1 

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

CAMPAIGN LEGAL CENTER

1101 14th Street NW, Suite 400 

Washington, DC 20005, 

 Plaintiff,

v. Civil Action No. ________________

FEDERAL ELECTION COMMISSION

1050 First Street NE

Washington, DC 20463, 

 Defendant. 

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

1. Plaintiff Campaign Legal Center (“CLC”) brings this action against the Federal 

Election Commission (“FEC” or “Commission”) for declaratory and injunctive relief pursuant to 

52 U.S.C. § 30109(a)(8), challenging as contrary to law the FEC’s dismissal of an administrative 

complaint, and a supplement to that complaint, that CLC filed against former President and 2020 

presidential candidate Donald J. Trump’s authorized campaign committee, Donald J. Trump for 

President, Inc. (“Campaign” or “Trump Campaign”),1 and one of his authorized joint fundraising 

committees, Trump Make America Great Again Committee (“TMAGA”; collectively, 

“Committees” or “Trump Committees”) for violations of the Federal Election Campaign Act 

(“FECA” or “Act”). 

2. The administrative complaint—filed with the FEC on July 28, 2020, and 

supplemented on January 28, 2021, and collectively designated Matter Under Review (“MUR”) 

 

1

 In February 2021, after CLC filed its complaint and supplement, the Trump Campaign changed 

its name to Make America Great Again PAC and converted to a multicandidate committee. See

Statement of Reasons of Chairman Allen J. Dickerson and Comm’rs Sean J. Cooksey and James 

E. “Trey” Trainor, III at 1 n.1, MUR 7784 (Make America Great Again PAC, et al.) (June 9, 2022), 

https://www.fec.gov/files/legal/murs/7784/7784_42.pdf. 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 1 of 26
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7784 (Make America Great Again PAC, et al.)

2

—alleged that the Trump Committees had violated 

52 U.S.C. § 30104(b) by failing to properly disclose hundreds of millions of dollars in payments 

to subvendors and staff made through two firms affiliated with the Trump Campaign. Ex. 1, 

Admin. Compl. ¶¶ 1-2, 81, 91; Ex. 2, Suppl. to Admin. Compl. 6. In particular, the complaint and 

its supplement alleged that the Trump Committees had laundered upwards of three quarters of a 

billion dollars in 2020 campaign spending through American Made Media Consultants, LLC

(“AMMC”)—a corporation apparently created and controlled by Campaign officials—and 

Parscale Strategy, LLC—the consulting firm of former Campaign manager Bradley J. Parscale—

thereby disguising the details of the transactions and the identities of the ultimate payees. Ex. 1, 

Admin. Compl. ¶ 2; Ex. 2, Suppl. to Admin. Compl. 1-2. 

3. Drawing on publicly available information, including press reports, statements by 

Campaign officials and contractors, FEC disclosure reports, and filings with other federal and state 

government agencies, the administrative complaint and its supplement documented how AMMC 

was created and run by Trump Campaign officials and used by the Committees to distribute 

hundreds of millions of dollars in campaign spending without disclosing the ultimate payees or 

accurately reporting the details or purposes of the payments. The administrative filings also 

described how the Trump Campaign used Parscale Strategy as a conduit to pay staff salaries, 

including to senior Campaign officials and Trump family members, again without accurately

disclosing the details or purposes of the transactions. 

4. The administrative complaint asked the Commission (1) to find reason to believe 

that the Committees had violated § 30104(b) by failing to properly itemize and report their 

 

2

 The July 28, 2020 administrative complaint and the January 28, 2021 supplement are attached 

hereto as Exhibits 1 and 2, respectively. Other documents in the MUR file are available on the 

FEC’s website, at https://www.fec.gov/data/legal/matter-under-review/7784. 

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disbursements, (2) to conduct an investigation to determine whether a violation had occurred or 

was about to occur, and (3) to seek appropriate sanctions. Ex. 1, Admin. Compl. ¶¶ 92-93. 

5. After reviewing the allegations in CLC’s administrative filings, the FEC’s

nonpartisan Office of General Counsel (“OGC”) recommended that the Commission find reason 

to believe that (1) the Committees violated FECA through their failure to disclose the ultimate 

payees of disbursements made through AMMC and (2) the Trump Campaign violated the Act by 

failing to disclose the ultimate payees and actual purposes of disbursements made through Parscale 

Strategy. See First General Counsel’s Report at 1-2, MUR 7784 (Apr. 6, 2022), https://www.fec.

gov/files/legal/murs/7784/7784_31.pdf (“OGC Report”). 

6. Despite OGC’s recommendation, the Commission failed, by a vote of 3-3, to obtain 

the four affirmative votes needed to find reason to believe and proceed with an investigation into 

the alleged violations. See Certification at 1-3, MUR 7784 (dated May 11, 2022), https://www.fec.

gov/files/legal/murs/7784/7784_32.pdf. The Commission subsequently voted 4-2 to close the file, 

dismissing the complaint. See id. at 3. 

7. The Commission’s failure to find reason to believe and consequent dismissal of 

Plaintiff’s administrative complaint rested on impermissible interpretations of FECA and FEC 

regulations and was arbitrary, capricious, and otherwise contrary to law. See Orloski v. FEC, 795 

F.2d 156, 161 (D.C. Cir. 1986). 

8. This failure to enforce FECA’s disclosure requirements undermines voters’ right to 

know “where political campaign money comes from and how it is spent,” Buckley v. Valeo, 424 

U.S. 1, 66 (1976) (per curiam) (quoting H.R. Rep. No. 92-564, at 4 (1971)), and “to make informed 

decisions” in elections, Citizens United v. FEC, 558 U.S. 310, 371 (2010). Moreover, the 

Commission’s dismissal of Plaintiff’s well-supported allegations encourages future campaigns—

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including any 2024 Trump presidential campaign3

—to seek to evade the Act’s transparency

requirements by similarly laundering payments through a small number of reported vendors. 

9. The Commission’s dismissal of Plaintiff’s administrative complaint injures CLC 

by depriving it of statutorily mandated disclosure information upon which CLC relies to complete 

its work and advance its mission. Without full and accurate reporting by the administrative 

respondents, Plaintiff cannot know what vendors and individuals ultimately supplied the services 

for which the Trump Committees paid through AMMC or Parscale Strategy, nor the amounts, 

dates, and purposes of payments ultimately made to those vendors. FECA legally entitles CLC to 

this information. 

