Republican National Committee Washington, DC 20003 … · RNC's voter daita collection ... for...

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Republican National Committee 310 First Street, SE

Washington, DC 20003

January 12, 2015.

JeffS. Jordan Assistant General Counsel Complmnts Examination & Legal Administration Federal Election Commission 999 E Street, NW Washington, DC 20463 Re: MUR 6888

Dear Mr. Jordan:

Days before the 2014 ejection, the American Democracy Legal Fund ("ADLF") filed a

politically motivated Complaint and supplemental Complaint (collectively, the "Complaint")

against the Republican National Committee ("RNC") and a host.of other Republican entities that

is nothing more than a rhetorically charged, overreaching parade of erroneous legal theories and

inaccurate facts, which relies primarily on internet stories, which in turn rely on anonymous and

uninformed sources, unfounded conclusory statements, and out-of-context quotes. For the

reasons explained below^ the Commission should promptly dismiss the Complaint against the

RNC.

I. INTRODUCTION & STATEMENT OF THE FACTS

By all accounts, data about voters has always been an important component of political

campaigns. Recognizing the importance of raw data to decisions about voter registration

identification, and turnout, the RNC has an active and robust Digital & Data Department. In

2011 and 2012, for example, the RNC Strategy team's (now known as the Data team) budget

was approximately $14 million. Affidavit of Chuck DeFeo ("DeFeo Aff.") H 5. In 2013, the

Strategy and Digital teams were combined to form the Digital & Data Department. Id. ^5. The

department is responsible for all aspects of the RNC's data and digital effort, including the

RNC's voter daita collection efforts, website and online presence (Facebook, Twitter, etc.),

online fundraising, and developing and managing "political technology" tools such as websites'

and applications for voter registration and absentee ballot requests, as well as - and most

importantly - management of the RNC's voter file.. Id. ^ 7. In 2014 alone, the RNC invested

approximately $11.5 million in that effort, for staff salaries and benefits, hardware such as

servers and web hosting, data acquisition, and software. Id. 5. The RNC collects data for its

own use, such as for fundraising, party building, voter contact and social media, and it hires

outside vendors to complement the in-house effort. For example, it paid $1.2 million to a vendor

jl^ in 2014 alone for data acquisition calls and data consulting. Id. f 5. The RNC also established

6 . , 9 Para Bellum Labs, its own in-house digital start-up and innovation hub, and hired a Chief Data 8

Officer, Chief Digital Officer, and Chief Technology Officer.

The RNC's Data and Digital department employed approximately 42 employees in 2014,

housed in the RNC's Washington D.C. headquarters and its tech-focused West Coast office in

Silicon "Valley.^ DeFeo Aff. 6. The team includes 15 technology experts: six data analysts

who write computer code to analyze the RNC's voter data; three data scientists who perform'-"

predictive analysis and modeling on the RNC's voter file data; and six data engineers who build

tools that interact with the RNC's voter file. DeFeo Aff. ^1 6. The department is headed by

Chuck DeFeo and Azarias Reda. DeFeo Aff. 1(3. DeFeo is the RNC's Deputy Chief of Staff

and Chief Digital Officer. Prior to his role at the RNC, he^was the Senior Vice President for

Edelmen. Earlier in his career he managed the digital efforts for the Bush/Cheney 2004 re

election campaign, and oversaw data and technology projects for the U.S. Attorney General and

See httD://www.Darabellufnlabs.com/whvwork.html. ' The RKG pays approximately $6,500 per month to rent office space for its Silicon Valley Office. See Ex. E.

http://www.Darabellufnlabs.com/whvwork.html

Department of Justice in 2001. Reda is the RNC's Chief Data Officer. He has a PhD in

Computer Science Engineering from the University of Michigan. He was previously employed

at Linkedin, and was the founder of an enterprise software startup company.

In contrast to ADLF's allegations, the RNC's Digital & Data department maintains,

operates, and administers its own voter file. DeFeo Aff. ^ 7; see Complaint at 5, 13. The RNC

captures data from many sources in addition to through its list exchange with the Data Trust,

1 including via state party and candidate list exchanges, from state and local election officials, and 6 0 from commercial list brokers. Id. ^ 7. In 2014, the RNC spent approximately $2.6 million on

^ data enhancements and in-house data management. After data is captured, the RNC Data team

9 2 sanitizes and formats it. For example, if the RNC purchases a list from the Florida Secretary of

6 9 State that contains a voter named Mary Smith, and the RNC's voter file already contains a voter 9

by the same name but at a different address, the RNC Data team must determine whether those

two records identify the same or different persons. After the data, is sanitized and formatted, the

Digital & Data team performs quality control testing and remediation on ah ongoing daily basis.

Not only is the Complaint faulty in its baseless conclusion that Data Trust manages the

RNC's voter file, but it makes an even more fundamental error by conflating the RNC with the

"GOP" or the "Republican Party." The RNC is neither. This obfuscation appears to be

intentional since Brad Woodhouse, the signatory of the Complaint for ADLF, is a former senior

official at the Democratic National Committee and Democratic Senatorial Campaign Committee'

and presumably is familiar with the difference between national committees of political parties

and the political parties themselves. The RNC is a national committee of the Republican Party

under 52 U.S.C. § 30101(14) exempt from income tax under section 527 of the Interrial Revenue

Service code, and is an unincorporated association governed by the rules adopted by the

' Seehtto://vi<ww.ameficansuniteclforchanBe.orB/DaBe/coritent/w.oodh6use.

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Republican National Gonvention. It is comprised by its 168 members, all of whom are partrtime

volunteers. Members consist of a national committeeman, national committeewoman, and state

party chairman from each of the states and territories. Although the RNC is the national

organization of the Republican Party, it is one of many Republican Party entities, including state

and local parties, as well as many other Republican organizations operating on the national, statOi

and local level.

ADLF purports that the RNC "formed" Data Trust, see Complaint at 4, and misconstrues

factually inaccurate media accounts to support its fallacious argument. But the reality is far

different. In 2011, a group of Republican leaders, including one of the RNC's 168 volunteer

members acting in his personal capacity, considering forming what would become the Data

Trust, approached the RNC about entering into a list exchange agreement. The RNC has had,

and does have, list exchange agreements in place with, many other entities, including state party

committees, candidate committees, and other organizations. List exchange agreements such as

these, which are common in the regulated community and within both major parties as well as

minor parties, allow the contracting entities on both sides of the transaction to receive valuable

enhanceihents to their data by paying for such enhancements with their own valuable data rather

than money. These arrangements are of course explicitly endorsed by the Federal Election

Commission (the "FEC" or "Commission"). See AO 2002-14 at 5; see also AO 1981-46 at 2.

