Memorandum to Commission

Request for Consideration of a Legal Question

Stop These Oppressive People: Tyrants Racists Unqualifieds Misogynists Propogandists (“STOP TRUMP”)

Page 2 of 10

We have considered the Committee’s arguments and the relevant law, and we 

recommend that the Commission conclude that the Committee’s name in its Statement of 

Organization includes the name of a federal candidate as proscribed by 52 U.S.C. § 30102(e)(4). 

II. UNAUTHORIZED COMMITTEES MAY NOT INCLUDE THE NAME OF A 

FEDERAL CANDIDATE IN THEIR NAMES ON THEIR STATEMENTS OF 

ORGANIZATION

Section 30102(e)(4) of the Federal Election Campaign Act, 52 US.C. §§ 30101-45 (the 

“Act”), states that “[i]n the case of any political committee which is not an authorized 

committee, such political committee shall not include the name of any candidate in its name.” 

The Committee is not an authorized committee of any candidate. It does not name on its Form 1 

a candidate who authorizes the Committee3 and it does not dispute that it is an unauthorized 

committee.

The Committee also does not dispute that “Trump” is the name of a federal candidate or 

that Donald Trump is the only active federal candidate with the name “Trump.”4 Instead, the 

Committee argues that its name “forms the name of a federal candidate” and that “simply 

indicat[ing]” Trump, which the Request characterizes as an acronym, on Line 1 does not 

constitute a “name” of a candidate for purposes of section 30102(e)(4).5 The plain language of 

the Act, its legislative history, court decisions, and the Commission’s application of section 

30102(e)(4) in enforcement actions, advisory opinions, and the RAD Review and Referral 

Procedures consistently demonstrate that the Committee may not use “Trump” in its name on its 

Statement of Organization because the Committee is not an authorized committee of federal 

candidate Donald Trump. 

A. The Act, its Legislative History, and Court Cases

Prior to 1980, although the Act contained various provisions differentiating political 

committees that are authorized by a federal candidate from those that are unauthorized,6 the Act 

did not include a formal name identification requirement. In legislative recommendations, the 

Commission explained to Congress that the name of most principal campaign committees 

identified the candidate supported by the committee, but that, “in some cases, it [was] difficult to 

3

 Committee, Statement of Organization at 2. The Committee does name three other unauthorized 

committees with which it is affiliated. See id. at 3, 5-6 (naming Progressive Turnout Project, Progressive Takeover, 

and Stop Republicans as affiliated committees). 

4

 See Candidates, Campaign finance data, https://www.fec.gov/data/candidates/?q=trump&election year=

2023&election year=2024&election year=2026&election year=2028 (search of candidate database for “Trump”

showing only Donald J. Trump as a 2023, 2024, 2026, or 2028 candidate) (last visited Nov. 27, 2023).

5

 Attachment at 1, 3. 

6

 Compare 52 U.S.C. § 30102(e)(1) (requiring candidates to “designate in writing a political committee . . . 

to serve as the principal campaign committee of such candidate” and authorizing them to designate other 

“authorized” committees), with id. § 30203(a) (establishing separate requirements for “other committees”).
Memorandum to Commission

Request for Consideration of a Legal Question

Stop These Oppressive People: Tyrants Racists Unqualifieds Misogynists Propogandists (“STOP TRUMP”)

Page 3 of 10

determine which candidate a principal campaign committee support[ed]” because the 

committees’ names did “not contain the candidate’s name as, for example, ‘Good Government 

Committee’ or ‘Spirit of ’76.’”7 The Commission concluded that “[i]n order to avoid confusion 

the Act should require the name of the principal campaign committee to include in its name the 

name of the candidate which designated the committee.”8

Based on this recommendation, in the Federal Election Campaign Act Amendments of 

1979,9 Congress provided that the name of each authorized committee “shall include the name of 

the candidate who authorized such committee,” while any committee not so authorized “shall not 

include the name of any candidate in its name.”10 The U.S. Court of Appeals for the District of 

Columbia Circuit explained in Common Cause v. FEC that Congress’s restriction on 

unauthorized committees “was understandably advanced as a further step in the clarification 

process designed to allow anyone reading the name of a political committee to determine 

immediately whether or not it is an authorized committee by the presence or absence of a 

candidate’s name.”11 The Act’s name identification requirements, including the prohibition on 

an unauthorized committee’s inclusion of a federal candidate’s name in its name, remain 

unchanged by Congress and are now codified at 52 U.S.C. § 30102(e)(4).

B. Regulatory History

In 1980, the Commission adopted an implementing regulation for the authorized and 

unauthorized committee name provision at 11 C.F.R. § 102.14(a) that “follows [52 U.S.C. 

§ 30102(e)(4)].”12 Following the decision in Common Cause, the Commission amended section 

102.14(a) to extend the prohibition beyond political committee’s names on their Statements of 

Organizations to include any names under which a committee conducts activities, such as a 

special project.

13 The Commission further amended section 102.14 in 1994 to add paragraph 

7 Federal Election Campaign Act Amendments of 1979, Hearing Before the Senate Committee on Rules and 

Administration, 96th Cong., 1st Sess., 23 (1979) (FEC’s Legislative Recommendations) (Appendix to Statement of 

Robert Tiernan, Charman of the FEC).