10. Plaintiff therefore requests that this Court declare that the FEC’s dismissal of the 

administrative complaint and its supplement was arbitrary, capricious, and contrary to law, and 

order the Commission to conform with such declaration within thirty days. 

JURISDICTION AND VENUE

11. This Court has both subject matter jurisdiction over this action and personal 

jurisdiction over the parties pursuant to 52 U.S.C § 30109(a)(8)(A) and 28 U.S.C. § 1331. 

 

3

 Former President Trump has repeatedly signaled that he plans to once again be a candidate for 

President in the 2024 election. See, e.g., Jill Colvin, Donald Trump Teases 2024 Presidential Run 

at Conservative Conference, PBS (June 17, 2022), https://www.pbs.org/newshour/politics/trumpteases-2024-presidential-run-at-conservative-conference; Mary Papenfuss, Trump Says Only 

Hurdle to 2024 Run Would Be a ‘Bad Call from a Doctor,’ Yahoo! News (Sept. 25, 2021), https://

news.yahoo.com/trump-says-only-hurdle-2024-231133553.html; Cheryl Teh, Trump Drops the 

Biggest Hint Yet that He’ll Be Running in 2024, Calling Himself the ‘45th and 47th President’ in 

a Video, Insider (Jan. 26, 2022), https://www.businessinsider.com/trump-drops-hint-about-2024-

run-calling-himself-47th-president-2022-1. Indeed, Trump may already have triggered candidate 

status under FECA based on his public statements and conduct. See, e.g., American Bridge PAC, 

FEC Complaint Against Donald J. Trump (Mar. 14, 2022), https://americanbridgepac.org/wpcontent/uploads/2022/03/Trump-FEC-complaint-edits-v2.pdf; Meg Kinnard, Trump Accused of 

Breaking Campaign Laws by Teasing 2024 Run, ABC News (Mar. 14, 2022), https://abcn.ws/

3t8X74G. 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 4 of 26
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12. Venue lies in this district under 52 U.S.C. § 30109(a)(8)(A).

THE PARTIES

13. Plaintiff CLC is a nonpartisan, nonprofit organization that works to strengthen 

American democracy through, among other activities, local, state, and federal efforts to ensure that 

the public has access to information regarding the financing and spending of U.S. election 

campaigns.

14. As part of this effort, CLC conducts research, authors reports and articles, and 

regularly provides expert analysis to the media. CLC also litigates throughout the country 

regarding campaign finance matters; files FEC complaints requesting that enforcement actions be 

taken against individuals or organizations that violate the law; participates in rulemaking and 

advisory opinion proceedings before the FEC to ensure that the agency is properly interpreting and 

enforcing federal campaign finance laws; and engages in legislative advocacy for reform measures 

at the federal, state, and local levels.

15. CLC relies on the accurate and complete reporting of campaign finance information 

to carry out activities central to its mission, including the production of reports and other materials 

to educate the public about campaign spending. These activities are obstructed when information 

that is subject to mandatory disclosure under FECA is not publicly available. 

16. CLC expends significant resources assisting reporters and other members of the 

media in their investigative research into candidates’ financial activities, to ensure that the public 

is equipped with the information necessary to evaluate different candidates and messages and to 

cast informed votes.

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17. CLC also uses its analyses of federal campaign finance disclosure information to 

support its administrative practice at the FEC and before state and local campaign finance agencies, 

and to defend campaign finance laws in its active docket of cases in federal and state courts.

18. When inadequate disclosure of federal campaign finance activity makes it difficult 

to ascertain the nature of a committee’s spending, reporters often contact CLC for guidance as to 

whether or where they can find the campaign finance information that is not being properly 

reported. This work requires CLC to divert resources and funds from other organizational needs. 

19. Defendant FEC is an independent federal agency charged with the administration 

and civil enforcement of FECA. 52 U.S.C. § 30106(b). 

STATUTORY AND REGULATORY BACKGROUND

FECA’s Disclosure and Reporting Requirements

20. FECA requires that “[e]ach treasurer of a political committee . . . file reports of 

receipts and disbursements” with the Commission. 52 U.S.C. § 30104(a)(1). These reports must 

disclose “the name and address” of each person to whom the committee has made operating 

expenditures or other disbursements of over $200, “together with the date[s], amount[s], and 

purpose[s]” of those expenditures or disbursements. Id. § 30104(b)(5), (6). 

21. FEC regulations similarly require that political committees disclose the dates, 

amounts, and purposes of expenditures and disbursements in excess of $200. 11 C.F.R. 

§ 104.3(b)(3)(i), (b)(4)(i). Those regulations define “purpose” to mean “a brief statement or 

description of why the disbursement was made.” Id. § 104.3(b)(3)(i)(A), (b)(4)(i)(A). 

22. A Commission policy statement further provides that the “purpose” description, 

together with the recipient’s name, should enable “a person not associated with the committee [to]

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easily discern why the disbursement was made.” Statement of Policy: “Purpose of Disbursement” 

Entries for Filings with the Commission, 72 Fed. Reg. 887, 888 (Jan. 9, 2007). 

23. Commission precedent makes clear that a federal political committee must itemize 

payments to a subvendor if (1) the immediate vendor receiving the disbursement does not have an 

arm’s-length relationship with the committee, (2) the payments to the subvendor are unrelated to 

the services provided pursuant to the immediate vendor’s contract with the committee, or (3) the 

immediate vendor is merely acting as a “conduit” for disbursements to subvendors. See, e.g., 

General Counsel’s Brief 33-37, MUR 3847 (Stockman) (Sept. 15, 1997); Conciliation Agreement 

2-4, MUR 4872 (Jenkins) (Feb. 15, 2002); Factual and Legal Analysis at 8-10, MUR 6724 

(Bachmann for President) (July 13, 2017). Under these circumstances, failing to itemize 

disbursements to the ultimate payee violates 52 U.S.C. § 30104(b). 

24. In addition, Commission precedent specifically indicates that political committees 

must itemize and individually report salary payments to committee staffers, even when those 

staffers are paid through an outside firm. See Factual and Legal Analysis at 4-6, MUR 6818 (Allen 

Weh for Senate) (June 15, 2017); see also Factual and Legal Analysis at 8-10, MUR 6724 

(Bachmann for President) (July 13, 2017). 