The RNC and the Data Trust entered their first such arrangement vrith each other in 2011Per

the terms of the agreement, the Data Trust would be provided access to a substantial portion of

* The Data Tnist is actually two separate entities; (I) The Data Tnist, which is a Virginia business trust, and (2) GOP Data Trust, LLC. GOP Data Trust, LLC is a wholly owned subsidiary of The Data Trust. The RNC's list exchange agreement was entered into with The Data Trust, and its purchase.of Data Beacon (discussed below) was through GOP Data Trust, LLC. For purposes of the RNC's response to the Complaint, the RNC refers to the two entities as one. The RNC acquired this information about Data Trust's iegal structure in the course of negotiating the list exchange and other agreements referenced herein.

the RNC's voter file, and in exchange, the RNC would receive commercial data enhancements.

The parties renewed this agreement in 201.4.

In addition to its list exchange agreement, the RNC also had and continues to have a

vendor relationship with the Data Trust. Although ADLF claims that the RNC has only paid

$25,000 to ,the Data Trust, like most of the allegations in the Complaint, this claim is false. In

2013, the Data Trust began developing a voter relationship management ("VRM") software

package called Data Beacon. During the software's Beta testing period,^ the RNC agreed to

lease the program; in exchange for making available to the RNC a Beta version of the software,

the RNC agreed to. pay a commercially reasonable fee Of $5,000 per month and provide expert

user feedback on the functionality of the product to help the Data Trust develop a high-quality

program that it could successfully market to Republican organizations, including the RNC.

DeFeo AfT. ^ 8. The RNC - and presumably the Data Trust - hoped and expected that the end

product would provide a long-term data solution, for which the RNC and other Republican

entities would pay a market rate license fee. By July 2014, however, the Data Trust decided that

it was no longer interested in developing Data Beacon. As a result, the RNC purchased the

unfinished Data Beacon from the Data Trust for the sales price of $150,000. Ex. A. At the same

time, the RNC also paid the Data Trust $87,800 for engineering and consulting services to

facilitate the transition. Ex. B. The RNC now engages an independent contractor. Scalable

Research Consulting Inc., to complete Data Beacon, with payments to the firm totaling

$410,185.77 in 2014. Ex. C.® The RNC'also now licenses from the Data Trust an application

program interface ("API") that works witli Data Beacon and in 2014 paid the Data Tmst $60,000

^ Data Beacon, although still not a complete product, was early stages of development during the Beta testing period; Data Trust provided it to the RNC to test, which provided the developer with vaiuable input. * The RNC paid Scalable Research Consulting Inc. $410,185.77 In 2014, but only $255,706 of the expenditures are currently on the RNCs FEC reports. The remaining payments will be demonstrated on the RNC's year-end FEC report.

for the use of this API. Ex. D. Data Beacon, along with a program called GOP Data Center, is

one of two VRM systems used by the RNC.

ir. LEGAL ANALYSIS

The Commission "may find 'reason to believe only if a Complaint sets forth sufficient

specific facts, which, if proven true, would constitute a violation of the FECA. Complaints not

based upon personal knowledge must identify a source of information that reasonably gives rise

1 to a belief in the truth of the allegations presented." MUR 587.8 (Arizona State Democratic

0 Central Committee), Statement of Reasons of Vice Chairman Donald F. McGahn and

^ Commissioners Caroline C. Hunter and Matthew S. Petersen, at 5; see also 11 C.F.R. §

111.4(d)(2). The Complaint fails to meet this minimum standard, instead relying upon

inaccurate media accounts based upon anonymous quotes. While such tactics may be the tools

of operatives like the signatory of this Complaint, they should have no credence in an

enforcement action by the Commission.

A. The Rive lias not received in.-ldiid contributions from Data Trust.

The RNC has not received any in-kind contributions from the Data Trust because the

RNC has always paid the usual and normal charge for the goods and services received from Data

Trust. The ADLF's allegations seem to stem from a misunderstanding of the activities

described, and are based on nothing more than inaccurate and misconstrued media accounts.

Even more fundamentally, tlie complaint's assertion of illegal in-kind contributions depends

entirely on its allegation that the RNC has paid the. Data Trust only $25,000 - a claim that is

demonstrably false.

The Data Trust has provided two types of products and services to the RNC:

technological and data. On the technological side, the Data Trust first provided a license to a

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Beta version of a VRM software package, Data Beacon, and subsequently sold Data Beacon to

the RNC. DeFeo Aff. ^ 8. The Data Trust now licenses an API to the RNC. On the data side,

the Data Trust provides enhanced list data (in exchange for the data of equal value that the RNC • t

has provided to the Data Trust). Jd. | 8. The Complaint wrongly asserts that the RNC "made a

single payment to the iSata Trust in 2014 for $25,000" and that "this amount does not accurately

reflect the fair market value" of the services provided to the RNC. Complaint at 16. In fact, in

addition to that $25,000 for the initial Data Beacon license, the RNC paid the Data Trust

$237,800 in 2014 for the purchase of Data Beacon, an unfinished product, and related

engineering and consulting services. See Ex. A; Ex. B. The RNC also pays a license fee to the

Data Trust for tlie API, which in 2014 amounted to $60,000. Ex. D.

Contrary to the ADLF's unfounded assertions, the Data Tmst does not "maintain and

control [the RNC's] entire voter file." Complaint at 13. The RNC maintains and controls ite

own voter file. DeFeo Aff. ^jV. In fact, essentially all of flie RNC's data team's time is spent on

voter file rhanagement and maintenance. Id. ^ 7. The RNC's in-house data and digital effort is

designed to develop the most robust, accurate, and sophisticated voter file in the party's history,

and to make that data available to other party committees and candidates, primarily through list

exchange agreements for data of. equal fair market value, in accordance with the requirements of

FECA. The ADLF's suggestion that the RNC "decided to house its data operation, in a for-profit

company specifically so that other organizations could subsidize the high cost of such an

operatioUj" Coniplaint at 17, ignores the fact that the RNC spends millions of dolliars on its data

operation and is clearly erroneous.

Witli respect to the second type of product or service that the Data Trust provides—^the

enhanced data that the RNC receives from the Data Trust—^the RNC licenses a major portion of

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its voter file to the Data. Trust in exchange for those enhanced records. The RNC has had list

exchange agiecments in place with Data Trust since 2011. In exchange for its voter list, the

RNC receives enhanced consumer data arid other data together valued at the same fair market

value as the data it licenses to the Data Trust. In addition to its agreement with the Data Tnist,

the RNC has similar list exchange agreements in place with, many other entities, including state

party committees and candidate committees, while also acquiring data itself and through outside

1 vendors. The Complaint fails to acknowledge that a national political party committee

y may exchange its mailing lists or. portions of its mailing lists of equal value with 2 any outside organization, including political committees under the Act, Section ^ 527 organizations (including state and local campaign, PAC, and party

organizations), 501(c)(3) and (c)(4) groups, non-profit and for-profit corporations, and labor organizations, provided that the lists or the portions of the lists that are exchanged are of equal value. When such exchanges of equal value occur, which

0 are non-reportable events under the Act, no 'contribution, donation, or transfer of 4 funds or any other thing of value' takes place under 2 U.S.C 441i(a), II CFR

300.10(a), or any other provision of the Act or the Commission's regulations.

AO 2002-l'4 at 5.