8 Id.

9 Federal Election Campaign Act Amendments of 1979, Pub. L. No. 96-187, § 102, 93 Stat. 1339, 1346 

(1980).

10 Id. (now codified at 52 U.S.C. § 30102(e)(4).

11 Common Cause v. FEC, 842 F.2d 436, 450 (D.C. Cir. 1988) (summarizing legislative history and 

concluding that Commission could reasonably interpret section 30102(e)(4)’s restriction on unauthorized 

committees’ names to apply only to the names of committees itself and not to names of any fundraising projects 

sponsored by committee).

12 Amendments to Federal Election Campaign Act of 1971; Regulations Transmitted to Congress, 45 Fed. 

Reg. 15,080, 15,085 (Mar. 7, 1980) (also allowing unauthorized committee names to include candidate names as 

allowed under paragraph (b) of section 102.14, which addressed delegate and draft committees).

13 See Special Fundraising Projects and Other Use of Candidate Names by Unauthorized Committees, 57 Fed. 

Reg. 31,424 (July 15, 1992) (amending paragraph (a) to state that “name” includes names, such as special project 
Memorandum to Commission

Request for Consideration of a Legal Question

Stop These Oppressive People: Tyrants Racists Unqualifieds Misogynists Propogandists (“STOP TRUMP”)

Page 4 of 10

(b)(3), which allowed unauthorized committees to include a candidate name in the title of a 

special project name or communication if the title showed opposition to the named candidate.14

In 2019, the U.S. District Court for the District of Columbia found the opposition 

exception applicable to titles of a special project name or other communication at paragraph 

(b)(3) to be impermissibly content-based and, on this basis, declared that section 102.14(a) was 

unconstitutional and permanently enjoined the Commission from enforcing it.

15 The court in 

Pursuing America’s Greatness did not address the validity of 52 U.S.C. § 30102(e)(4), however, 

and did not enjoin the Commission from enforcing the statutory requirements for political 

committees’ names on their Statements of Organization. Since the Pursuing America’s 

Greatness decision, the Commission has applied only the statute, and not the enjoined regulatory 

provision, in conducting its analyses of committee uses of candidate names.16 

C. Court Treatment of Section 30102(e)(4)

In Common Cause, the U.S. Court of Appeals for the D.C. Circuit upheld the 

Commission’s interpretation of section 30102(e)(4) “as applying only to the official name of a 

political committee.”17 In Stop Hillary PAC v. FEC, the U.S. District Court of the Eastern 

District of Virginia held that the plaintiffs — an unauthorized committee seeking to use the name 

“Stop Hillary PAC” as its registered name and a voter — did not show a likelihood of success on 

the merits of their claim that the naming restrictions for unauthorized political committees are an 

impermissible content-based restriction on speech or violate their First Amendment rights.18 The 

Stop Hillary PAC decision found that section 30102(e)(4) serves only as a “narrow and specific” 

prohibition on committees’ registered names to “limit[] public confusion about which person, 

group, or candidate the PAC represents.”19 The court, citing the legislative history discussed 

names, under which committees conduct activities); and see Common Cause, 842 F.2d 436.

14 Special Fundraising Projects and Other Use of Candidate Names by Unauthorized Committees, 59 Fed. 

Reg. 17,267 (Apr. 12, 1994) (adding paragraph (b)(3)).

15 Pursuing America’s Greatness v. FEC, 363 F. Supp. 3d 94 (D.D.C. 2019).

16 See Advisory Opinion 2019-16 (Shemanski) (analyzing, after Pursuing America’s Greatness, statutory 

language and concluding that the initials “DT” do not constitute the “name” of a candidate under 52 U.S.C. 

§ 30101(e)(4)).

17 Common Cause, 842 F.2d at 448 (noting that “adherence” to section 30102(e)(4) includes applying 

provision to any name under which the Committee has registered); and see id. at n.5 (describing name on Statement 

of Organization as the “officially registered name” of the committee).

18 166 F. Supp. 3d 643 (E.D. Va. 2015). In Stop Hillary PAC, the unauthorized committee, like the 

Committee at issue in this Request, had received an RFAI directing it to amend its Statement of Organization to 

remove the name of a federal candidate. See Complaint ¶ 15, Stop Hillary PAC, v. FEC, 1:15-cv-01208 (E.D. Va. 

Sept. 22, 2015), ECF No.1 (discussing procedural history of case).

19 Stop Hillary PAC, 166 F. Supp. 3d at 649-50 (also finding that section 30102(e)(4) cannot be considered to 

target speech based on its communicative content, because it leaves unauthorized political committees “entirely free 

to discuss candidates” through their websites, solicitations, special projects, and various other communications).
Memorandum to Commission

Request for Consideration of a Legal Question

Stop These Oppressive People: Tyrants Racists Unqualifieds Misogynists Propogandists (“STOP TRUMP”)