25. The Supreme Court has recognized the importance of FECA’s disclosure and 

reporting requirements, which “provide[] the electorate with information ‘as to where political 

campaign money comes from and how it is spent,’” Buckley, 424 U.S. at 66 (quoting H.R. Rep. 

No. 92-564, at 4 (1971)), and thereby “enable[] the electorate to make informed decisions,” 

Citizens United, 558 U.S. at 371. 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 7 of 26
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Governing Administrative and Judicial Process

26. Any person may file a complaint with the FEC alleging a violation of FECA. 52 

U.S.C. § 30109(a)(1). Commission regulations specify, in relevant part, that a complaint must 

identify the complainants and be sworn and signed, and that any allegations in a complaint “not

based upon personal knowledge” should identify the source of the information that “gives rise to

the complainant’s belief in the truth of such.” 11 C.F.R. § 111.4(b), (d). 

27. The Commission, after reviewing the complaint, any responses, and OGC’s

recommendation, then votes on whether there is “reason to believe” a violation has occurred. 52 

U.S.C. § 30109(a)(2). The Commission will find “reason to believe” where a complaint “credibly 

alleges” that a FECA violation “may have occurred.” FEC, Statement of Policy Regarding 

Commission Action in Matters at the Initial Stage in the Enforcement Process, 72 Fed. Reg. 

12,545, 12,545 (Mar. 16, 2007). 

28. Any “party aggrieved” by the Commission’s dismissal or failure to act upon an 

administrative complaint may seek judicial review in the U.S. District Court for the District of 

Columbia. 52 U.S.C. § 30109(a)(8)(A).

FACTUAL BACKGROUND

CLC’s Administrative Complaint Against the Trump Committees

29. CLC and Margaret Christ, an individual, filed an administrative complaint with the 

FEC against the Trump Campaign and TMAGA on July 28, 2020. The complaint alleged that the 

Committees had violated 52 U.S.C. § 30104(b) by routing payments to vendors and staff through 

AMMC and Parscale Strategy without itemizing those disbursements or properly reporting them 

to the FEC. Ex. 1, Admin. Compl. ¶¶ 70-91. The FEC designated the matter initiated by the 

administrative complaint as MUR 7784. 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 8 of 26
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30. On January 28, 2021, CLC and Christ filed a supplement to the July 28, 2020 

complaint with the Commission. The supplement explained that the Committees had continued to 

route payments through AMMC and Parscale Strategy after CLC filed its administrative 

complaint. Ex. 2, Suppl. to Admin. Compl. 1-2. The supplement also described reporting from 

December 2020 showing that senior Trump Campaign officials had approved AMMC’s creation 

and appeared on its board, providing further evidence that AMMC was an extension of the Trump 

Campaign used to conceal the Campaign’s spending. Id. at 2-3. 

31. Drawing on publicly available information—including media reports, public 

statements by Trump Campaign officials and contractors, FEC disclosure reports, and filings with 

other state and federal agencies—the complaint and its supplement alleged that the Committees 

violated FECA by failing to itemize and accurately describe the purposes of payments to 

subvendors paid through AMMC and Parscale Strategy even though those firms both (1) did not 

have arm’s-length relationships with the Committees and (2) were used by the Committees as 

conduits for disbursements to subvendors that were effectively working directly for the 

Committees. 

AMMC

32. The administrative complaint and its supplement alleged both that the Trump 

Committees did not have an arm’s-length relationship with AMMC and that AMMC acted merely 

as a conduit for disbursements to subvendors.4

33. First, the complaint and supplement alleged that the Committees and AMMC did 

not have an arm’s-length relationship according to the key factors set forth in Commission 

precedent, which include whether a vendor’s principals held positions with a campaign, whether 

 

4

 See Ex. 1, Admin. Compl. ¶¶ 73-81. 

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those principals held themselves out to the public as campaign officials, whether the vendor 

operated out of campaign headquarters, and whether the vendor was devoted largely to the 

campaign.5

 

34. CLC’s administrative filings described the substantial evidence that officials from 

the Trump Campaign approved of and oversaw AMMC’s creation and participated in its corporate 

governance, including: 

a. Published reports indicating that Jared Kushner, a senior Campaign official, 

“approved the creation of” AMMC.

6

 

b. Corporate filings with state authorities and the Federal Communications 

Commission showing that Campaign officials served as officers of AMMC and its 

parent corporation and that AMMC’s parent company shared an address with the 

Campaign’s compliance firm.

7

c. Numerous media reports describing AMMC as “created,”8 “established,”9 or “set 

up” by the Campaign or its officials.10

 

5

 See Ex. 1, Admin. Compl. ¶¶ 13-25, 73-74; Ex. 2, Suppl. to Admin. Compl. 2-3. 

6

 Ex. 2, Suppl. to Admin. Compl. 2 (quoting Tom LoBianco & Dave Levinthal, Jared Kushner 

Helped Create a Trump Campaign Shell Company that Secretly Paid the President’s Family 

Members and Spent $617 Million in Reelection Cash, a Source Tells Insider, Bus. Insider (Dec. 

18, 2020), https://www.businessinsider.com/jared-kushner-trump-campaign-shell-companyfamily-ammc-lara-2020-12). 

7

 Ex. 1, Admin. Compl. ¶ 13 (citing state and FCC filings). 

8

 E.g., Ex. 1, Admin. Compl. ¶ 19 (quoting Kenneth P. Vogel, Trump Campaign Doubles 

Spending Rate as the 2020 Race Draws Near, N.Y. Times (Oct. 15, 2018), https://www.nytimes.

com/2018/10/15/us/politics/trump-campaign-spending-midterms-2020.html).

9

 Ex. 1, Admin. Compl. ¶ 21 (quoting Ashley Balcerzak, Trump Campaign Spends Big at Trump 

Properties—and Feathers Friends’ Nests, Ctr. for Pub. Integrity (Apr. 15, 2019), https://public

integrity.org/politics/trump-campaign-spends-big-at-trump-properties-and-feathers-friendsnests).

10 Ex. 1, Admin. Compl. ¶ 23 (quoting Michelle Ye Hee Lee & Anu Narayanswamy, Trump’s 

2016 Campaign Was Run on a Shoestring. His Reelection Machine Is Huge—and Armed with 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 10 of 26
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35. In addition, the complaint and supplement demonstrated that AMMC was devoted 

largely to the Trump Committees’ success: for example, all but one FEC-reported payment to 

AMMC came from the Committees, and the lone exception—a single payment for “list 

acquisition” in September 2019—came from the Republican National Committee (“RNC”), a joint 

fundraising participant in TMAGA.