The Complaint further alleges that because American Crossroads has paid the Data Trust

more than the RNC has, it necessarily follows that the Data Trust provided services to the RNC

at a discount. Complaint at 16-17. The RNC does not know how much American Crossroads

has paid the Data Trust. But according to this logic, the Commission should launch an

investigation every time a vendor appears pn multiple conunittees' disclosure reports with

different disbursement amounts. Common sense, of course, allows for the reality that different

committees pay for different services, and a vendor obviously must charge different amounts -

for both commercial and legal reasons - when the market value of one is higher than that of

another. Indicative of the Complaint's unreliability are its false statements about the goods and

services provided by the Data Trust to the RNC and the amount that the RNC paid the Data Trust

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for those goods and services. Because the Complaint simply cannot overcome its. misstatement

of amounts paid, its misunderstanding of services provided, and its failure to consider

Commission precedent, the Commission must find no reason to believe that the RNC received an

excessive contribution from the Data Trust.

B. The RNC. did not cneage in illegal coorilinatioii thrbilgli Data Trust and i360.

ADLF makes sweeping and unspeoific accusations of rampant "coordination" based on

more factual inaccuracies and without pointing to a single particular communication that was

supposedly coordinated with the RNC. The Complaint alleges that "[cjustomers [of the Data

^ Trust] don't have to wait for non-public information provided by the Trust to be shared between

9 2 them, as the most recent upgrade allows that information to be shared in real time," and

Q repeatedly cites to the purported "real time" updating, downloading, or tracking of data.

Complaint at 14. First, there is no legal significance to whether data is exchanged in real time or

periodically, nor does ADLF specifically claim any significance. But this real-time exchange is

another inaccurate assertion based on a speculative media account that does not quote anyone

with first-hand knowledge of how Data Trust operates. In reality, the data exchanges are

periodic and not in real time. The Complaint also alleges that the Data Trust provides voter

identification and list development services to the RNC and guesses that the Data Trust "is

providing the exact same IDs and lists to outside groups." Complaint at 13-14. ADLF

misunderstands the law and the facts. Data Trust does not provide list management services for

the RNC. (nor does ADLF even explain what it naeans by "list management services"). And

while the RNC has no direct knowledge of whether the Data Trust provides similar lists to other

organizations as it does to the RNC, there is nothing remotely remarkable or illegal about a list or

data vendor, providing the same data to multiple clients. Moreover, there is nothing improper

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about the RNC receiveing data from the Data Trust since the RNC pays lair market value for the

information via its list exchange agreement.

A commiinication is coordinated when the communication (1) "[i]s paid for ... by a

person other than the candidate, authorized committee, or political party committee;" (2) satisfies

the content standard; and (3) satisfies the conduct standard. iSee IIC.F.R. 109.21(a)(l)-(3). The

Complaint does not even identify a single communication paid for by a person other than the

RNC; allege that the Data. Trust created, produced or distributed any such cominunication; or

identify any material information from the RNC used in such a communication. Thus, the

Complaint fails to even make specific allegations as to any of the three prongs. "The

Commission may find 'reason to believe only if a Complaint sets forth sufficient specific facts,

which, if proven true, would constitute a violation of the FECA. Complaints not based upon 8

personal knowledge must identify a source of information that reasonably gives rise to a belief in

the truth of the allegations presented." MUR 5878 (Arizona State Democratic Central

Committee), Statement of Reasons of Vice. Chairman Donald F. McQahn and Commissioners I

Caroline C. Hunter and .Matthew S. Petersen, at 5; see also 11 C.F.R. 111.4(d); The Complaint

fails to meet this pleading standard, relying instead on the following legally flawed syllogism: i

American Crossroads, Crossroads GPS, Americans for Prosperity and "presumably other outside

groups supportive of the Republican Party" were clients of the Data Trust and/or i360, and the

RNC was a client of the Data Trust, and therefore all of the independent expenditures by these

groups were "coordinated" with tlie RNC.

The Complaint does not point to a single communication that, purportedly satisfies the

content prong. Moreover, it is the RNC's understanding that the Data Trust does not even

pailicipate in the creation, production, or distribution of communications. Thus, even if a

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comraunication did satisfy both the payment and content prongs of the Commission's

coordination regulations, the conduct prong is not met because the Data Trust is not a "conunon

vendor" as that term has been defined by the PEG in its own regulations.

.11 C.F.R. 109.21 (d)(4) explains that the "conduct" prong of the coordination regulation is

satisfied if "the person paying for the communication, or an agent of such person, contracts with

or employs a commercial vendor to create, produce, or distribute the communication," and that

cominercial vendor has provided any of the enumerated services during the previous 120 days to

the candidate who is clearly identified in the communication, or the candidate's authorized

^ committee, or a political party committee.

9 2 As an initial matter, the Data Trust is not an agent of the RNC because it has no authority

7 to engage in any of the enumerated activities on the RNC's behalf, as the Complainant implicitly

acknowledges by relying on a "conunon vendor" theory of coordination. Further, no past

Commission enforcement matters of which we are aware consider a vendor who did not "create,

produce, or distribute" communications because the regulations simply do not allow for it.

Instead, they have considered situations where the veiidor in question could potentially fall

within the scope of the regulation based on their creation, production, or distribution of identified

communications. See e.g., MUR 5502 (Martinez for Senate), First General Counsel's Report,

Feb. 14, 2005; MUR 5598 (John Swallow for Congress), First General Counsel's Report, July

21, 2006. The Data Trust cannot be a common vendor as defined in 11 C.F.R. 116.1(c), since it.

did not, to " the RNC's knowledge, "create, produce, or distribute" communications under the

commission's regulations.. And even if the Data Trust were a "common vendor," no infoimation

about the RNC's campaign plans, projects, activities, or needs, that could be material to the

creation, production, or distribution of any public communication, was conveyed by the Data

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Trust to any other person, nor could it have been since the RNC has never shared such

information vvith the Data Trust.' Finally, the Data Trust, does not provide any of the enimierated

services, listed in 11 C.F.R. 109.21(d)(4) to the RNC. In fact, the RNC has no basis for believing

that the Data Tmst even offers these services.

The Complaint cobbles together allegations based on unattributed and often unsupported

conclusions selectively picked from various media accounts; Many of the unattributed quotes

are wrong and not based on reality. Where the Complaint points to attributed quotes, it attempts

to find impropriety where none exists. For example, it cites a few quotes by an RNC

spokesperson: "the platform is the way the Party is going to create an open data environment to

give Republican data users more access to the RNC's premier data warehouse." Complaint at 5.

The Complaint also refers to a quote by the spokesperson whieh stated that "[a]ny time we are

having a conversation with voters, we want to have that information and share that with everyone

on our side." Complaint at 5. These statements about the RNC's aspirations for the future of the

Republican data enviromnent simply rest on a list exchange agreement the RNC has in place

with the Data Trust, and such exchanges have been validated by the Commission, ^ee AO 2002-

14 at S. Although information is shared or enhanced, the clients are unable to determine where

new data originated, who has used the information, or the date it was collected. Although the

Data Trust provides ravv information about voters to the RNC througli the exchange agreement,

as does the RNC to the Data Trust, neither tells the other how to target voters. In fact, the RNC

has its own operation to do this and makes its own decisions about how to use the data it receives

from the Data Trust. The Data Trust does not suggest which voter Characteristics the RNC

should use; nor does the RNC make such suggestions to the Data Trust. The RNC receives and

^ Because the HNC did not coordinate with the Data Trust, it follows that the KNC did not coordinate with i360. The RNC has absolutely no afTiliation with i360.