Page 5 of 10

above, noted that section 30102(e)(4), which had been “well-established law...for the last 35 

years,” serves “to alleviate constant public confusion” surrounding misleading committee names 

and concluded that, even where a political committee’s name unambiguously opposes a 

candidate, “the possibility of public confusion still exists.”20 As the court further explained, the 

plaintiffs failed to “address the possibility that members of the public would see the PAC 

unambiguously opposing one candidate — for example “Stop Hillary” — and mistakenly get the 

impression that the PAC was in fact an authorized PAC supporting one of Hillary Clinton’s 

opponents.”21

D. Commission’s Application of Section 30102(e)(4) to Committee Names on 

Statements of Organization

1. In Commission MURs and AOs

The Commission has consistently applied section 30102(e)(4) in enforcement matters and 

advisory opinions to prohibit unauthorized committees’ inclusion of candidate names in their 

names, including in MUR 7086 (Stop Hillary PAC), which followed the court case discussed 

above.22 In one such matter, the Commission squarely addressed and rejected the argument 

raised in the Request that characterization of a candidate’s name as an acronym removes the 

name from the ambit of the statutory provision. In MUR 6213 (Decidedly Unhappy Mainstream 

Patriots Rejecting Evil-mongering Incompetent Democrats Political Action Committee 

(DUMPREID PAC), the Commission stated that, “[t]he Committee’s assertion that ‘Dump Reid’

is an ‘acronym or abbreviation’ ... do[es] not change the fact that Senator Reid’s name is listed 

as part of the official name of the Committee.”23 The Commission concluded that the committee 

may have violated section 30102(e)(4) “by including Senator Reid’s last name as part of its 

official name on its Form 1,” though dismissed the complaint in its prosecutorial discretion and 

cautioned the committee to comply with the Act and Commission regulations by removing the 

parenthetical “(DUMPREID PAC)” from its Statement of Organization.24 Similarly, in 

Advisory Opinion 1995-09 (NewtWatch PAC), the Commission concluded that “NewtWatch” 

could not be used as part of an unauthorized committee’s name, because it included the name of 

Speaker of the House Newt Gingrich, a federal candidate.25

20 Id. at 646-47, 649 (internal alterations omitted). 

21 Id. at 649 (internal alterations omitted).

22 See Conciliation Agreement ¶¶ V-VI, MUR 7086 (Stop Hillary PAC) (conciliating violation of 52 U.S.C. 

§ 30102(e)(4) with payment of $5,500 penalty and agreement to cease and desist from further violations, with 

acknowledgment that “Hillary” could remain in committee name if the reference to “Hillary” was exclusively to 

Hillary Clinton and Hillary Clinton was no longer a candidate). 

23 Factual and Legal Analysis, MUR 6213 (DUMPREID PAC) at 4. 

24 Id. at 5; Notification Letter attaching Factual and Legal Analysis at 1-2, MUR 6213 (DUMPREID PAC); 

and see Certification ¶ 1, MUR 6213 (DUMPREID PAC) (Apr. 27, 2010). 

25 Advisory Opinion 1995-09 (NewtWatch PAC) at 5-6.
Memorandum to Commission

Request for Consideration of a Legal Question

Stop These Oppressive People: Tyrants Racists Unqualifieds Misogynists Propogandists (“STOP TRUMP”)

Page 6 of 10

2. Under the RAD Review and Referral Procedures

The Commission-approved RAD Review and Referral Procedures are grounded in, and 

set forth a ministerial application of, the law set out above. The relevant part of Standard 2: 

Statement of Organization (FORM 1) of the 2023-2024 RAD Review and Referral Procedures 

states that “an RFAI will be sent” to an unauthorized committee if “the committee’s name 

includes a Federal candidate’s name, or a portion thereof that clearly identifies the candidate 

(with the exception of joint fundraising committees that have an authorized committee as a 

recipient).”26 The “portion thereof” language was added to the standard in the 2015-2016 RAD 

Review and Referral Procedures. Following the Pursuing America’s Greatness decision in 2019,

RAD modified its RFAI’s under Standard 2 to delete reference to 11 C.F.R. § 102.14(a) and cite 

only 52 U.S.C. § 30102(e)(4) as the authority for the RFAI.27 

Applying this standard, RAD sends RFAIs to all unauthorized committees that include 

the full name, first name, or last name of a federal candidate if that name clearly identifies a 

federal candidate. If there is more than one candidate seeking election with that full, first, or last 

name, RAD will not send an RFAI.

28 Since 2019, following the Pursuing America’s Greatness

decision, RAD has sent 13 RFAIs (in addition to the one sent to the Committee) to unauthorized 

committees that included at least a portion of a candidate’s name in the committees’ names on 

their Statements of Organization in all capital letters similar to the Committee’s name, in what 

the Request has characterized as an acronym.29

26 Standard 2, 2023-2024 RAD Review and Referral Procedures (Redacted) at 39, https://www.fec.gov/

resources/cms-content/documents/Final-Redacted-2023-2024-RAD-Review-Referral-Procedures.pdf. 

27 The Commission took the same approach in 2021 when it approved the Campaign Guide for Congressional 

Candidates and Committees, which removed the reference to 11 C.F.R. § 102.14(a) and replaced it with a reference 

to 52 U.S.C. § 30102(e)(4). See Campaign Guide for Congressional Candidates and Committees, Federal Election 

Commission, Oct. 2021, at 9 n.7, https://www.fec.gov/resources/cms-content/documents/policy-guidance/

candgui.pdf. 

