reading of the limited 

information available is that Pitts and Matrix sought and complied with legal 

counsel. 

 Unless there is reason to believe the purported scheme was ever put into 

effect, Matrix’s level of control or influence over the Contributing Corporations is 

irrelevant. But even if there were an anonymous donor that gave to each of those 

entities, OGC is mistaken in arguing that there is RTB that each Corporation 

knowingly permitted its name to be used in connection with conduit contributions. 

The nonprofits are defunct, which means they cannot file responses with the 

Commission. But Richard Alexander and Sean Anderson, who “each served in various 

director and officer capacities for” those groups, filed a joint response, arguing that 

“the Complaint does not provide any evidence or other indication” other than the 

complainant’s own assertion “that any ‘true source’ of funds directed and controlled 

funds through the five social welfare organizations associated with Messrs. 

Alexander and Anderson to one or more specific federal candidates or 

committees...[a]t most, the Complaint alleges that a donor may have contributed 

funds to one or more nonprofit organizations as part of a broader political engagement 

29 Like OGC, we have only press reports characterizing these memoranda. To the best of our 

knowledge, neither the Complainant nor OGC has seen them.

30 Complaint at 14, 17-18, ¶¶ 32 and 38 (emphasis supplied, quotation marks omitted). 

31 OGC chooses to read this phrase as expressing doubts as to the purpose of Fed Promise rather than 

a need for legal clearance generally. FGCR at 34, n. 162 and accompanying text. In the absence of any 

corroboration for that view – after all, neither the Complainant nor OGC has read the memos – we 

believe the best reading of this evidence is that Pitts intended to consult with counsel, as he in fact

did. 

32 FGCR at 32-34.

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strategy” but not “with the intent to direct and control the funds through the 

organization to one or more ultimate recipients.”33 

Just so. Under 52 U.S.C. § 30122, there must be reason to believe the 

Contributing Corporations made their contributions at the direction of another. But 

there is no support—none—for that proposition. Instead, OGC zeroes in on assertions 

in news articles34 in an effort to show close connections between Matrix, Pitts, and 

the Contributing Corporations.35 Even that evidence is thin.

OGC’s central theory is that the Contributing Corporations all “appear to have 

been controlled by or associated with Pitts and/or Matrix” because each of them was 

managed in some manner by either Richard Alexander or Sean J. Anderson.36 As a 

preliminary matter, there is a vast difference between being “controlled by” someone 

and being “associated with” that person, a difference OGC does not explore. 

On the evidence, OGC’s first problem is its source. The overwhelming majority 

of support for the Complaint comes from anonymously-sourced reporting in the 

press.37 The Commission has long declined to proceed on the basis of such 

33 Alexander/Anderson Resp at 1-3.

34 And OGC seems to reverse the burden of proof, suggesting that Alexander and Anderson’s failure to 

categorically deny those press reports cuts against their defense. FGCR at 31 (“[Respondents]...do not 

contend that the news articles’ description of Pitts’s and Matrix’s plan to anonymize political activities 

was incorrect”).

35 FGCR at 33 (“Moreover, the conduits depicted on the flowchart appear to have been in fact controlled 

by or associated with Matrix...the layers of corporations depicted on the flowchart appear to be linked 

together because they are controlled by persons associated with Pitts or Matrix”); id. at 35 (“[T]he 

persons nominally in charge of the alleged Conduit Corporations, Alexander and Anderson, had close 

relationships with Pitts and Matrix”); id. at 36, n.168 (“reporting Pitts as having attended Anderson’s 

bachelor party”); id. at n.170 (“reporting that Matrix offered a city councilman a job on behalf of FPL 

using Grow United’s name”); id. at n.171 (“reporting that internal Matrix records included a text 

message from [April] Odom stating that she procured access to the bank accounts of CAIJ and Grow 

United”).

36 FGCR at 10 (capitalization altered for clarity). 

37 OGC disagrees, arguing that “the news articles stated that the sources of the documents were from 

Matrix itself, noting that the documents were internal Matrix documents.” FGCR at 31. But OGC 

truncates the quote; the article explicitly states that the “cache of documents” was “anonymously 

delivered” to the reporters. Jason Garcia & Annie Martin, Operative Pitched Secretive Political 

Spending Plan to FPL Exec’s Email Alias, Records Reveal, Orlando Sentinel, Jan. 24, 2022 (emphasis 

supplied). 

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information.38 As one of us has noted, relying on anonymously-sourced media articles 

as complaint fodder is “antithetical to due process” because “decisions to find RTB 

and set the machinery of government in motion against respondents based upon 

anonymously sourced media reports will necessarily reflect commissioners’ subjective 

views of particular publications and journalists.” 39

Here, OGC took assertions from Florida news articles at face value. For 

instance, OGC’s enforcement theory relies heavily on reporters’ characterizations of 

the memo accompanying the flowchart assembled by Mr. Pitts—a memo OGC has 

never seen. Similarly, OGC argues that the president and chairman of Broken 

Promises “has a history of allowing Pitts to control the nonprofits that [Anderson]

purportedly ran.”40 OGC’s support for this broad accusation? Media reports about a 

single text message allegedly sent by Pitts to the vice president of Florida and Power 

Light—a text that was not even fully quoted in the original article (a fact OGC’s 

Report fails to mention).41 In another such instance, OGC claims that April Odom, a 

Matrix employee, “procured access to Grow United’s bank account.”42 OGC’s sole 

source for this assertion is a purported text message included as one component of an 

illustration.43 And even that graphic does not “state” what OGC says it does.44

38 Policy Statement of Chairman Dickerson Regarding the Commission’s Use of Anonymous Sources 

Reported in the Press at 2-4, Oct. 5, 2022 (collecting precedent).