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transmits only data through the exchange; it does not pass on political strategy or strategic

information. The same is true for the Data Trust. Because the Data Trust is not a "common

vendor" under Commission regulations and has never had access to and thus never conveyed

information about the RNC's plans, projects, activities, or needs that, could be material to any

communication (and no communications have even been identified), there can be no reason to

believe that the RNC engaged in or benefitted from illegal coordination.

C. The RNC did not establish, and has never financed, maintaihcd. or controlled the Data Trust.

For good measure, ADLF tacks on an allegation that the RNC somehow established the

Data Trust or that it maintains or controls it. But here too ADLF's rhetoric cannot overcome the

factual and legal reality. In determining whether a national party committee has established,

financed, maintained, or controlled another organization, the Commission examines the factors

set forth in 11 C.F.R. 300.2(c). These factors "must be examined in the context of the overall

relationship between tlie sponsor and the entity to determine whether the presence of any factor

or factors is evidence that the sponsor directly or indirectly established, finances, maintains, or

controls the entity." 11 C.F.R. 300.2(c)(2). In other words, "the Commission performs a

'totality of the evidence' analysis." MUR 4953 (National Republican Congressional Committee,

et al). First General Counsel's Report, May 21,2003, at 14.

The reality is that the RNC did not establish, and has never financed, maintained or

controlled the Data Trust. The Complaint rests upon media accounts that rely on un-sourccd

assertions and quotes from un-named sources to make broad-brush accusations. The only factors

of the regulation that ADLF cites are 11 C.F.R. 300.2(c)(2)(vi) and (ix). According to the

Complainant, the RNC "had an active or significant role in the formation of the" Data Trust. See

Complaint at 17-18; 11 C.F.R. 300.2(c)(2)(ix). The only evidence offered by the Complainant of

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this allegation is an un-sourced quote from a "media account" that the Complainant fails to cite,

and an allegation that the Data Trust's- website contains the logos of the RNC, National

Republican' Congressional Committee, and the National Republican Senatorial Committee. See

Complaint at 18. These un-sourced media accounts are inaccurate. The RNC did not create the

Data Trust, and the Complainant offers no evidence to suggest it did. In 2011 the RNC was

approached by a group of individuals who were considering forming the Data Trust about

entering iiito a list exchange agreement. The RNC decided to enter into such an agreement.

While Mike Duncan, in his personal capacity, did have a role in the formation of the Data Trust

and once served as its Chairman, his tenure as RNC Chairman had ended more than two years

before he helped form the Data Trust, and as one of its 168. volunteer members, Duncan had no

authority to act as an agent of the RNC.

With respect to the RNC's logo appearing on the. Data Trust website, this was done

without the RNC's permission. Upon learning of its use, the RNC followed its usual policy and

requested that the Data Trust remove the logo. As stated in the Complaint, the logos of the

NRCC and the NRSC were also, on the Data Trust website. This is indicative of the fact that the

Data Trust serves the larger Republican communityi. and likely used the names of the political

committees for advertising purposes, not because of any special relationship between the RNC

and the Data Trust.

ADLF also alleges that the RNC "controls" the Data. Trust because the Data Trust "has

officers who used to be officers of the [RNC], indicating a formal or ongoing relationship"

between the RNC and the Data Trust. Complaint at 18. Although the Data Trust has had

"members, officers, or employees who were memberSj officers, or employees" of the RNC, such

overlap is insufficient to meet even this single factor of the test where,, as here, that overlap does

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not indicate a "formal or ongoing relationship" between the RNC and Data Trust. 11 C.F.R.

300.2(c)(2)(iv). The ADLF's assertion that "[k]ey members of the Republican Party

infrastructure were selected for high raniking positions at the Data Trust" does not amount to an

indication that the RNC established, financed, maintains or controls the Data Trust.* RNC or

DNC members, let alone former Chairs of party committees, need not sit on the sidelines and

forgo business opportunities that involve politics. Indeed, the Commission's Office of General

Counsel ("OGC") has recognized the absurdity of using these kinds of "professional ties" that

many people in politics have with other political participants as the basis for an investigation.

MUR 5338 (Common Cause, et al). First General Counsel's Report, March 27, 2003, at 18, 23.

The "professional ties" the Complainant points to here similarly do not constitute any sort of

basis for a reason to believe that the RNC established, financed, maintained, or controlled the

Data Trust is absurd.

Perhaps aware of the deficiencies in his allegations, the Complainant shades the truth (to

be charitable) significantly by conflating the RNC with "the Republican Party infrastructure."

Complaint at 4. For example, the Complaint notes that the president of the Data Trust "is a

former high ranking aide to John Boehner, and the former deputy executive director of the

[NRCC]." Complaint, at 4. However, John Boehner is not an officer or employee of the RNC,

nor is the Data Trust's president, and the RNC and NRCC are distinct legal entities with different

officers and members with different missions. Second, the Complaint points out that the former

chairman of the RNC has served as the chairman of the Data Trust, but that alone is insufficient

to indicate a formal relationship that would meet one of the factors in the totality-of-the-

' If this were an indication of establishing, financing, maintenance, or control, then the operations of Catalist, a for-profit data company founded by long-time Democratic. National Committee member Harold Ickcs whose clients include numerous Democratic party committees and candidates along with liberal independent expenditure and issue groups would expose Catalist and its many Democratic and liberal clients to liability.

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circumstances test in assessing whether the RNC established, financed, maintains, or controls the

Data Trust.

In MUR 5338, the OGC considered the relationships between the allegedly sponsored

entity, the Leadership Forum, the NRCC, and the House Republican Leadership, and noted that

the relationships in this situation "[were] not insubstantial" (one former chairman of the NRCC,

two former NRCC staff, one who has provided legal representation to both the Forum and the

NRCC). Id. at 16-17. OGC, however, concluded that "something more than the mere fact of [ ]

informal, ongoing relationships between the personnel of a potentially sponsoring and potentially

sponsored entity is necessary to support a conclusion of'establishment, financing, maintenance,

or control.'" Id. at 17-18.

The RNC is an unincorporated association of 168. members. The members consist of a

national committeeman, national committeewoman, and state party ehairman firom each of the

states and territories. The former Chairman of the Data Trust is Mike Duncan, an RNC member,

national committeeman from Kentucky, and former RNC Chairman. All RNC members serve in

a volunteer capacity, as does Duncan. Having an RNC member serve as part of the Data Trust is

hardly evidence in support of a finding that the RNC established, or finances, maintains, or

controls the entity. During his tenure with the Data Trust, Duncan was not only a volunteer RNC

member, but. also led other businesses and organizations. On multiple occasions and in various

contexts, tlie Commission has concluded that one person can wear multiple hats allowing them to

engage in an activity in one capacity that such person would be prohibited from doing in another

capacity.