28 Accord Advisory Opinion 2019-16 (Shemanski) at 2 (concluding that an unauthorized committee could use 

the initials “DT” in its registered name because those initials are “not commonly used to refer to President Trump,” 

and “there [were] at least two other federal officeholders with the initials ‘DT’ who [were] also candidates for reelection in 2020, Representative David Throne of Maryland and Representative Dina Titus of Nevada”).

29 See RFAI, ASA PAC, INC. (May 30, 2023); RFAI, MARLIN PAC (Apr. 27, 2023); RFAI, DANA PAC 

(Feb. 13, 2023); RFAI, MADISON PAC (Dec. 20, 2022); RFAI, REPUBLICANS UNITED TO DEFEND YOU 

PAC (RUDY PAC) (Sept. 13, 2022); RFAI, DOSE OF REALITY, OPTIMISM AND ZEAL PA PAC (DR OZ PA 

PAC) (Aug. 17, 2022); RFAI, Fung Yeah (Aug. 4, 2022); RFAI, KILEY ELECTION VICTORY PAC (KEVPAC) 

(June 22, 2022); RFAI, KYLE PAC Knowledgeable unYielding Leadership Experienced (June 14, 2022); RFAI, 

Making A Difference In Service to Our Nation (MADISON PAC) (Sept. 15, 2020); RFAI, Forever Youth 

Organization Utilizing a New Generation PAC (Forever Y.O.U.N.G. PAC) (Sept. 14, 2020); RFAI, Traitorous 

Racist Unqualified Megalomaniac Puppet (TRUMP) Super PAC (June 30, 2020); RFAI, Freedom Rings Every Day 

PAC (aka FRED PAC) (July 10, 2019). 
Memorandum to Commission

Request for Consideration of a Legal Question

Stop These Oppressive People: Tyrants Racists Unqualifieds Misogynists Propogandists (“STOP TRUMP”)

Page 7 of 10

III. THE COMMITTEE MAY NOT INCLUDE “TRUMP” IN ITS NAME ON ITS

STATEMENT OF ORGANIZTION

A. RAD’s Consistent Application of Standard 2 

The Request contends that RAD inconsistently sends RFAIs for including candidate 

names in committee names, pointing to several unauthorized committees that did not receive 

RFAIs although their “names constitute acronyms that spell out the name of a federal candidate 

or include the actual candidate’s name.”30 Each of the committee names identified in the 

Request are distinguishable from the Committee’s inclusion of “Trump” in its name. 

As discussed above, “Trump” is a name that clearly refers to only one person registered 

as a candidate, former President Donald Trump; there are currently no other candidates in any 

election with the name of “Trump” for the current or any upcoming election cycle.31 The 

Request contends that its use of “Trump” is similar to the use of “Ron” in the name of “Ron 

Response PAC,” which did not receive an RFAI.32 But unlike “Trump,” who is the only 

registered candidate for an upcoming election with that name, there are presently four federal 

candidates with the name “Ron” (De Santis, Vitiello, Estes, and Johnson), and four additional 

candidates with the name “Ronald,” “Ronda,” or “Ronny” (Tupa, Kennedy, Jackson, and 

Wyden).33 Accordingly, RAD, consistent with its practice as stated in the 2023-2024 RAD 

Review and Referral Procedures, found the inclusion of “Ron” in Ron Response PAC to be 

ambiguous and did not send an RFAI. 

The Request also identifies four unauthorized committees, all leadership PACs, that did 

not receive RFAIs although their names include the name of a federal candidate, and questions 

whether leadership PACs are treated more leniently than it has been.34 They are not.35 Two of 

these committees’ names spell an acronym of a federal candidate’s name formed from the initial 

letter of each word in the committee name.36 But these committees do not include the 

30 Attachment at 3. 

31 See supra, note 4 and related text. 

32 Attachment at 3 (arguing that “Ron” is not ambiguous because it includes the first name of a candidate “the 

committee is organized to oppose”). 

33 See Candidates, Campaign finance data, https://www.fec.gov/data/candidates/?q=ron&election year=

2023&election year=2024&election year=2025&election year=2026&election year=2027&election year=2028&i

s active candidate=true&has raised funds=true (search of candidate database for “Ron” in 2023-2028) (last visited 

Nov. 15, 2023).

34 See Attachment at 2, 3-4; see also 52 U.S.C. § 30104(i)(8) (providing that a leadership PAC “is not an 

authorized committee of [a] candidate”).

35 RAD sends RFAIs to leadership PACs that meet the criteria in Standard 2 of the 2023-2024 RAD Review 

and Referral Procedures. See, e.g., supra, note 29 and related text (identifying application of Standard 2 RFAI 

practice for past four years consistent, including to several leadership PACs).

36 See Statement of Organization, Building Leadership & Inspiring New Enterprise PAC (July 18, 2018) (not 
Memorandum to Commission

Request for Consideration of a Legal Question

Stop These Oppressive People: Tyrants Racists Unqualifieds Misogynists Propogandists (“STOP TRUMP”)

Page 8 of 10

candidate’s name (in the form of an acronym or any other form) on Line 1 of Form 1 and, 

therefore, did not meet the criteria for sending an RFAI. The Committee’s name, which includes 

the candidate’s name “Trump” in its name on Line 1 of its Statement of Organization, is 

materially distinguishable. The Request further identifies two unauthorized committees that 

include acronyms that spell out the name of a federal candidate on Line 1 of their Form 1s and 

did not receive an RFAI.

