FEDERAL ELECTION COMMISSION

Washington, DC 20463

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of )

)

White Coat Waste PAC and Janna Rutland ) MUR 7964

 as treasurer )

White Coat Waste Project, Inc. )

Anthony Bellotti )

Justin Goodman )

STATEMENT OF REASONS OF CHAIR DARA LINDENBAUM, VICE CHAIRMAN 

SEAN J. COOKSEY, AND COMMISSIONERS ALLEN J. DICKERSON AND JAMES E. 

“TREY” TRAINOR, III

The Complaint alleges that White Coat Waste PAC and Janna Rutland in her official 

capacity as treasurer (“WCW PAC”), a non-connected multicandidate political committee, is 

financially supported and controlled by White Coat Waste Project, Inc. (“WCW Corp”), a 

section 501(c)(3) corporation, and that WCW PAC is therefore a separate segregated fund of 

WCW Corp.

1

 Respondents deny the allegations and assert that the organizations are financially

and organizationally independent of one another.2 The Office of General Counsel (“OGC”) 

recommended that the Commission find reason to believe that WCW PAC was a separate 

segregated fund of WCW Corp, which resulted in multiple violations of the Federal Election 

Campaign Act of 1971, as amended (the “Act”), and Commission regulations.3 We disagreed

and voted to find no reason to believe that WCW PAC violated the Act or Commission 

regulations with respect to the allegations that WCW PAC was a separate segregated fund of 

WCW Corp.4 We further voted to dismiss as a matter of prosecutorial discretion allegations that 

1 Compl. at 8-9 (Feb. 24, 2022).

2 Resp. at 4-8 (Apr. 15, 2022). 

3 First Gen. Counsel’s Rpt. (“FGCR”) at 2-3, 18-19 (May 4, 2023). Specifically, OGC recommended reason to 

believe that (1) WCW PAC violated 52 U.S.C. § 30103(b) by failing to include the name, address, relationship, and 

type of its connected organization in its statement of organization; (2) WCW PAC violated 52 U.S.C. § 30102(e)(5) 

and 11 C.F.R. § 102.14(c) by failing to include in its name the full name of its connected organization; and (3) 

WCW PAC violated 52 U.S.C. § 30118(b)(4)(a)(i) and 11 C.F.R. § 114.5(g)(1) by soliciting contributions from 

persons outside of its connected organization’s restricted class. Id. at 18-19. In addition, OGC recommended that 

the Commission take no action at this time as to WCW Corp, Anthony Bellotti, and Justin Goodman. Id. at 19.

4 Amended Certification at 2 (July 5, 2023). Specifically, the Commission voted to find no reason to believe on 

each of OGC’s reason to believe recommendations. See supra note 3.

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Statement of Reasons

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WCW Corp made, and WCW PAC accepted, prohibited corporate contributions.5 This 

Statement explains the reasons for our votes.

WCW Corp is a section 501(c)(3) corporation established in 2013 whose mission is to 

combat taxpayer funded experimentation on animals.6 Anthony Bellotti is its founder, president, 

and a board member, and Justin Goodman is its senior vice president.

7

 WCW PAC, which was 

co-founded by Bellotti and Goodman, registered as a non-connected multicandidate political 

committee on February 10, 2017.8 WCW PAC similarly describes its mission as helping to elect 

candidates who oppose taxpayer funded experimentation on animals.9 Bellotti is WCW PAC’s 

president, and Bellotti and Goodman also serve on WCW PAC’s board.10

Relying on publicly available information, the Complaint alleges that WCW Corp is 

listed as the registrant and administrative organization for WCW PAC’s GoDaddy account, 

indicating that WCW Corp financially supported WCW PAC.

11

 However, Respondents 

submitted the sworn Affidavit of Bellotti explaining that he used to own the GoDaddy account 

personally, would pay expenses for both organizations on his personal credit card, and would 

seek reimbursement from the appropriate organization.12 In an effort to professionalize the 

organizations, Bellotti obtained a corporate credit card for WCW Corp, switched the GoDaddy 

domain registration account over to WCW Corp, and mistakenly once paid WCW PAC’s web 

hosting fees with the WCW Corp credit card.13 When the mistake was discovered, Bellotti 

attests that WCW Corp invoiced WCW PAC for reimbursement, which was paid on May 4, 

2022.14 Bellotti further attests that he is “aware of no outstanding payments requiring 

reimbursement that [WCW Corp] has incurred on behalf of [WCW PAC].”15 

While WCW PAC and WCW Corp maintain separate websites, they contain similar 

logos and describe their mission similarly.

16 In all other respects; however, the websites appear 

5 Amended Certification at 2 (July 5, 2023).

6 FGCR at 3; Resp. at 2.

7 FGCR at 3.

8 White Coat Waste PAC, Statement of Organization at 1 (Feb. 10, 2017).

9 FGCR at 4.

10 Id.

11 Compl. at 2 (citing “WHOIS” domain registration database); FGCR at 5. GoDaddy is a corporation that provides 

a variety of web services, including website domain, web hosting, and website design services. GODADDY, 

https://www.godaddy.com/ (last visited July 7, 2023). 