In AO 2007-05, for example, the Commission concluded that a federal officeholder's

chief of staff was not prohibited from soliciting, directing, and spending non-federal funds on

16

behalf a state political party committee, provided that such activities were undertaken on behalf

of the state party and not the officeholder or the officeholder's campaign committee. The

Commission explained that although the Act prohibits agents of federal candidates and

officeholders from soliciting, receiving, directing, transferring or spending funds in connection

with an election for non-federal office, because the Chief of Staff "received no express

instruction from [the federal officeholder] that he is the Congressman's agent for fundraising

purposes, nor has the Congressman's conduct caused the [Chief of Staff] to believe that he is the

^ Congressman's agent for such purposes," the Chief of Staffs role "does not include any actual

authority, express or implied, to raise or spend campaign funds, and he is not an agent of [the]

Congressman [ ] under 11 C.F.R. 300.2(b)(3)." AO 2007-05 at 3. The Commission further

concluded that even if the Chief of Staff was a fundraising agent of the Congressman, he was

nevertheless not prohibited from raising non-federal flmds, provided that the solicitations were

made "in his own capacity and exclusively on behalf of the State committee, and not on the

authority of any Federal candidate or officeholder." AO 2007-05 at 4, citing AO 2003-10.

Similarly, in AO 2004-25, the Commission reiterated that "the plain language of both the Act

and Conunission's regulations specifically limit application of [the soft money ban] to national

party committee officers and agents only when such individuals are acting on behalf of the

national party committee," in concluding that the chairman of the Democratic Senatorial

Campaign Committee was not prohibited from donating his personal funds to voter registration

organizations. AO 2004-25 at 2 (emphasis in original); see also AO 2013-03 (concluding that a

candidate for federal office was not prohibited from serving as a paid consultant to an

organization that is not registered with the PEC and raises and spends non-federal funds.)

17

The Complaint points to no evidence that the RNC established the Data Trust, or that it

has ever financed, maintained, or controlled the Data Trust. Instead it relies on speculative

media reports. Moreover, the Complaint does not attempt to apply the factors enumerated in 11

C.F.R. 300.2(c), and only even references two of the ten factors of the regulation. Under any

definition of the term, there is no evidence that the RNC established or has ever financed,

maintained, or controlled the Data Trust. 11 C.F.R. 300.2(c)(2). To the contrary, the evidence, as

set foilh herein and by sworn affidavit, demonstrates the complete lack of establishment,

financing, maintenance or control - or of any other violation of the Act.

III. CONCLUSION

This politically motivated Complaint, filed days before the 2014 election, woetully fails

to meet the Commission's pleading standard. It throws a lot against the wall - and names just

about every Republican the Complainant can think of - but nothinjg can stick. It offers no

evidence of violations of the law by the RNC or anyone else, and instead relies on erroneous

legal theories, inaccurate facts, and media opinion pieces relying on anonymous and uninformed

sources. The RNC and the Data Trust have a vendor relationship in which the RNC paid fair

market value for a VRM system, and an agreement for the exchange of data of equal fair rharket

value, the legality of which is clear in Commission precedent.

The Complaint does not allege a single communication that supports the content prong, of

the coordination regulation, nor does the Data Trust create, produce, or distribute

communications. Moreover, the conduct prong is not satisfied because the Data Trust is not a

"common vendor."

With respect, to the assertion that the RNC established, fmances, maintains, or controls

the Data Trust, the Complaint, offers no evidence to support this conclusory allegation other than

18

speculative media accounts based on anonymous quotes and the fact that some individuals

associated with the Data Trust are also connected with the RNC. But there is nothing ithproper,

much less illegal, about such mutual associations. For the reasons above, the Cottunission must

find no reason to believe the RNC has committed any violation and dismiss the Complaint.

Sincerely,

John R. Phillippe Jr. Chief Counsel

David Powers Senior Counsel

5

19

8 5 4 3 9 1

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PAGE 5761 OF 6221

2 21b 22 23 Z4 25

27 28B 2Bb 2Bc 29

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Any Information copied from such Rsports and Stalcmenis may not be sold or used by any perse or for commercial purpos'o.s, other than using'the name and address ol any political ecmmittee to

in lor lha purpose ol soliciting contribullons solicit conlrlbutlons from such commlnee.

V NAME OF COMMrrTEE (In Full) > REPUBLICAN NATIONAL COMMITTEE

A. GOP DATA TRUST LLC

Mailing Address PO BOX 12385

City ARLINGTON Purpose 01 uisbursomeni SOFTWARE PURCHASE

Candidate Nome

State VA

Zip Code 22219

Olllco Sought:

Stele:

House Senate President

Disrlet;

.Disbursement For: Primary Q] General Olher (spaclly) y

Category/ Type

Full Name (Last, First, Middle Inlllal)

B. SMARTECH CORPORATION

Mailing Address AIRNET 801 BROAD STREET. SUITE 530

City CHATTANOOGA Purpose 'ol DlGbursomonl

DATA SERVICES

Slate TN

Zip Code 37402

Candidate Name

Olllce Sought:

State:


rict:

Disbursement For: Primary Q Oaneral Olher (spedly) T

Category/ Type

Full Name (Last, First, Middle Inilial)

C- MATTHEW ALBERS

Mailing Address 9807 EMERALD LINKS DRIVE

City TAMPA Purpose ol Utsbursemeni STIPEND

State FL

Zip. Code 33626

Candldaie^Name

Ofltce.Soughl.;

State: }ls


rlct:

Olsbur^qntenl For:. Primary

flSiB.jOi-'j.'.-s&'SWSr. L;.:J Category/

Type

[~| General Olher (spedly) •

•ale or Disbursement

L.,SL4 .U° J J

Transaction ID; 2ai4M06L2100370

Amount ol Each Disbursement Ihls Period

j _ 150000.00 ij

Dale ol Disbursement

Frv=il^ i jfVFiTi! .

L.^ LMI Transaction ID; 2014M08L2100373

Amount ot Each Disbursement this Period

1 . ' . . 1,2950.01 •! r. •- . "i. .• rj.Ui-r tli. fj—r;,,..w.tw.L

Dete of OlsbursemenI

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Amount of Each Disbursement this Period

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SUBTOTAL ot Disbursements This Page (opllonal). ^ V='-"':?==-si

il 163150.01 Ir

.r —ir—I,"*-'!:'-"*" -'-y*":

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FE6AN026 FEC Schedule 3 (Form 3X) Rev. 02/2003

Imago# 14970688S91

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(or each category of the Detailed Summary Page

FOR LINE NUMBER: (chock only one)

PAGE 5724 OF 6221

2tb 22 23 24 25 27 28a 28b 280 29

26 .30b

Any Inrormalion copied Irom such Reports and Slatements may nol be sold or used by any person for Uio purpose ol soOclling contributions or for commorclal purposes, other than using the name and address of any political committee'to solicit confrlbullons lrom such committee.