11 

36. Second, based on publicly available information that known “subvendors” being 

paid through AMMC were effectively working under the Campaign’s direction and control, the 

administrative complaint alleged that the Committees used AMMC as a mere conduit to pay 

subvendors without disclosing them as payees.

12

37. For example, drawing on media reports, press releases, and filings made to agencies 

other than the FEC, the administrative complaint described the Trump Campaign’s use of AMMC 

as a conduit to pay software company Phunware, Inc. (“Phunware”) to develop the Campaign’s 

official app.13

38. Comments from both Phunware and Trump Campaign officials indicated that the 

company effectively worked directly for the Campaign, with AMMC serving merely as a conduit 

for payments. Parscale, for example, stated that the Campaign wanted “to build [its] own app,” 

 

Consultants, Wash. Post (Oct. 8, 2019), https://www.washingtonpost.com/nation/2019/10/08/

trumps-campaign-was-run-shoestring-his-reelection-machine-is-huge-armed-with-consultants); 

see also id. ¶ 73 (summarizing media reports regarding the Campaign’s control of AMMC). 

11 Ex. 2, Suppl. to Admin. Compl. 1-2. At the times relevant to the administrative complaint, 

TMAGA consisted of the Trump Campaign and the RNC; after the 2020 election, Save America, 

a leadership PAC, was added to TMAGA. See Ex. 1, Admin. Compl. ¶ 5; OGC Report at 3 & n.2.

12 See Ex. 1, Admin. Compl. ¶¶ 26-48, 75-80.

13 See Ex. 1, Admin. Compl. ¶¶ 26-34, 76. 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 11 of 26
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one that the Campaign “actually” and “directly owned,”14 and that the Campaign was involved in 

the decision to create the app, in defining the project’s scope, and in adjusting the project’s goals 

in light of the COVID-19 pandemic.15 Phunware’s president and CEO similarly explained that the 

company built the software for “the Trump-Pence team,”16 and a company press release touted 

“American Made Media Consultants (otherwise known as ‘Trump-Pence 2020’ and ‘Keep 

America Great’ Campaign)” as new Phunware clients.17

39. Multiple media outlets reported that Phunware was “hired” by18 or “working for” 

the Trump Campaign.19

40. Yet, although Phunware’s SEC filings revealed that the company received millions 

of dollars in payments from AMMC in 2019 and 2020,20 neither the Trump Campaign nor any 

 

14 Ex. 1, Admin. Compl. ¶ 30 (emphasis omitted) (quoting Dana Bash & Bridget Nolan, Trump’s 

New Campaign App Gamifies Voter Outreach, CNN (Apr. 23, 2020), https://www.cnn.com/2020/

04/23/politics/trump-campaign-app/index.html). 

15 Ex. 1, Admin. Compl. ¶ 31 (citing Peter Doocy, Trump Team Launches New App Allowing 

Supporters to ‘Engage with the Campaign from Their Couch,’ Fox News (Apr. 23, 2020), https://

www.foxnews.com/politics/trump-team-launches-new-app-allowing-supporters-to-engage-withthe-campaign-from-their-couch).

16 Ex. 1, Admin. Compl. ¶ 29 (quoting Josh Rivera, Donald Trump’s 2020 Campaign App Gets 

a Boost with Phunware Partnership, One Day After Twitter Fact-Check, USA Today (May 28, 

2020), https://www.usatoday.com/story/tech/2020/05/27/donald-trump-reelection-app-phunware/

5271268002). 

17 Ex. 1, Admin. Compl. ¶ 28 (emphasis added) (quoting Press Release, Phunware, Phunware 

Announces Third Quarter 2019 Customer Wins (Oct. 4, 2019), https://www.phunware.com/pressreleases/third-quarter-2019-wins).

18 Ex. 1, Admin. Compl. ¶ 28 (quoting Jarrett Renshaw & James Oliphant, With Rallies Halted 

and Tweets Fact-Checked, Trump Campaign Turns to Smartphone App, Reuters (June 2, 2020), 

https://www.reuters.com/article/us-usa-election-trump/with-rallies-halted-and-tweets-factchecked-trump-campaign-turns-to-smartphone-app-idUSKBN2391FT).

19 Ex. 1, Admin. Compl. ¶ 33 (quoting Stephen Gandel & Graham Kates, Phunware, a Data Firm 

for Trump Campaign, Got Millions in Coronavirus Small Business Help, CBS News (Apr. 23, 

2020), https://www.cbsnews.com/news/phunware-data-collection-trump-campaign-coronavirussmall-business-loans). 

20 Ex. 1, Admin. Compl. ¶ 27 (citing Gandel & Kates, supra note 19, and SEC records).

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other political committee reported any disbursements to Phunware during the 2019-2020 election 

cycle.

21

41. The administrative complaint described similar evidence that the Trump 

Committees used AMMC as a conduit to pay ad-placement firms Realtime Media22 and Harris

Sikes Media LLC,

23 and peer-to-peer messaging company Opn Sesame,24 none of which appeared 

in the Committees’ FEC-reported expenditures for the 2019-2020 election cycle at the time of the 

complaint’s filing.

25

42. CLC, by conducting independent research, identified Phunware, Realtime Media, 

Harris Sikes Media LLC, and Opn Sesame as apparent undisclosed Campaign vendors and AMMC 

subvendors. But CLC remains unable to discern all the information that FECA required the 

Committees to disclose in connection with payments to those subvendors, including the amount, 

date, and purpose of each disbursement. 

43. Moreover, the four subvendors discussed in CLC’s administrative complaint do not 

account for the full amount of the payments to AMMC reported by the Committees or for the full 

range of purposes given for those payments. For example, the Committees regularly labeled 

disbursements to AMMC as paying for media or video production, yet none of the four subvendors 

 

21 Ex. 1, Admin. Compl. ¶ 34 (citing Disbursements to Phunware, FEC.gov, https://www.fec.

gov/data/disbursements/?data_type=processed&recipient_name=phunware&two_year_trans

action_period=2020&max_date=12%2F31%2F2020). No committee reported any payments to 

Phunware after the administrative complaint was filed. See Disbursements to Phunware, supra. 