12 Resp., Attach. A, Bellotti Aff. ¶ 4.

13 Id. ¶¶ 6-8.

14 Id. ¶ 10; Resp., Attach. B (copy of invoice). The FGCR notes that there is reason not to credit Bellotti’s Affidavit 

because there is no corresponding disbursement in WCW PAC’s disclosure reports, and the date of the reimbursed 

invoice – July 16, 2022 – postdates the date of supposed payment on May 4, 2022. Id. at 6-7

15 Resp., Attach. A, Bellotti Aff. ¶ 11.

16 The logos have the same basic stop sign shape, similar fonts, and the same phrase “stop taxpayer funded animal 

experiments,” but the logos are different colors, have different backgrounds, and identify the specific organization 

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Statement of Reasons

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different, including the layout, images, language, and content. OGC further asserts that WCW 

PAC and WCW Corp “may be operating from the same location” based on addresses both 

organizations filed with state governmental entities.17 However, the address OGC identifies

appears to be an office for the law firm both organizations used, not a shared office space.

18

A separate segregated fund, also known as a connected political committee, is a 

committee that has a connected organization (such as a corporation, labor union, or trade 

association) that establishes, administers, or financially supports the committee.19 A benefit of 

organizing as a connected political committee is that the committee may use unlimited funds 

from its connected organization to pay for its “[e]stablishment, administration, and solicitation 

costs,” such as “the cost of office space, phones, salaries, utilities, supplies, legal and accounting 

fees, fund-raising and other expenses incurred in setting up and running” the committee.20 These 

payments are not considered contributions and thus are not subject to the Act’s contribution 

prohibitions,21 which otherwise generally prohibit corporations and labor unions from making 

direct or in-kind contributions.22 However, except for two written solicitations per year to the 

general public, the connected political committee may only solicit contributions from members 

of its connected organization’s restricted class, which are the connected organization’s members, 

stockholders, executive or administrative personnel, and their families.23

In contrast, all payments to a non-connected political committee, including those for its 

establishment, administration, and solicitation, are considered direct or in-kind contributions

(i.e., “PAC” vs. “Project”). See FGCR at 5 (including images of each logo). While the websites describe their 

purposes similarly in part, contrary to the FGCR’s selective and partial quotes, they are not identical. Compare

WHITE COAT WASTE PROJECT, INC., https://www.whitecoatwaste.org/ (last visited July 7, 2023) (“White Coat Waste 

Project is a taxpayer watchdog group representing more than 2 million liberty-lovers and animal-lovers who all 

agree: taxpayers shouldn’t be forced to pay over $20 billion every year for wasteful and cruel experiments on dogs, 

cats, monkeys and other animals.”), with WHITE COAT WASTE PAC, https://www.whitecoatwastepac.org/ (last 

visited July 7, 2023) (“The nonpartisan White Coat Waste PAC empowers Americans to help elect candidates for 

U.S. Congress who are committed to ending $20 billion in wasteful and cruel taxpayer-funded animal 

experiments.”). 

17 FGCR at 7. OGC also notes that WCW PAC identified two P.O. boxes in reports filed with the Commission, but 

did not report any corresponding disbursements in its disclosure reports. Id. at 13.

18 Resp. at 7; Holtzman Vogel, https://www.holtzmanvogel.com/ (last visited July 7, 2023) (reflecting an office at 

15405 John Marshall Hwy, Haymarket, VA 20169).

19 52 U.S.C. §§ 30101(7), 30118(b)(2); 11 C.F.R. § 100.6(a). For the purposes of determining whether a committee 

has a connected organization, financial support for the committee “does not include contributions to the political 

committee, but does include the payment of establishment, administration and solicitation costs of such committee.” 

11 C.F.R. § 100.6(c). 

20 11 C.F.R. §§ 114.1(b), 114.5(b). 

21 11 C.F.R. § 114.1(a)(2)(iii). 

22 52 U.S.C. § 30118(a). Corporations may contribute to independent-expenditure-only political committees 

(“IEOPCs”). Advisory Opinion 2010-11 at 2-3 (Commonsense Ten) (“AO 2010-11”). 

23 52 U.S.C. § 30118(b)(4); 11 C.F.R. §§ 114.1(j), 114.5(g), 114.6(a)-(b). 

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Statement of Reasons

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subject to the limits and prohibitions of the Act, unless another exception applies.24 In exchange, 

the non-connected political committee is permitted to solicit contributions from the general 

public.25 In determining whether a committee is a separate segregated fund, the Commission has 

considered: (1) “whether the committee is financially supported by that corporation” and (2) “the 

organizational independence of the committee from any other incorporated entity.”26 Under 

Commission regulations, “the term financially supports does not include contributions to the 

political committee, but does include the payment of establishment, administration and 

solicitation costs of such committee.”