NAME OF COMMITTEE (In Full)

REPUBLICAN NATIONAL COMMITTEE

Full Name (Last, First, Middle Initial)

A- LORI FRANSSEN

MaUIng Address' 11033 PARKLAND DR

City TRUCKEE

State CA

Zip Code 96161

Purpose .01 •Isburscment -TRAVEL EXPENSES

li - . ii Candidate Namo ws.' . :tr i KUfci

Cstogory/' tVPfl

state;

Senate President

^rlcl:

Primary Q General Other (specify) T

Full Name (Last. First, Middle Initial)

B- GOP DATA TRUST LLC


City ARLINGTOiy Hurposc or Disbursement

ITSUPPpRT/MAINTENANCE.

.Candidate'Name

Stale VA

Zip Code 22219

Olllce Sought:

Slate: 5S


ricl:

Disbursement For: Primary General

~ Olher (specify) r

Ji-'-"--!*.--

rr-'f!;"3K'_-:*==a'U

Category/ Type

Full Name (Last, Rrst, Middle Initial)

C. INFO GROUP


CHy OMAHA Purpose. 01 Disbursement .LIST ACQUISITION

Candidate Name

State NE

Zip Code 68103

Olllce Sought:

State;

•RoUsd Senate President

li^rlct:

Disbursement For-Primary

I \ Category/

Typo

I I General Olher (spedly) T

Date ol Disbursement

ij 07 ; (! 02 ; f 2014 S fK-.r.-r-sTiiv.iKrf.-..asT !. -ai-fVvK'—

Transaction ID: 2014M08L2100082

Amount of Each Disbursement this Period p."-':';;"."'?""-:™" •• • "..—.T' !; 1202.79 11

: .i;:= ;=J

Dale of Disbursement

02-rM-.iTr:! i • r 2014 ^

Transaction ID : 2014M08L2100083

Amount of Each Disbursement this Period j,% "javr ftw:^tuiv:!^.TK.t^r«;tse^o;sMi ;iieuj^<i:sisjiv4r;f,sbnw!

I 67600.00 V

Date of Disbursement

Iru-^Ptr J / / I j 07 02 2014

Transaction ID: 2014M08L210008S

Amount ol Each Disbursement this Period n=".'

2274.89 I

SUBTOTAL of Olabursomonts This Pago (optional)..

TOTAL This Period (last page this line number only)..

91277:60 :•! ... _

retuion FEC Schedule a (Fcrm 3X) Rev. 02/2003

1 9

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for each category ot the Detailed Summary Page

FOR LINE NUMBER: (check only one)

PAGE 8975 OF 7442

5? 21b 22 23 24 25 26 27 28a 28b 280 29 30b

Any Inlormelton copied from such Reports, and Slalenients may not bb sold or used by any p.erson for Iho purpose ol'solicliing conlri'buUcns or for commerclat purposes, olher than using the name and address .ol.any pollllcat cdmthlHao lo solicit contributions from sucti commltlse.

\ NAME OF COMMITTEE (In Full)

) REPUBLICAN NATIONAL COMMITTEE

Full Name' (Last, RrsI, Middle I

A. SCALABLE RESEARCH CONSULTING

Mailing Address 1017 EL CAMINO REAL #279

City REDWOOD CITY Purpose Of UlsDursomeni.' IT SUPPORT/MAINTENANCE

Slate CA

Zip Code 94063

Candidate Nemo

Oflico Sought:

Slate:

Hbuso Senate President

ilTrlci:.

Disbursement For: Primary

Category/ Type

[~1 General Olher (specify) y


B- SOUTHWEST PUBLISHING AND MAILING CORPORATION

Mailing Address 4000 SE ADAMS STREET

Clly TOPEKA

Stale KS

Zip Code 66609

Purpose ol Uisbursomonl POSTAGE r'n

.^L a. _ -a t

Cendidaio Name Category/ . Type

Office Sought:

Stale:

Senate President

i^icl:

Primary Q General Other (specify) y

Fulf Name (Last, First, Middle Initial)

C- ACADEMY DOOR & CONTROL CORP

Mailing Address 3931 AVION PARK COURT SUITE C-104

City CHANTILLY Purpose of'Disbursement BUILDING IMAINTENANCE

Candfdato.NamC'

State VA

. Zip Code 20151

Office Sought;

State:

-House Senate President

}ls rtct:

Disbursement For: Pdmary

in" Category/

Typo

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Data of Disbursement

L5^J Lm uisM TransacUon ID; 2014M09L2100073


70000.00 'v?u{ a


/ yS'lTiTj , [ Q8 •: i 04 if I , 20.14 , ?

TranBaction ID: 2014M09L2100074

Amount of Each Dl&bursemom this Period

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Amount of Each Disbursement this Period -.-.SI,-., fs.Vi;, /!•« ,

f 928.20 I

SUBTOTAL Of Disbursements This Page (optional).. 68237.37 j|

TOTAL This Period (fast page .this fine number only).. c FE6AN0Z6 FEC Schedule B (Form 3X] Rev. 02/2003

Image# 14970889332

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FOR LINE NUMBER; (check only one)

I PAGE 7100 OF 7442

fS^lZlb 27

22

28a

23

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24

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Any informallon copied from such Reports and Stalomonts may not bo sold or used by any person tor the purpose of soliclling conlribullons or for commercial purposes, other than using the name and address of any pblllical committee to solicit contributions from such committee.

NAME OF .COMMITTEE (In Full)


Full Name '(Lasl, FlrsL Middle Iriili'al)

A. SCALABLE RESEARCH CONSULTING



08 I i! 21 !i ji 2014

City REDWOOD CITY

Stale CA

Zip Code 94063

Purpose 01 Drstrursemenl IT SUPPORT/MAINTENANCE

Candidate Name

.Ollice Sought:

State;


ifsirici;

pisbursemenl For: ~ Primary General

Other (specify) •

L-r...- I Category/

TVpe

transaction ID: 2014M09L2100979


i . . " 40555.00 H


B- SOUTHWEST PUBLISHING AND MAILING CORPORATION Date of Disbursement

Mailing Address 4000 SE ADAMS STREET > Q8 i 21 !l 5 .2014 . i

City TOPEKA

Stale KS

Zip Code 66609

Purpose, of Disbursemenl POSTAGE.

Candidate Name

Office Sought:

State:


i^rlcl:

Category/ Type

Transaellon fO: 20t4M09L2100981


i 265827.14

Disbursement For: Primary I I General Olher (specify) y

Full Name (Lasl, First, Middle initial)

c. JASON BERLINSKY

Mailing Address 179 TRANSIT STREET Floors


/ rivW: /

City PROVIDENCE

stale Zip Code Rl 02906

Purposo. of Disbursement MANAGEMENT CONSULTING SERVICES

Candidate Name

Oflicp Sought:

Slate:

House Senate

^ Prasldenl Oisirici:

Disbursement For. Prtmaty

Category/ type


Amount of Each Disbursemenl this Period .•.•-.v..,v—'L* ••••!:•'•

2035.00

General

Other (specify) •

SUBTOTAL of Dlsbursemonls This Page (optional)..