37 Both of these committees were organized and registered with 

committee names that included portions of candidate names prior to the inclusion of the “portion 

thereof” language in the 2015-2016 RAD Review and Referral Procedures: CAROLYN’S PAC

in 1998 and COLE PAC in 2004. While RAD did review existing committees for adherence to 

the revised standard when it was adopted, these two committees were apparently overlooked and 

were not sent RFAIs retroactively. Since they have been brought to RAD’s attention, they will 

now be reviewed for adherence to the same RAD Review and Referral Procedures applied to the 

Committee’s Statement of Organization and other committees over the years since the “portion 

thereof” language was adopted.38 The Commission should conclude that the RFAI sent to the 

Committee is well-within RAD’s current practices and procedures.

B. Legal Correctness of RAD’s Application of Standard 2

The only legal authority the Request cites in support of its position that the RFAI was 

improper is MUR 6213 (DUMPREID PAC). As discussed above, the Commission explicitly 

found in MUR 6213 that an unauthorized committee may have violated section 30102(e)(4) by 

including the name of federal candidate Reid in the committee’s name and cautioned the 

committee to change its name. The Commission also unequivocally stated that “‘an acronym or 

abbreviation’ do[es] not change the fact that [a candidate’s] name is listed as part of the official 

name of the Committee.”39 With respect to the use of an acronym, the Committee’s inclusion of 

“Trump” in its name is materially indistinguishable from the use of “Reid” in Decidedly 

Unhappy Mainstream Patriots Rejecting Evil-mongering Incompetent Democrats Political 

Action Committee (DUMPREID PAC) in MUR 6213. Both committees include in their names, 

in all capital letters, a name that clearly identifies a candidate; both committees characterize the 

candidate’s name as an acronym. The Request does not offer any authority or cite any changes 

in the law that warrant revisiting the approach the Commission took in MUR 6213, i.e., to treat 

what is characterized by the committee as an acronym as a name and to assess its use in the 

committee’s name on its Statement of Organization under 52 U.S.C. § 30102(e)(4).

including “Blaine” acronym formed by committee name on Line 1 of Statement of Organization); Amended 

Statement of Organization, Support Taxfighters & Elect Effective Leaders PAC (Jan. 14, 2023) (not including 

“Steele” acronym formed by committee name on Line 1 of Statement of Organization). 

37 See Statement of Organization, Conservative Opportunity Leadership and Enterprise PAC (COLE PAC) 

(Aug. 4, 2004); Amended Statement of Organization, CAROLYN’S PAC (Mar. 31, 2010). 

38 See supra, note 29 and related text (identifying application of Standard 2 RFAI practice for past four years 

consistent with the RFAI sent to the Committee). 

39 Factual and Legal Analysis, MUR 6213 (DUMPREID PAC) at 4.
Memorandum to Commission

Request for Consideration of a Legal Question

Stop These Oppressive People: Tyrants Racists Unqualifieds Misogynists Propogandists (“STOP TRUMP”)

Page 9 of 10

Moreover, MUR 6213 was followed by both the court decision in Stop Hillary PAC and 

the subsequent MUR conciliation with Stop Hillary PAC in MUR 7086, in which the 

Commission found the inclusion of “Hillary” in the name of “Stop Hillary PAC” violated 52 

U.S.C. § 30102(e)(4). The Request, citing no legal authority, argues that there is no risk of 

public confusion with the Committee’s use of “Trump” in its name because acronyms40 in long 

names of political committees are “so common that news articles often write about them” and the 

Committee’s name “unequivocally shows opposition to Donald Trump.”41 But as discussed 

above, in concluding that an unauthorized committee could not use the name “Stop Hillary 

PAC,” the U.S. District Court of the Eastern District of Virginia explained that “the possibility of 

public confusion still exists” and that members of the public could see a political committee 

unambiguously opposing one candidate and “mistakenly get the impression that the PAC was in 

fact an authorized PAC supporting one of [the candidate’s] opponents.”42 The Commission’s 

subsequent finding and conciliation of a violation by Stop Hillary PAC demonstrates that the 

bright line of 52 U.S.C. § 30102(e)(4) is clear for even committees opposing the clearly 

identified candidate in the committee’s name.

Finally, the Request argues that the “ordinary textbook definition of ‘acronym’ does not 

support the notion that an acronym is a ‘name.’”43 The Committee cites two dictionary 

definitions of “acronym,” including Merriam-Webster Dictionary, which defines “acronym” as a

“word (such as NATO, radar, or laser) formed from the initial letter or letters of each of the 

successive parts or major parts of a compound term.”44 But this argument is unpersuasive 

because the Request does not provide any authority in support of its contention that an acronym 

cannot also be a name, which is the relevant term in section 30102(e)(4). 

The dictionaries cited in the Request define “name” as a “word that a person, thing, or 

place is known by”45 or “a word or phrase that constitutes the distinctive designation of a person 

or thing.”46 The definitions of “acronym” and “name,” when looked at in conjunction, indicate

that a word (such as “NATO”) can be both an acronym and a name by which a person is 

known.47 Thus, despite the Request’s attempt to redefine or recharacterize the name “Trump” as

40 The Request does not address that an acronym can also be a name, which is discussed below.

41 Attachment at 4. 

42 Stop Hillary PAC, 166 F. Supp. 3d at 648-49 (internal alterations omitted)

43 Attachment at 3. 

44 Acronym, Merriam-Webster Dictionary, https://www merriam-webster.com/dictionary/acronym (last 

visited Nov. 27, 2023); see also Attachment at 3 (quoting Cambridge Dictionary definition of “acronym” as “an 

abbreviation consisting of the first letters of each word in the name of something, pronounced as a word).