39 Id. at 8. 

40 FGCR at 33.

41 The original form of the quote is modified and does not include an explicit reference to any particular 

nonprofit. Mary Ellen Klas, et al., ‘Nightmare Scenario’: How FPL Secretly Manipulated a Florida 

State Senate Election, Miami Herald, Aug. 29, 2022 (“‘Bottom line is we are the ones with the check 

books and in control [of the nonprofits] 100 percent,’ Pitts told Martell”) (brackets in original).

42 FGCR at 17. 

43 FGCR at 14, n. 53; Id. at 17., n. 68. OGC frames this text message as being included among “Matrix 

internal records,” id. at 17, but the article itself doesn’t say that. In fact, it never explains the graphic 

upon which OGC relies.

44 Compare FGCR at 17 (“Matrix’s internal records also reportedly include a September 23, 2020 

message from Odom stating that she procured access to Grow United’s bank account”) with Garcia & 

Martin, Florida’s dark money playbook: How ‘ghost’ candidate scheme revealed secretive political 

tactics, Orlando Sentinel Dec. 30, 2021 (“Got the bank accounts for Grow United and Center for 

Advancement of Integrity and Justice”). The difference is important – the original text is ambiguous 

and says nothing about access or control. Odom could have received access to the accounts themselves, 

or could have received bank statements or other information about the accounts. 

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These examples illustrate why the Commission has wisely chosen not to 

proceed with enforcement on the basis of anonymously sourced press reports. Not 

only do we lack necessary context for reporters’ characterizations and assertions, but 

we avoid the great temptation to fill in the gaps and interpret ambiguities against 

respondents. Where, as here, anonymously-sourced reporting, double hearsay, is “the 

main evidence” supporting enforcement, we will not find RTB.45

There are other problems with OGC’s approach. It suggests that Pitts 

controlled the five Contributing Corporations through Alexander and Anderson, but 

in some cases its basis for that assertion is weak. For instance, the Report leans 

heavily on the facts that “Alexander’s sister, April Odom, was a Matrix contractor” 

and that Anderson was friends with Pitts.46 Indeed, as regards Florida Promise, 

Inc.—whose $1,000,000 contribution to the Senate Leadership Fund represents more 

than three quarters of the contributed funds in the Complaint’s chart—the only 

evidence OGC could point to supporting RTB was the organization’s inclusion on 

Matrix’s original chart and the bare fact that Alexander was the organization’s 

chairman.47

At the end of the day, these minor issues are not the crux of the matter. The 

Complaint is premised upon press reports suggesting a specific scheme involving

Florida Power and Light. But that allegation did not pan out. Numerous individuals 

and entities credibly denied their involvement, and their testimony is for the most 

part unrebutted. Accordingly, there is insufficient information to find reason to 

believe that Florida Power and Light, or any other entity, funded an unlawful conduit 

contribution scheme, or that any particular entity acted as a conduit by making 

contributions at the direction of another. OGC’s effort to salvage the Complaint by 

recommending RTB against defunct organizations based upon vague social 

connections and financial entanglements fails for the simple reason that there is no 

reason to believe the overall scheme was ever carried out. 

CONCLUSION

The Federal Election Commission “will not pursue enforcement-by-rumor,” 48

nor by hunch, especially where “OGC’s proposed theory is predicated upon factual 

45 Statement of Reasons of Chairman Dickerson and Comm’rs Cooksey and Trainor at 6, MURs 

7581/7614 (Yang a/k/a Gong), Sept. 6, 2022 (quotation marks omitted); id. at n.30 (collecting cases).

46 FGCR at 10-11. 

47 FGCR at 11-12.

48 Statement of Reasons of Chairman Dickerson and Comm’rs Cooksey and Trainor at 1, MUR 7784 

(Make Am. Great Again PAC), June 9, 2022 (emphasis supplied).

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assumptions about which the record is—at the very best—ambiguous,” and at the 

worst, the product of the type of unreliable pattern-seeking for which humans are 

justifiably infamous.49

Because the evidence before the Commission was insufficient to find reason to 

believe that any of the Contributing Corporations knowingly permitted its name to 

be used for contributions made by an Unknown Contributor, we voted to dismiss the 

complaint.

_________________________________ _________________________

Sean J. Cooksey Date

Chairman

_________________________________ _________________________

Allen J. Dickerson Date

Commissioner

_________________________________ _________________________

James E. “Trey” Trainor, III Date

Commissioner

49 Id. at 12 (emphasis omitted). 

April 8, 2024

April 8, 2024

April 8, 2024

MUR808200514