TOTAL This Period (lasl page this line number only)..

j 308417.14 i|

FEGANOSB FEC Schedule B (Perm 3X] Rev. 02/2003

12/19«114 Schedi.4eBrorlJnB#21B

4 4

1 7 2 3

PO BOX 1214 ALEXANDRIA, Virginia 22313

TELEMARKETING 10015.50 PO BOX 1214 ALEXANDRIA, Virginia 22313

PEPCO POBOX 13608 PHILADELPHIA, Pennsylvania 191013608

09/10/2014 PEPCO POBOX 13608 PHILADELPHIA, Pennsylvania 191013608

UTILITIES 226.67 PEPCO POBOX 13608 PHILADELPHIA, Pennsylvania 191013608

PREFERRED PARKING PO BOX 670902 DALLAS, Texas 75367

09/10/2014 PREFERRED PARKING PO BOX 670902 DALLAS, Texas 75367

VALET SERVICES 378.88 PREFERRED PARKING PO BOX 670902 DALLAS, Texas 75367

PRIDE SHEETMETAL INC PO BOX 263 LOTHIAN, Maryland 20711

09/10/2014 PRIDE SHEETMETAL INC PO BOX 263 LOTHIAN, Maryland 20711

BUILDING MAINTENANCE 4260.00 PRIDE SHEETMETAL INC PO BOX 263 LOTHIAN, Maryland 20711

LINDSAY REYNOLDS 2106 CONVENT LANE CINCINNATI, Ohio 45208

09/10/2014 LINDSAY REYNOLDS 2106 CONVENT LANE CINCINNATI, Ohio 45208

FUNDRAISING SERVICES 570.00 LINDSAY REYNOLDS 2106 CONVENT LANE CINCINNATI, Ohio 45208

SCALABLE RESEARCH CONSULTING 1017 EL CAMINO REAL #279 REDWOOD CITY, California 94063

09/10/2014 SCALABLE RESEARCH CONSULTING 1017 EL CAMINO REAL #279 REDWOOD CITY, California 94063

IT SUPPORT/MAINTENANCE 35000.00


SCHINDLER ELEVATOR CORPORATION P 0 BOX 93050 CHICAGO, Illinois 606733050

09/10/2014 SCHINDLER ELEVATOR CORPORATION P 0 BOX 93050 CHICAGO, Illinois 606733050

EQUIPMENT MAINTENANCE

641.46 SCHINDLER ELEVATOR CORPORATION P 0 BOX 93050 CHICAGO, Illinois 606733050

SECURITAS SECURITY SERVICES P.O. BOX 403412

09/10/2014 SECURITAS SECURITY SERVICES P.O. BOX 403412 SECURITY SERVICES 5239.93 ATLANTA, Georgia 303843412

KELSEY SHANNON 221 CHURCH STREET WILLIAMSTON, New Jersey 08094

09/10/2014 KELSEY SHANNON 221 CHURCH STREET WILLIAMSTON, New Jersey 08094

MANAGEMENT CONSULTING SERVICES

• 1500.00 KELSEY SHANNON 221 CHURCH STREET WILLIAMSTON, New Jersey 08094

SMARTECH CORPORATION AIRNET 801 BROAD STREET, SUITE 530

09/10/2014 SMARTECH CORPORATION AIRNET 801 BROAD STREET, SUITE 530 PHONE SERVICES 6672.42 CHATTANOOGA, Tennessee 37402

09/10/2014 SMF LLC 107 S. WEST STREET #700 ALEXANDRIA, Vireinia 22314

MAIL PROCESSING SERVICES

3683.46

hHp://docquery.rec.gov/cgl-bin/dcdev/forfns/C00003418S63035/sbK!1B 9/48

iai9a(ii4 Schcdulo B for Uno #2'IB

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13195 FREEDOM WAY BOSTON, Virginia 22713 13195 FREEDOM WAY BOSTON, Virginia 22713

GREATER SANFORD REGIONAL COC 40.0 EAST FIRST STREET SANFORD, Florida 32771

• 09/19/2014 GREATER SANFORD REGIONAL COC 40.0 EAST FIRST STREET SANFORD, Florida 32771

. REGISTRATION FEE 175<00 GREATER SANFORD REGIONAL COC 40.0 EAST FIRST STREET SANFORD, Florida 32771

RHA MARKETING LLC 6910 CRESTWOOD BLVD FREDERICK, Maryland 21703

09/19/2014 RHA MARKETING LLC 6910 CRESTWOOD BLVD FREDERICK, Maryland 21703

POSTAGE 4870.76 RHA MARKETING LLC 6910 CRESTWOOD BLVD FREDERICK, Maryland 21703


09/19/2014 SCALABLE RESEARCH CONSULTING 1017 EL CAMINO REAL #279 REDWOOD CITY, California 94063

IT SUPPORT/MAINTENANCE

40215.89 SCALABLE RESEARCH CONSULTING 1017 EL CAMINO REAL #279 REDWOOD CITY, California 94063

USPS ACCOUNTING SERVICE CENTER 2700 CAMPUS DRIVE SAN MATEO, California 94497

09/19/2014 USPS ACCOUNTING SERVICE CENTER 2700 CAMPUS DRIVE SAN MATEO, California 94497

POSTAGE 100000.00 USPS ACCOUNTING SERVICE CENTER 2700 CAMPUS DRIVE SAN MATEO, California 94497

BRANCH BANKING & TRUST 1909 K STREET NW 2ND FLOOR WASHINGTON, DC 20006

09/22/2014 BRANCH BANKING & TRUST 1909 K STREET NW 2ND FLOOR WASHINGTON, DC 20006

BANK FEES 6873.91 BRANCH BANKING & TRUST 1909 K STREET NW 2ND FLOOR WASHINGTON, DC 20006

AJUUA 14150 E.LLIFF AVE AURORA, Colorado 80014

09/23/2014 AJUUA 14150 E.LLIFF AVE AURORA, Colorado 80014

CATERING/FOOD AND BEVERAGE

. 422.40 AJUUA 14150 E.LLIFF AVE AURORA, Colorado 80014

CORPORATE PRESS INC 9700 PHILADELPHIA COURT LANHAM, Maryland 20706

09/23/2014 CORPORATE PRESS INC 9700 PHILADELPHIA COURT LANHAM, Maryland 20706

POSTAGE 90709.72 CORPORATE PRESS INC 9700 PHILADELPHIA COURT LANHAM, Maryland 20706

RST MARKETING ASSOCIATES INC 1272 CORPORATE PARK DRIVE FOREST, Virginia 24551

09/23/2014 RST MARKETING ASSOCIATES INC 1272 CORPORATE PARK DRIVE FOREST, Virginia 24551

POSTAGE 18893.12 RST MARKETING ASSOCIATES INC 1272 CORPORATE PARK DRIVE FOREST, Virginia 24551

ADP INC PO BOX 842875

09/24/2014 ADP INC PO BOX 842875 PAYROLL SERVICES 903.00 BOSTON, Massachusetts 022842875

ALAMEDA COUNTY REGISTRAR PHILLIP CABLE 1255 FALLON STREET. SUITE G-1 OAKLAND California 94612

09/24/2014 ALAMEDA COUNTY REGISTRAR PHILLIP CABLE 1255 FALLON STREET. SUITE G-1 OAKLAND California 94612

VOTER FILE MAINTENANCE 360.00

N/' at ^ I aw A #A1C4 ^ • W A M

AMERICAN EXPRESS 09/24/2014

htlp;//doequery.rec.gov/cgi-blrVdC(lev/rorms/C00003418/96303S/sb/21B 29/48

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for each category ol the Detailed Summary Page


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Any Information copied from such Reports and Stalemenis may not bo sold or used by any parse or for commercial purposes, other than using the name and address of any political committee to

m for the purpose of sollclllng contributions solicit contributions from such committee.