45 Name, Cambridge Dictionary, https://dictionary.cambridge.org/us/dictionary/english/name (last visited 

Nov. 27, 2023).

46 Name, Merriam-Webster Dictionary, https://www merriam-webster.com/dictionary/name (last visited Nov. 

27, 2023).

47 See About us, North Atlantic Treaty Organization, https://www.nato.int/cps/en/natohq/organisation htm
Memorandum to Commission

Request for Consideration of a Legal Question

Stop These Oppressive People: Tyrants Racists Unqualifieds Misogynists Propogandists (“STOP TRUMP”)

Page 10 of 10

an acronym, the Request has not shown that “Trump” is not also a name. And, more 

importantly, the Request has not shown that the name “Trump” in the Committee’s name does 

not clearly identify only one person registered as a federal candidate: Donald Trump.48 

Consistent with MUR 6213 (DUMPREID PAC), the fact that the Committee includes “Trump” 

as an apparent acronym in its name on its Statement of Organization does not change that it is a 

name of a clearly identified candidate in the name of an unauthorized committee on its Statement 

of Organization, in apparent violation of section 30102(e)(4).49

* * *

In sum, the Act, court opinions, Commission MURs and advisory opinions, the RAD 

Review and Referral Procedures, and RAD practice all consistently lead to the conclusion that 

the Commission should reject the Committee’s argument and determine that the Committee’s 

name on its Statement of Organization includes the name of a federal candidate as proscribed by 

52 U.S.C. § 30102(e)(4).

IV. RECOMMENDATION

For the reasons stated above, we recommend that the Commission conclude that the 

Committee’s name on its Statement of Organization includes the name of a federal candidate as 

proscribed by 52 U.S.C. § 30102(e)(4).

Attachment

Letter from Jon Berkon, Request for Consideration of Legal Question, Stop These Oppressive 

People: Tyrants Racists Unqualifieds Misogynists Propagandists (“STOP TRUMP”) (Oct. 18, 

2023).

(last visited Nov. 27, 2023) (referring to both its full name and acronym in reference to itself).

48 See supra, note 4 and related text.

49 An additional concern with concluding that an acronym cannot, by law, be a name is possible inconsistency 

with or frustration of the Commission’s recent amendments to regulations concerning internet public communication

disclaimers. See Internet Communication Disclaimers and Definition of “Public Communication,” 87 Fed. Reg. 

77,467 (Dec. 19, 2022). The Commission approved the use of “a commonly understood abbreviation or acronym by 

which the person or persons are known” in lieu of the full name in adapted disclaimers that might not otherwise 

conveniently or practicably accommodate the payor’s full name. 11 C.F.R. § 110.11(g)(1)(i). Of note, adapted 

disclaimers for communications not authorized by candidates must satisfy the general disclaimer requirements, 

which require disclaimers to “clearly state the full name” of the payor, among other requirements. Id. 

§ 110.11(b)(3); id. § 110.11(g)(1)(i) (requiring any adapted disclaimer to satisfy 11 C.F.R §110.11(b)).
October 18, 2023 

VIA EMAIL 

Federal Election Commission 

Attn: Commission Secretary

1050 First Street, NE 

Washington, DC 20463 

LegalRequestProgram@fec.gov

Re: Request for Consideration of Legal Question, Stop These Oppressive People: 

Tyrants Racists Unqualifieds Misogynists Propagandists 

Dear Commissioners:

Pursuant to the Reports Analysis Division Legal Question Resolution Program, 92 Fed. 

Reg. 30,741 (May 12, 2023), Stop These Oppressive People: Tyrants Racists Unqualifieds 

Misogynists Propagandists (the “Committee”), seeks consideration from the Federal Election 

Commission (“Commission” or “FEC”) on whether the use of the acronym STOP TRUMP on its 

Statement of Organization violates 52 U.S.C. § 30102(e)(4) because it forms the name of a federal 

candidate. 

Background 

The Committee is a hybrid PAC that filed its Statement of Organization with the 

Commission on August 9, 2023.1 On August 27, 2023, the Committee received a Request for 

Additional Information (“RFAI”) from the Reports Analysis Division (“RAD”) concerning the 

Committee’s Statement of Organization and whether the Committee was in violation of 52 U.S.C. 

§30102(e)(4). Under 52 U.S.C. § 30102(e)(4), a statement of organization filed by authorized

committees must “include the name of the candidate who authorized such committee,” but in the

case of unauthorized political committees, the statement “shall not include the name of any

candidate in its name.”2 The RFAI directed the Committee to “amend [its] Statement of

Organization to change the name of [the Committee] so that it does not include the candidate’s

name and/or provide further clarification regarding the nature of [the] [C]ommittee.”3

1

 Stop These Oppressive People: Tyrants Racists Unqualifieds Misogynists Propagandists (STOP TRUMP), 

Statement of Organization (Aug. 9, 2023), 

https://docquery fec.gov/pdf/052/202308099596506052/202308099596506052.pdf. 2

 52 U.S.C. § 30102(e)(4). 

3

 Request For Further Information (Aug. 27, 2023), 

https://docquery fec.gov/pdf/447/202308270300191447/202308270300191447.pdf. 