22 See Ex. 1, Admin. Compl. ¶¶ 35-38, 77. 

23 See Ex. 1, Admin. Compl. ¶¶ 46-48, 79. 

24 See Ex. 1, Admin. Compl. ¶¶ 39-45, 78. 

25 Ex. 1, Admin. Compl. ¶¶ 38, 45, 47. After the complaint’s filing, the Trump Campaign reported

a disbursement to Harris Sikes Media LLC on December 22, 2020, for “Recount: Placed Media.” 

See Disbursements to Harris Sikes, FEC.gov, https://www.fec.gov/data/disbursements/?data_

type=processed&recipient_name=harris+sikes(last visited July 7, 2022). This date and description 

would not cover spending made to the firm through AMMC before Election Day. 

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identified in the complaint appear to provide those services.26 Thus, the Committees’ funneling of 

payments through AMMC has hidden the identities of other subvendors paid through AMMC and 

the details of the Committees’ disbursements to those subvendors. 

44. The Trump Committees’ failure to properly report the disbursements made through 

AMMC to undisclosed subvendors therefore violates 52 U.S.C. § 30104(b) and deprives CLC of 

disclosure information to which it is statutorily entitled. 

Parscale Strategy

45. Again drawing on publicly available information, including media reports, 

statements by Trump Campaign officials, and corporate filings, the administrative complaint also

alleged both that the Committees did not have an arm’s-length relationship with Parscale Strategy

and that Parscale Strategy acted merely as a conduit for disbursements to subvendors.

46. First, the complaint alleged that the Committees did not have an arm’s-length 

relationship with Parscale Strategy.27

47. The complaint explained that, according to corporate records, Parscale Strategy’s 

only principal was Brad Parscale, a senior Trump Campaign official and, from February 2018 to 

July 2020, the Campaign manager.

28 In addition, the only firms to report payments to Parscale 

Strategy in 2020 were the Committees and the RNC, itself a participant in the TMAGA joint 

fundraising committee.29

 

26 Ex. 1, Admin. Compl. ¶¶ 11, 80 n.122; see also Disbursements to American Made Media 

Consultants, FEC.gov, https://www.fec.gov/data/disbursements/?committe&data_type=pro

cessed&recipient_name=american+made+media+consultants (last visited July 7, 2022). 

27 See Ex. 1, Admin. Compl. ¶¶ 6, 12, 50-51, 84-85. 

28 Ex. 1, Admin. Compl. ¶¶ 49, 84 (citing Taxable Entity Search Results for “Parscale Strategy,”

Tex. Comptroller of Pub. Accts., https://mycpa.cpa.state.tx.us/coa/coaSearchBtn (last visited July 

7, 2022) (search under “Entity Name” for “Parscale Strategy”)).

29 Ex. 1, Admin. Compl. ¶¶ 50-51, 85 (citing FEC records). 

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48. Second, the complaint alleged that the Trump Campaign used Parscale Strategy as 

a conduit to pay salaries for individuals working under the direction and control of the Campaign.30

49. The complaint compiled numerous media reports indicating, based on statements 

by Parscale and other Trump Campaign officials, that the Campaign used Parscale Strategy as a 

conduit to pay Campaign staff salaries.

31 For instance, the Washington Post reported that “Parscale 

Strategy[] bills for the campaign salaries of Lara Trump and Kimberly Guilfoyle, the wife and 

girlfriend respectively of Trump’s two oldest sons, Eric and Donald Jr.”32 Parscale himself was 

reportedly also paid through the firm.33

50. The Trump Committees did not report any salary payments to Guilfoyle, Parscale, 

or Lara Trump during the 2020 election cycle.34

51. The Trump Campaign’s FEC filings listed the purposes of disbursements to 

Parscale Strategy as “strategy consulting” or other consulting and media services.35 None of the 

purposes given referenced payroll or staff salary.36

 

30 See Ex. 1, Admin. Compl. ¶¶ 49-60, 86-90. 

31 See Ex. 1, Admin. Compl. ¶¶ 52-59 (citing, for example, Vogel, supra note 8; Vicky Ward & 

Jim Acosta, Trump Campaign Manager Brad Parscale Remains on Defense After Scrutiny over 

Financial Ties, CNN (Sept. 9, 2019), https://www.cnn.com/2019/09/09/politics/brad-parscaletrump-campaign-financial-ties/index.html). 

32 E.g., Ex. 1, Admin. Compl. ¶ 59 (quoting Josh Dawsey & Michael Scherer, Trump Replaces 

Campaign Manager as Polls Show Him Trailing Biden in Presidential Race, Wash. Post (July 15, 

2020), https://www.washingtonpost.com/politics/trump-parscale-stepien-campaign-manager/

2020/07/15/91aad9b6-c6fd-11ea-8ffe-372be8d82298_story.html). 

33 E.g., Ex. 1, Admin. Compl. ¶ 53 (citing Julie Bykowicz, Trump Campaign Machine Has TwoYear Head Start, Wall St. J. (Apr. 14, 2019), https://www.wsj.com/articles/trumps-campaignmachine-has-two-year-head-start-11555243200).

34 Ex. 1, Admin. Compl. ¶ 60 (citing FEC records).

35 Ex. 1, Admin. Compl. ¶ 50 (citing FEC records); OGC Report at 22-23. 

36 See Ex. 1, Admin. Compl. ¶ 50 (citing FEC records); OGC Report at 22-23.

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 15 of 26
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52. CLC, by conducting independent research, uncovered the information included in 

its administrative filings about the relationship between the Trump Committees and Parscale 

Strategy. But the available information is incomplete and cannot substitute for the comprehensive 

and verified disclosure reports required under FECA. And CLC remains unable to discern the

identities of all the staff and contractors potentially paid through Parscale Strategy, or the true 

amounts, dates, and purposes of each payment funneled through Parscale Strategy. 