27

OGC argues that several facts in the record indicate that WCW Corp financially 

supported WCW PAC. For example, OGC points to WCW Corp’s payment of $188 to 

GoDaddy for hosting WCW PAC’s website.

28

 However, Bellotti’s Affidavit adequately explains 

that the payment was a mistake and WCW PAC promptly reimbursed WCW Corp.

29

 But even if 

we did not credit Bellotti’s Affidavit, as OGC urges us to do, we do not believe that WCW 

Corp’s single payment of $188 reflects the level of financial support necessary to find that WCW 

PAC is a separate segregated fund. 

In another example, OGC asserts that WCW Corp and WCW PAC shared office space

and WCW PAC’s disclosure reports do not reflect any disbursements to WCW Corp for rent.

30

 

However, the Response explained that the Complaint merely identified the address of the law 

firm both organizations used, and the law firm’s website corroborates the Response’s 

explanation.

31

 

OGC finally argues that the organizations’ similar names, logos, and phrasing of the 

organizations’ purposes on their respective websites indicate that WCW Corp paid for WCW 

PAC’s solicitation costs in the form of WCW PAC’s use of WCW Corp’s intellectual property

free of charge.

32

 We disagree. OGC cites to MUR 7302 for the proposition “that a corporation’s 

name, trade name, trademarks, and service marks are things of value owned by the corporation,

and that allowing a committee to use them in a manner suggesting the corporation’s support or 

24 Advisory Op. 1997-26 (Assoc. of Metropolitan Sewerage Industries); F&LA at 4, MUR 6746 (AICPAC). 

25 F&LA at 3, MUR 5830 (U.S.-Cuba Democracy PAC, et al.). 

26 F&LA at 4, MUR 6746 (AICPAC) (citing Advisory Op. 1997-26 (Assoc. of Metropolitan Sewerage Industries)).

27 11 C.F.R. § 100.6(c) (italics omitted).

28 FGCR at 12.

29 Resp., Attach. A, Bellotti Aff. ¶ 9.

30 FGCR 12-13 (identifying the address, 15405 John Marshall Hwy, from the organizations’ public filings).

31 Resp. at 7 Holtzman Vogel, https://www.holtzmanvogel.com/ (last visited July 7, 2023) (reflecting an office at 

15405 John Marshall Hwy, Haymarket, VA 20169).

32 FGCR at 11.

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Statement of Reasons

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endorsement of a candidate may constitute an in-kind contribution.”33 However, in MUR 7302,

the Commission dismissed as de minimis the allegations that a candidate’s use of a corporate 

name and logo in television ads constituted prohibited corporate contributions.

34

 Accordingly, 

even if OGC’s thing-of-value analysis is correct, the value here is likely de minimis and, thus, 

not probative of WCW Corp’s financial support of WCW PAC.

In sum, the Complaint has not identified information sufficient to establish that WCW 

Corp financially supported WCW PAC and, therefore, we need not reach the issue of 

organizational independence. For these reasons, we voted to find no reason to believe that 

WCW PAC violated the Act or Commission regulations with respect to the allegations that 

WCW PAC was a separate segregated fund of WCW Corp.

35

 

Given that we find that WCW PAC correctly registered as a non-connected PAC, it was 

prohibited from accepting corporate contributions, including contributions from WCW Corp.

36

To the extent the facts discussed above resulted in WCW Corp making in-kind contributions to 

WCW PAC, the value was likely de minimis and not worth the Commission’s resources to 

pursue further.37 We therefore voted to dismiss as a matter of prosecutorial discretion the 

allegations that WCW Corp made, and WCW PAC accepted, prohibited corporate 

contributions.

38

__________________ ___________________

Date Dara Lindenbaum

Chair 

__________________ _______________________

Date Sean J. Cooksey

Vice Chairman

33 F&LA at 4, MUR 7302 (Tom Campbell for North Dakota). Given that the name, logo and phrases of WCW PAC 

and WCW Corp are not identical, and that a corporation’s endorsement of a candidate is not at issue here, it is not 

clear whether this broad legal proposition from MUR 7302 even applies to this matter.

34 F&LA at 5, MUR 7302 (Tom Campbell for North Dakota); see also F&LA at 7, MUR 6542 (Mullin for 

Congress) (same). 

35 Amended Certification at ¶ 2a-c.

36 52 U.S.C. § 30118(a).

37 F&LA at 5, MUR 7302 (Tom Campbell for North Dakota) (dismissing similar allegations as de minimis); F&LA 

at 7, MUR 6542 (Mullin for Congress) (same).

38 Amended Certification ¶ 2d; see also Heckler v. Chaney, 470 U.S. 821 (1985).

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Statement of Reasons

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__________________ _______________________

Date Allen J. Dickerson

Commissioner

__________________ _______________________

Date James E. “Trey” Trainor, III

Commissioner 

7/27/23

7/27/23

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