250 Massachusetts Ave NW, Suite 400 | Washington, DC 20001

Attachment 001
2 

On October 2, 2023, the Committee responded to the RFAI by noting that it the Committee 

explained that it intended to use the acronym STOP TRUMP on its website, social media, and as 

the name of various programs and projects.4

 The Committee explained that was well within its 

First Amendment rights to use the acronym STOP TRUMP online and in special projects,5 and 

that it included the acronym on line 1 of its Statement of Organization to provide transparency to 

members of the public. The Committee further responded that it was not an authorized committee 

of any federal candidate and that its name did not include the name of a federal candidate.6 In 

particular, the Committee asserted that the use of an acronym does not violate the Act’s prohibition 

on an unauthorized committee’s inclusion of a candidate’s name in its name. The Committee also 

pointed out that committees registered with the FEC routinely use acronyms that spell out names 

of federal candidates.7

 

On October 4, 2023, a RAD analyst informed the Committee that its response to the RFAI 

was not sufficient because the majority of the examples cited in the response were either leadership 

PACs or cases where the reference to the candidate was ambiguous (e.g., Ron Response PAC). 

Even though leadership PACs are unauthorized committees just like the Committee, the analyst 

claimed that leadership PACs were different because they have the candidate listed as a sponsor 

on the Statement of Organization. The analyst informed the Committee that it would be referred 

to the Alternative Dispute Resolution Office unless the Committee filed a Form 1 changing its 

name. 

Analysis 

The Legal Question Resolution Program permits committees to seek Commission 

consideration of a determination by “RAD that a person remains obligated to take corrective action 

to resolve an issue that has arisen during the report review” if there is a material dispute on a 

question of law on the recommended corrective action and the request is submitted within 15 days 

of RAD’s determination.8 A question of law warrants Commission consideration if: 

(1) the legal issue is novel, complex, or pertains to an unsettled question of law; (2) 

there has been intervening legislation, rulemaking, or litigation since the 

Commission last considered the issue; or (3) the request to take corrective action is 

contrary to or otherwise inconsistent with prior Commission matters dealing with 

the same issue.9

The Committee’s request satisfies these standards. The response is timely filed because 

RAD informed the Committee on October 4, 2023, of its determination that the Committee 

remained obligated to take corrective action despite the Committee’s thorough response to the 

4 Id.

5 Id. 6 See Stop These Oppressive People: Tyrants Racists Unqualifieds Misogynists Propagandists (STOP TRUMP), 

Miscellaneous Text (FEC Form 99), 

https://docquery fec.gov/pdf/112/202310029597392112/202310029597392112.pdf (Oct. 2, 2023). 7 Id.

8

 RAD Legal Question Resolution Program, 92 Fed. Reg. 30,741, 30,741 (May 12, 2023). 

9 Id.

Attachment 002
3 

RFAI. Further, there exists a material dispute on the question of whether the Committee must 

remove the acronym from its Statement of Organization to comply with 52 U.S.C. § 30102(e)(4). 

As explained below, the Committee’s position is that contrary to RAD’s determination, its name 

fully complies with 52 U.S.C. § 30102(e)(4). 

First, as explained in its response to the RFAI, the Committee’s name does not use a federal 

candidate’s name. Rather, the Committee’s name—Stop These Oppressive People: Tyrants Racists 

Unqualifieds Misogynists Propagandists—forms an acronym, “STOP TRUMP,” which the 

Committee simply indicated on Line 1 of its Statement of Organization. Use of the STOP TRUMP 

acronym on the Form 1 cannot be reasonably viewed as the “name” of a federal candidate. To be 

sure, “acronym” is defined as an “abbreviation consisting of the first letters of each word in the 

name of something, pronounced as a word.”10 The ordinary textbook definition of “acronym” does 

not support RAD’s determination that it is somehow a “name” and thus the Committee is in 

violation of 52 U.S.C. § 30102(e)(4). 

Second, while there has been at least one enforcement action involving a committee that 

used an acronym as part of its official name, the Commission did not definitively settle the question 

on whether the acronym violated 52 U.S.C. § 30102 (e)(4). MUR 6213 involved an unauthorized 

committee that included the following name on its Statement of Organization: “Decidedly 

Unhappy Mainstream Patriots Rejecting Evil-mongering Incompetent Democrats Political Action 

Committee (DUMPREID PAC).”11 Although the Office of General Counsel took the position that 

the committee “has violated, and is still violating” the Act “by including Senator Reid’s last name 

in a parenthetical,”12 the Commission did not adopt such a finding. Instead, the Commission simply 

noted that the Committee “may have violated” the Act and ultimately dismissed the matter.13 As a 

result, the Commission has not definitively settled the question of whether the use of an acronym 

that forms the name of a federal candidate on the Statement of Organization violates the Act. The 

Committee strongly urges the Commission to resolve this question now by firmly concluding that 

its use of an acronym does not constitute a “name” for purposes of 52 U.S.C. § 30102(e)(4). 