The Trump Committees and AMMC Respond to the Administrative Complaint 

53. AMMC, its parent corporation, and the Committees filed responses to CLC’s 

complaint with the Commission. The responses and attached affidavits did not dispute any factual 

assertions included in the complaint or supplement; for example, the responses “acknowledged 

that AMMC has been run by individuals known and trusted by the Campaign.”37 Instead, the 

respondents principally asserted that some past campaigns had similarly contracted with 

clearinghouse vendors, but did not cite any statutory or regulatory authority allowing, or 

Commission precedent approving, those arrangements. E.g., Committees’ Response at 2-4. The 

responses also argued that the Committees and AMMC had interacted pursuant to a non-exclusive 

contract, but did not explain how the Committees could negotiate an arm’s-length contract with 

the Campaign staffers running AMMC or address the fact that AMMC appears to have worked

essentially exclusively for the Committees. See, e.g., id. at 5-7. And the responses, citing the 

administrative complaint itself, suggested that the Campaign staff paid through Parscale Strategy 

 

37 Suppl. Response of Make America Great Again PAC, et al., MUR 7784 (Mar. 12, 2021), 

https://www.fec.gov/files/legal/murs/7784/7784_27.pdf (“Committees’ Suppl. Response”); see 

also Response of Donald J. Trump for President, Inc., et al. at 5-7, MUR 7784 (Oct. 19, 2020), 

https://www.fec.gov/files/legal/murs/7784/7784_14.pdf (“Committees’ Response”); Response of 

American Made Media Holding Corporation, Inc., and American Made Media Consultants, LLC, 

MUR 7784 (Nov. 16, 2020), https://www.fec.gov/files/legal/murs/7784/7784_15.pdf. 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 16 of 26
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were W-2 employees of Parscale Strategy, but did not dispute that those staffers also worked for 

the Trump Campaign. See id. at 7. 

OGC Recommends Finding Reason to Believe that the Committees Violated FECA38

54. Based on Plaintiff’s administrative complaint and its supplement and the 

respondents’ written responses, OGC recommended that the Commission find reason to believe 

that (1) the Trump Campaign “violated 52 U.S.C. § 30104(b)(5)(A) and 11 C.F.R. § 104.3(b) by 

misreporting the payees of payments made to [AMMC] and Parscale Strategy,” (2) TMAGA

“violated 52 U.S.C. § 30104(b)(5)(A) and 11 C.F.R. § 104.3(b) by misreporting the payees of 

payments made to [AMMC],” and (3) the Trump Campaign “violated 52 U.S.C. § 30104(b)(5)(A) 

and 11 C.F.R. § 104.3(b) by misreporting the purpose of payments made to Parscale Strategy.”

OGC Report at 26. 

55. In its report accompanying this recommendation, OGC first explained that 

Commission precedent indicated that the Committees “improperly failed to itemize[] AMMC’s 

payments to subvendors in connection with their disclosures of more than three quarters of a billion 

dollars ($781,584,527.57) in disbursements to AMMC.” OGC Report at 15; see id. at 11-21. After 

rigorously comparing the Committees’ use of AMMC to the facts of past Commission 

proceedings, OGC determined that the Committees’ lack of an arm’s-length relationship with 

AMMC and use of the firm as a conduit for subvendor payments required the Committees to report 

 

38 On March 29, 2022, after the FEC failed to act on CLC’s administrative complaint for over 

twenty months (and its supplement for over fourteen months), CLC filed suit in this district to 

challenge the Commission’s inaction as unlawful under the Act. See Compl., Campaign Legal Ctr. 

v. FEC, No. 1:22-cv-00838 (D.D.C. Mar. 29, 2022); see also 52 U.S.C. § 30109(a)(8)(A) 

(authorizing suit by administrative complainant to challenge FEC delay). Only after CLC took the 

agency to court did the Commission finally act on the administrative complaint. See Certification 

at 1-3, MUR 7784 (dated May 11, 2022). CLC voluntarily dismissed the delay suit on May 19, 

2022, after receiving notice that the Commission had dismissed its administrative complaint. See

Min. Order, Campaign Legal Ctr. v. FEC, No. 1:22-cv-00838 (D.D.C. May 19, 2022). 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 17 of 26
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the ultimate payees of disbursements made through AMMC. See id. at 16-17, 20-21. In particular, 

OGC emphasized that AMMC received significant portions of the overall disbursements made by 

the Committees, that it was created and run by Trump Campaign staff, that it appeared to have 

been “created to serve the needs of the Trump [Campaign],” that its only clients appeared to be the 

Committees and the RNC, and that several of the supposed subvendors paid through AMMC 

appeared in fact to have been hired or controlled directly by the Trump Campaign and its staff. See 

id. at 15-17. 

56. In reaching its recommendation, OGC considered and rejected the Committees’ 

arguments that they were not required to report their ultimate payees because their use of AMMC 

assertedly followed practices employed by past campaigns and because AMMC was a distinct 

legal entity. See OGC Report at 17-19. Instead, OGC concluded, relevant agency precedents made 

clear that, even if AMMC was technically a distinct legal entity from the Committees, its close ties 

to the Committees and the evidence that the Committees had used it as a conduit would still require 

the Committees to disclose the ultimate recipients of their disbursements through AMMC. See id.

at 17-18. 

57. Next, OGC discussed its recommendation that the Commission find reason to 

believe that the Trump Campaign misreported the payees of disbursements to Parscale Strategy, 

explaining that “the Commission has previously concluded that a committee should disclose salary 

payments to specific, individually identified employees” and that, in any event, a committee must 

report payments to subvendors when the initial recipient of the funds is “merely a conduit for the 

intended recipient.” OGC Report at 19 (citing Factual and Legal Analysis at 4-6, MUR 6818 (Allen 

Weh for Senate) (June 15, 2017); Factual and Legal Analysis at 9-10, MUR 6724 (Bachmann for 

President) (July 13, 2017)). OGC observed that the record indicated that “Parscale Strategy was 

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used [as] a pass-through to conceal” salary payments to Campaign staff, including Guilfoyle and 

Lara Trump, and accordingly, “that salary payments made by Parscale Strategy on behalf of the 

Trump [Campaign] to Trump [Campaign] staff should have been reported as salary payments to 

the ultimate individual payees rather than consulting service payments to Parscale Strategy.” Id.

at 20. 

58. Finally, OGC explained that the record established reason to believe that the Trump 

Campaign failed to accurately disclose the purposes of disbursements to Parscale Strategy. See 

OGC Report at 21-25. OGC reiterated that “[t]he available information support[ed] an inference 

that Guilfoyle’s (and others’) Trump [Campaign] salary was paid by Parscale Strategy, which is 

not apparent” from the purposes given for disbursements from the Campaign to Parscale Strategy 

from 2019 to 2020. Id. at 22-23. OGC concluded that these facts were analogous to those presented 

by a matter recently investigated and settled by the Commission in which “two committees, the 

Democratic National Committee and Hillary for America, made payments to a law firm for the 

reported purpose of ‘legal services’ [when the disbursements] in fact appeared to have been passthrough payments for opposition research conducted by a subvendor.” Id. at 24. In the same way, 

the Trump Campaign “incorrectly” described salary payments to Campaign staff paid through 

Parscale Strategy as “‘strategy consulting[,]’ . . . ‘video production services,’ ‘photography 

services,’ and ‘consulting—management/strategy/communications/political/digital.’” Id. (quoting 

FEC records). OGC therefore recommended finding reason to believe that the Trump Campaign 

misreported the purposes of salary payments made through Parscale Strategy.

