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 UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

 

 ) 

CAMPAIGN LEGAL CENTER, ) 

 ) 

 Plaintiff, ) Civ. No. 20-2842 (CJN) 

 ) 

 v. ) 

 ) ANSWER 

FEDERAL ELECTION COMMISSION, ) 

 ) 

 Defendant. ) 

 ) 

DEFENDANT FEDERAL ELECTION COMMISSION’S ANSWER 

Defendant Federal Election Commission (“FEC” or “Commission”) submits this answer 

to the Complaint for Declaratory and Injunctive Relief of plaintiff Campaign Legal Center. Any 

allegation not specifically responded to below is DENIED. 

1. This paragraph characterizes the claims in plaintiff’s complaint, and so no 

response is required. To the extent a response is required, ADMIT that plaintiff’s complaint 

purports to assert a claim under 52 U.S.C. § 30109(a)(8)(A). 

2. This paragraph contains conclusions of law, to which no response is required. To 

the extent the paragraph relies on unspecified “publicly available information,” the Commission 

is without knowledge or information sufficient to admit or deny this paragraph. 

3. This paragraph contains conclusions of law, to which no response is required. To 

the extent the paragraph relies on unspecified “publicly available information,” the Commission 

is without knowledge or information sufficient to admit or deny this paragraph. 

4. This paragraph contains conclusions of law, to which no response is required. To 

the extent the paragraph relies on unspecified “publicly available information,” the Commission 

is without knowledge or information sufficient to admit or deny this paragraph. 

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extent this paragraph alleges that the FEC has not made required information publicly available, 

the second sentence of this paragraph is DENIED. 

13. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

14. The Commission is without knowledge or information sufficient to admit or deny 

this paragraph. 

15. ADMIT. 

16. This paragraph quotes FECA, which speaks for itself, and so no response is 

required. To the extent a response is required, ADMIT that FECA contains the quoted text. 

17. This paragraph characterizes FEC regulations, which speak for themselves, and so 

no response is required. To the extent a response is required, ADMIT that this paragraph 

accurately quotes the cited FEC regulation. 

18. This paragraph and its accompanying footnote characterize the purpose of a 

federal statute and judicial opinion, which speak for themselves, and so no response is required. 

19. This paragraph contains plaintiff’s characterization of a Statement of Reasons 

issued by former Commissioners Matthew S. Petersen, Caroline C. Hunter, and Lee E. 

Goodman, which speaks for itself and so no response is required. To the extent a response is 

required, ADMIT that those Commissioners issued a Statement of Reasons on April 1, 2016 in 

MURs 6485, 6487, 6488, 6711, and 6930 and that the quoted language in this paragraph from 

that Statement of Reasons is accurate. 

20. This paragraph quotes FECA, which speaks for itself, and so no response is 

required. To the extent a response is required, ADMIT that FECA contains the quoted text, but 

DENY that this paragraph sets forth all the requirements for a political committee to exist. 

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21. This paragraph purports to describe the legal requirements for determining 

whether a group is a political committee based on Supreme Court judicial opinions, which are 

legal conclusions, and so no response is required. To the extent a response is required ADMIT 

that the Supreme Court adopted a “major purpose” requirement for certain organizations but 

DENY that this paragraph sets forth a complete description of that analysis. 

22. This paragraph quotes the Political Committee Status Supplemental Explanation 

and Justification, 72 Fed. Reg. 5595 (Feb. 7, 2007), which speaks for itself, and so no response is 

required. To the extent a response is required, ADMIT that the quoted language appears in the 

cited Explanation and Justification, but DENY that this paragraph sets forth the complete 

analysis. 

23. This paragraph contains plaintiff’s characterizations of applicable law, to which 

no response is required. 

24. This paragraph contains plaintiff’s descriptions of certain provisions of FECA, 

which speak for themselves, and so no response is required. To the extent a response is required, 

ADMIT that FECA and FEC regulations require groups meeting the definition of “political 

committee” to file a statement of organization, file periodic reports with the FEC, and meet other 

organizational requirements. 

25. This paragraph contains plaintiff’s characterizations of judicial opinions, which 

speak for themselves, and so no response is required. To the extent a response is required, 

ADMIT that the case quotations in this paragraph are accurate. 

27. ADMIT that 1820 PAC has registered with the FEC as an independent 

expenditure-only political committee, and that 1820 PAC reported receiving the contribution 

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from SYWSE as described in this paragraph. The FEC is without sufficient information to admit 

or deny the remaining allegations in this paragraph. 

28. The first sentence of this paragraph contains plaintiff’s characterization of the 

availability of information about SYWSE, and so no response is required. 

 To the extent a 

response is required, DENY. 

29. This paragraph contains plaintiff’s legal argument, and so no response is 

required. 

30. This paragraph contains plaintiff’s legal argument, and so no response is 

required. 

31. This paragraph contains plaintiff’s legal conclusions, to which no response is 

required. 

32. This paragraph contains plaintiff’s legal conclusions, to which no response is 

required. 

33. This paragraph contains plaintiff’s legal conclusions, to which no response is 

required. 

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37. This paragraph re-alleges and incorporates by reference the allegations contained 

in paragraphs 1-36 of plaintiff’s complaint, and the Commission therefore incorporates by 

reference its responses to those paragraphs. 

38. DENY. 

Plaintiff is not entitled to the relief requested in the “Requested Relief” portion of the complaint 

or to any other relief. 

Respectfully submitted, 

Lisa J. Stevenson (D.C. Bar No. 457628) 

Acting General Counsel 

lstevenson@fec.gov 

Kevin Deeley 

Associate General Counsel 

kdeeley@fec.gov 

Jacob S. Siler (D.C. Bar No. 1003383) 

Acting Assistant General Counsel 

jsiler@fec.gov 

/s/ Seth Nesin 

Seth Nesin 

Attorney 

snesin@fec.gov 

COUNSEL FOR DEFENDANT 

FEDERAL ELECTION COMMISSION 

1050 First Street, NE 

Washington, DC 20463 

(202) 694-1650

February 16, 2021 

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