Third, RAD’s determination that the examples included in the Committee’s response are 

either ambiguous or involve leadership PACs, rendering them different from the Committee, is 

clearly erroneous and requires reversal by the Commission. There is nothing ambiguous about Ron 

Response PAC; it actually includes the first name of a federal candidate, and the committee is 

organized to oppose that candidate’s presidential bid. To date, this committee has not been asked 

to change its name. Further, RAD’s conclusion that leadership PACs are somehow different 

because they are sponsored by federal candidates is a distinction without any meaning under 52 

U.S.C. § 30102(e)(4). Just like the Committee, a leadership PAC “is not an authorized committee 

of the candidate or officeholder and is not affiliated with an authorized committee of a candidate 

10 Cambridge Dictionary, https://dictionary.cambridge.org/us/dictionary/english/acronym (last visited Oct. 18, 2023) 

(emphasis added); see also Mirriam Webster, https://www merriam-webster.com/dictionary/acronym (last visited 

Oct. 18, 2023) (similar definition). 

11 See First General Counsel’s Report at 1, MUR 6213 (Decidedly Unhappy Mainstream Patriots Rejecting Evilmongering Incompetent Democrats Political Action Committee (DUMPREID PAC). 12 Id. at 5. 13 Factual & Legal Analysis at 4-5, MUR 6213 (Decidedly Unhappy Mainstream Patriots Rejecting Evil-mongering 

Incompetent Democrats Political Action Committee (DUMPREID PAC). 

Attachment 003
4 

or officeholder.”14 Indeed, the Commission’s guidance states that leadership PACs “operate under 

the same rules as other nonconnected committees.” 15 As noted in the Committee’s response to the 

RFAI, there are several examples of unauthorized committees whose names constitute acronyms 

that spell out the name of a federal candidate or include the actual candidate’s name.16 There is no 

legal reason for treating the Committee any differently from these committees. 

Finally, there is no risk of public confusion with the Committee’s use of an acronym that 

spells out the name of a federal candidate. Using such acronyms is so common that news articles 

often write about them.17 With the name (and acronym), “Stop These Oppressive People: Tyrants 

Racists Unqualifieds Misogynists Propagandists (STOP TRUMP),” the public will not mistake the 

Committee as being affiliated with or authorized by candidates Donald Trump or Joe Biden. The 

Committee’s name unequivocally shows opposition to Donald Trump, and any ads it disseminates 

to the public will include the required disclaimer stating that the ad “is not authorized by any 

candidate or candidate’s committee.” Thus, the name and required disclaimer eliminate any risk 

of confusion about the Committee’s status vis-à-vis any federal candidates. 

Conclusion 

For the reasons outlined above, the Committee does not believe that including an acronym 

that forms the name of a federal candidate on a Statement of Organization violates 52 U.S.C. 

§ 30102(e)(4).18 However, RAD has determined that the Committee is in violation of 52 U.S.C. 

§ 30102(e)(4) and has advised the Committee to take corrective action by amending its Statement 

14 FEC, Types of Nonconnected PACs, https://www.fec.gov/help-candidates-and-committees/registering-pac/typesnonconnectedpacs/#:~:text=A%20leadership%20PAC%20is%20defined,an%20authorized%20committee%20of%20a (last visited 

Oct. 18, 2023). 

15 Id. 16 These include: 

 “Conservative Opportunity Leadership and Enterprise PAC (COLE PAC),” which is currently operating as 

the leadership PAC of Representative Tom Cole; 

 “Building Leadership & Inspiring New Enterprise PAC,” (BLAINE PAC) which is currently operating as 

the leadership PAC of Representative Blaine Luetkemeyer; and 

 Support Taxfighters & Elect Effective Leaders PAC” (STEEL PAC), which is currently operating as the 

leadership PAC of Representative Michelle Steel. 

 CAROLYN’s PAC is the leadership PAC of Representative Carolyn Maloney. 17 See, e.g., Herb Jackson, Leadership PACs are often overlooked. These corny names can’t be ignored, RollCall, 

(Apr. 20, 2021), https://rollcall.com/2021/04/20/leadership-pacs-fundraising-names/ (last visited Oct. 18, 2023); 

Eliza Newlin Carney, Roll Call’s Guide to the Most Clever Leadership PAC Names (Feb. 20, 2015), 

https://rollcall.com/2015/02/20/roll-calls-guide-to-the-most-clever-leadership-pac-names-2/; Colin Campbell, Tillis 

acronyms his first name, launches PAC, The News & Observer (Jan. 7, 2015), 

https://www.newsobserver.com/news/politics-government/politics-columns-blogs/under-thedome/article10214774 html (last visited Oct. 18, 2023). 18 There is no question that the Committee is permitted to use the acronym “STOP TRUMP” in projects. 

Commission regulations at one time prohibited the use of a candidate’s name by nonconnected committees in any 

“project name or other designation,” but that regulation was found to be unconstitutional in Pursuing America’s 

Greatness v. FEC, 363 F.Supp.3d 94 (D.D.C. 2019). Even when the regulation was in effect, it permitted the use of 

a candidate’s name in the title of a special project if the title “clearly and unambiguously shows opposition to the 

named candidate.” 11 CFR § 102.14(b)(3). 

Attachment 004