The Commission Deadlocks 3-3 on a Reason to Believe Finding and Dismisses the Complaint 

59. On May 10, 2022, by a deadlocked vote of 3-3, the Commission failed to approve 

OGC’s recommendations, falling short of the four affirmative votes required to find reason to 

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believe that the Committees had violated 52 U.S.C. § 30104(b)(5)(A) and 11 C.F.R. § 104.3(b). 

See Certification at 1-2, MUR 7784 (dated May 11, 2022). 

60. Also on May 10, the Commission failed by 3-3 votes to dismiss the allegations as 

an exercise of prosecutorial discretion under Heckler v. Chaney, see Certification at 2, or to find 

reason to believe that the Trump Campaign and its treasurer had “violated 52 U.S.C. 

§ 30104(b)(5)(A) and 11 C.F.R. § 104.3(b) by misreporting the purpose of payments made to 

Parscale Strategy,” id. at 3.

61. Finally, again on May 10, the Commission voted by a 4-2 margin to “[c]lose the 

file,” thereby dismissing the matter. Certification at 3. 

62. By letter dated May 16, 2022, the Commission notified Plaintiff that it had closed 

the file and dismissed Plaintiff’s complaint. Notification to Campaign Legal Center at 1, MUR 

7784 (May 16, 2022), https://www.fec.gov/files/legal/murs/7784/7784_34.pdf. 

63. On June 9, 2022, the three Commissioners who voted against finding reason to 

believe and authorizing an investigation into Plaintiff’s allegations issued a Statement of Reasons 

explaining the basis for their votes. See Statement of Reasons of Chairman Allen J. Dickerson and 

Comm’rs Sean J. Cooksey and James E. “Trey” Trainor, III, MUR 7784 (June 9, 2022), https://

www.fec.gov/files/legal/murs/7784/7784_42.pdf (“Dickerson, Cooksey & Trainor Statement”).

The no-voting Commissioners’ Statement of Reasons demonstrates that their votes rested on

interpretations of FECA and agency precedent that are legally unsustainable, arbitrary and 

capricious, and otherwise contrary to law. 

64. For example, the no-voting Commissioners applied an unjustifiably stringent legal 

standard that flouts the Act and relevant agency precedent, and clearly “unduly compromises the 

Act’s purposes.” Orloski, 795 F.2d at 164. The Commissioners first rejected OGC’s conclusion 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 20 of 26
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that the Committees were required to disclose the ultimate payees of disbursements made through 

AMMC and Parscale Strategy. See Dickerson, Cooksey & Trainor Statement at 4-9. Rather than 

employing the careful analysis dictated by Commission precedent, the Commissioners stated in 

conclusory fashion that reporting of ultimate payees is required only “when the facts indicate that 

the immediate recipient is merely a conduit for the intended recipient of the funds”—which, the 

Commissioners argued, is the case only “when the committee has previously instructed the payee 

to pass payments along to a third party that was not involved in the provision of services by the 

payee.” Id. at 5 (emphasis and citation omitted). They further opined that subvendor reporting is

not required in this context absent a showing that the reported vendor was deliberately used as a 

conduit “only out of a desire to conceal payments” to the ultimate subvendor, “in an attempt to 

disguise the intended recipient of funds.” Id. at 6-7. 

65. The Commissioners also grounded their votes on an “agency acquiescence” 

rationale that lacks any legal or factual basis. They posited that use of a single clearinghouse 

vendor like AMMC—which here enabled the Trump Campaign to conceal the true receipients of 

nearly three-quarters of its 2019-20 reported spending, see OGC Report at 15 n.66 (noting that 

Trump Campaign’s $516,697,606.57 million in reported disbursements to AMMC amounted to 

69% of its $752,889,328.62 in total expenditures)—was “unremarkable” and consistent with the 

“historical practice” of past campaigns, a conclusion they notably rested on respondents’ citations 

to “credible reports” in the news media detailing allegedly similar arrangementsfrom prior election 

cycles, Dickerson, Cooksey & Trainor Statement at 7-8, 12. Although they did not suggest that the 

practice has been the subject of a matter under review by the FEC in the past, they argued that the 

agency had silently “acquiesce[d]” in the practice. Id. at 12-13.

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 21 of 26
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66. The Commissioners further contrived to demand a standard of proof under which 

they could arbitrarily disregard large swaths of the factual record. They offered two principal 

reasons for finding the allegations in the complaint legally insufficient to support a preliminary

reason-to-believe finding. First—despite the fact that the administrative respondents had not 

disputed the accuracy of any of the factual allegations raised by Plaintiff’s administrative 

complaint—the Commissioners opined that published news reports drawing on anonymous 

sources “are not a proper basis for Commission enforcement action.” Dickerson, Cooksey & 

Trainor Statement at 8-9. Second, the Commissioners argued that “the bulk of the [cited] articles’ 

factual allegations . . . would not persuade us to pursue enforcement here, even if they were true,” 

as “ties” or even common staff between a vendor and a committee would not, in the 

Commissioners’ view, suffice to show that the vendor was “merely a conduit” for disbursements 

to subvendors. Id. at 9. This portion of the Statement did not address significant facts alleged in 

the administrative complaint—for example, the evidence that Campaign staff created AMMC to 

benefit the Campaign, that the firm existed solely to benefit the Committees, or that the 

Committees directly worked with and supervised subvendors and staff paid through AMMC and 

Parscale Strategy. 

67. The Commissioners next rejected OGC’s conclusion that the Trump Campaign 

failed to adequately describe the purpose of payments made through Parscale Strategy. Dickerson, 

Cooksey & Trainor Statement at 10-12. The Commissioners first noted that “strategy consulting” 

and other purpose descriptors used by the Trump Campaign to describe its disbursements to 

Parscale Strategy were, in the abstract, sufficiently specific to satisfy the Campaign’s reporting 

obligations, provided that they accurately described the payments’ purposes. See id. at 10-11. 

Critically, the Commissioners then refused to credit the uncontroverted news reports cited in 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 22 of 26
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Plaintiff’s administrative complaint documenting that disbursements to Parscale Strategy were in 

fact used to pay Campaign staff salaries, rather than for the purposes given by the Trump 

Campaign; the Commissioners observed that some of those reports were consistent with those 

Campaign staffers’ being paid for their work for Parscale Strategy, rather than directly for the 

Campaign, and that the remainder drew on anonymous sources, which the Commissioners again 

suggested are a categorically illegitimate basis for a Commission investigation. See id. at 11-12. 

The Commissioners’ reasoning left unexplained several anomalies raised by CLC’s administrative 

filings—for instance, how the Trump Campaign could have compensated Parscale for his service 

as Campaign manager without reporting any salary payments to him. 

68. Following this extended factual and legal analysis of the complaint’s merits, the 

Commissioners purported to explain their votes against finding reason to believe as an exercise of 

prosecutorial discretion. In support of this asserted rationale, the Commissioners first reiterated 

their view of the complaint’s merits, then summarily argued that pursuing the matter would create 

“litigation risk” and consume agency resources. Id. at 12. The Commissioners also suggested that 

“the regulatory environment is uncertain,” again referencing past campaigns’ use of supposedly 

similar vendor arrangements and citing a pending FEC rulemaking petition filed by CLC that seeks 

to expand current subvendor reporting requirements so they apply beyond the vendor relationships

alleged here. See id.39 

 

39 See also CLC, Petition for Rulemaking to Revise and Amend Regulations Relating to 

Subvendor Reporting Transparency 3-4 (June 29, 2021), https://campaignlegal.org/sites/default/

files/2021-06/6-29-21%20CLC-CSTP%20subvendor%20petition.pdf (noting that subvendor 

reporting is required under current law “when the vendor receiving the itemized disbursement does 

not have an ‘arm’s-length’ relationship with the committee; when the payments to the ultimate 

payee were unrelated to the services provided pursuant to the itemized vendor’s contract with the 

committee; and/or when the itemized vendor was merely acting as a ‘conduit’”). 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 23 of 26
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69. Two of the three Commissioners who voted to approve OGC’s recommendation 

that the FEC find reason to believe also issued a Statement of Reasons explaining their votes. See 

Statement of Reasons of Comm’rs Shana M. Broussard and Ellen L. Weintraub, MUR 7784 (June 

15, 2022), https://www.fec.gov/files/legal/murs/7784/7784_43.pdf (“Broussard & Weintraub 

Statement”). The Commissioners found that the “meticulously documented” administrative 

complaint alleged the concealment of “exactly the type of information the FECA is intended to 

expose to the sunlight of disclosure,” id. at 4, and “agreed” with OGC that the complaint provided 

reason to believe that the Committees violated the Act, id. at 3. They rejected the no-voting 

Commissioners’ “attempt to discredit news reports as appropriate sources of information for 

complaints,” observing that the complaint drew on “detailed reporting” from an array of reputable 

news organizations, such as the Wall Street Journal and the New York Times. Id.

70. Commissioners Broussard and Weintraub further noted in their Statement that the 

dismissal of Plaintiffs’ administrative complaint continued former President Trump’s “remarkable 

win streak before th[e] Commission,” during which “the FEC has received more than 40 

complaints involving Donald Trump or his committee” but conducted “a grand total of zero” 

investigations, despite OGC’s recommending a reason to believe finding in “at least 24” of those

matters—and despite the Commission’s recently pursuing enforcement against the Democratic 

National Committee for subvendor reporting violations analogous to those alleged here. Broussard 

& Weintraub Statement at 1, 5. The Commissioners concluded that the complaint’s dismissal 

violated principles of fairness and consistent treatment under the law, and would “damag[e] . . . the 

integrity of America’s campaign-finance process.” Id. at 5. 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 24 of 26
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CAUSE OF ACTION

Count I: FECA, 52 U.S.C. § 30109(a)(8)(A) 

71. Plaintiff repeats and realleges paragraphs 1-70 as if set forth fully herein.

72. CLC’s administrative complaint in MUR 7784 established reason to believe that 

(1) the Trump Campaign violated 52 U.S.C. § 30104(b)(5)(A) and 11 C.F.R. § 104.3(b) by failing 

to disclose the ultimate payees of disbursements made through AMMC and Parscale Strategy, 

(2) TMAGA violated 52 U.S.C. § 30104(b)(5)(A) and 11 C.F.R. § 104.3(b) by failing to disclose 

the ultimate payees of disbursements made through AMMC, and (3) the Trump Campaign violated 

52 U.S.C. § 30104(b)(5)(A) and 11 C.F.R. § 104.3(b) by failing to adequately and accurately 

describe the purposes of disbursements made to Parscale Strategy.

73. The Commission’s failure to find reason to believe that these violations occurred 

and its subsequent dismissal of Plaintiff’s administrative complaint were arbitrary, capricious, and 

contrary to law. See 52 U.S.C. § 30109(a)(8)(A); Orloski, 795 F.2d at 161. 

REQUESTED RELIEF

WHEREFORE, Plaintiff requests that this Court:

(1) Declare that the FEC’s dismissal of Plaintiff’s administrative complaint was 

arbitrary, capricious, and contrary to law under 52 U.S.C. § 30109(a)(8)(A);

(2) Order the FEC to conform with this declaration within thirty days pursuant to 52 

U.S.C. § 30109(a)(8)(C);

(3) Award Plaintiff its costs and reasonable attorney’s fees incurred in this action; and

(4) Grant such other relief as the Court may deem just and proper. 

Case 1:22-cv-01976 Document 1 Filed 07/08/22 Page 25 of 26
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Dated: July 8, 2022 Respectfully submitted, 

/s/ Megan P. McAllen 

Megan P. McAllen (DC Bar No. 1020509) 

Richard Samuel Horan* (pro hac vice

motion forthcoming) 

CAMPAIGN LEGAL CENTER

1101 14TH ST. NW, SUITE 400 

WASHINGTON, D.C. 20005 

(202) 736-2200 

* Licensed to practice in Massachusetts 

only; District of Columbia Bar application 

pending. Supervised by Megan McAllen, a 

member of the D.C. Bar.

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