> REPUBLICAN NATIONAL COMMITTEE

A. WEST LAW INC.


City CAROL STREAM

Slate IL

Zip Code 60197

Purpose. 01 .•.isbursomoni BOOKS AND SUBSCRIPTIONS

•1 .. Candidalo Name

Category/ Type


fViI 10 ir in ; i; 22 i| I: 2014 I

a...- JiLirs'.is'vsVrr.'SSia.-i'

onico Sought:

Stale: m Senate President

riei;

Transaction ID: 2014G30L2100121


/ 2800.49 i

Primary n General Other (specify) y

Full Name (Last, Rrsl, Middle Initial)

B- NORTH CAROLINA BLACK PUBLISHERS ASSOCIATION Dale of Disbursement

Mailing /tddress PO BOX 3825

City DURHAM

Stale NC

Zip Code 27702

Purpose of Disbursement. ADVERTISING

VA- sTw'iti'st.wetist..

Calfigory/ Ty^

Candidate Name VA- sTw'iti'st.wetist..

Calfigory/ Ty^

Oljice Sought

State;

Senate President

Oiirlcl:

Transaction ID: 201403012100130

Amount ol Each Disbursement this Period CT=r-!j:.r.Trn.-.r—

12075.00 i|

Primary Q General Other (specify) y

Full Name (Last, First, Middle InHlaQ

C. SCALABLE RESEARCH CONSULTING


Dale of Dlsbursemenl

•T'i 10

iTTT'B'? ; jrb-uVjl / Tv -

^ LMJ City REOWOOD CITY Purpose 01 Dlsbursemenl IT SUPPORT/MAINTENANCE

candidalo Name

Stale OA

Zip Code 94063

Olllce Sought;

State:


Tii'rict';

Dlsbursemenl For; Primary General Other (specify) y

Category/ Type

Transaction ID; 2014G30L2100131


;| 7booo.oo' I

SUBTOTAL of Olsbursemanfs This Page (optional)


; 84875.:f9 j{

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FE6AN02B FEC Schedulo 8 (Form 3X> Rev. 02/2003

Imago# 14953-191531

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(or each, category of the Detailed Summary Page


PAGE 10674OF-11182

21b 22 23 24 25 27 28a 266 26c 29

26 sob

Any Itiformatlori copied from such Reports and Statements may not be sojd or used by any person (or the purpose oi soliciting contributions or lor commercial purposes, other than.iislng the name and address of any political committee to solicit contributions from such commltteo.



Full Name (Last. Firsi. Middle Initial)

A. PIRYX INC

Mailing Address 144 2ND ST ISTFL


jJiB-FM"-! ; r r-'v'v'Y-v r-'FS-ll i| 10 ij !; 31 ;! : 2014 S ^-.-t'^irvrS V.-ar.i

city SAN FRANCISCO Purpose of Disbursement

BANK CARD SERVICE FEES

State CA

Zip Code 94105

Caridldato Name

Olflcd Sought':

Slate:

I House I Senate

J President listHct:


r !i fc.-

Category/ TVPe


Amount ol Each Disbursement this Period

•i " - - • • - '2170a •:

["""I General Other (specify) y

Full Name (Last, First, Middio Initial)

B- SCALABLE RESEARCH CONSULTING Date of Disbursement


t..Kj LaJ City REDWOOD CiTY Purposo ot Disbursement. iT SUPPORT/MAINTENANCE

Candidate Name

State CA

Zip Code 94063

-J

Olllce Sought:

State:

Category/ Type


Amount ol Each Disbursement this Period w.jin.s. ;.;,.4.:y.:ess

" 5151.30 =

Bli


rtct:

Disburacment For: Primary General Othor (spedly) y

Full Name (Last, Rrst, Middle initial)

C. SOUTH CAROLINA DEPARTMENT OF REVENUE WITHHOLDING Date of Disbursement

Mailing Address REGISTRATION UNIT

City COLUMBIA

State SC

Zip Code 29214-0004

Purpose oh Olsbursemcnl TAXES

•vi. 70 »eats']

Category/ Type

Candidate Name •vi. 70 »eats']

Category/ Type

i: 10 I i 31 ,5 i 2014 . 1

Office Sought

State:

Senate President

)istrlct:

Disbursement For Primary Q General Other (specify) T



I 590.95 I

SUBTOTAL ol Disbursements This Page (optional).... •


5959.33 [

I<

FEC Schedule B (Form 3X) Rev. 02^003

I

Image* 14953191632

SCHEDULE B (FEC Form 3X) ITEMIZED DISBURSEMENTS Use separate schcdule(s)

lor each calegory of the Delailed Summary Page

FOR LINE NUMBER: (cheek only one)

rPAGE10775OF 111^

21b 22 23 24 25 27 28a 2eb 2ec 29

26 30b

Any inlormation copied Irom such Reports and Statsrtienta may. nol ba sold or used by any parse or lor oommorclal puipo.s.os, other, uian using the name and addrcss ol any political commltloe to

(in lor the purpose ol eolicili'ng contribuliona solicit contrlbullons Irom such committee.



A. HOMEAWAY.COM INC

Mailing Address tot 1W FIFTH ST SUITE 300

City Staite Zip Code AUSTIN TX 78703 Purpose 01 Ulsbursemoni TRAVEL EXPENSES

". ..v ii Candidate Name Category/

TVpe Ollico .Sought;

State:

Senate President'

(Id:

Primary Q] General Other (speclly) y

FutI Name (Last. First, Middle Initial)

B- SCALABLE RESEARCH CONSULTING

MaHing Address 1017 EL CAMINO REAL .#279

City REDWOOD CITY Purpose 01 Olstnirsement

IT SUPPORT/MAINTENANCE

State CA

Zip Code 94063

Candidate Name

Olfl(» Sought;

State;


3is rid;.

Olsbursemant For:; Primary

Category/ Type

General Other (speclly)' y

Full Name (LasL First, Middle Initial}

C. AMERICAN EXPRESS

Mailing Address P 0 BOX 981532

Cily EL PASO

State TX

Zip Coda 79998

Purpose ol Disbursement BANK CARDSERVICE FEES i ii

!L,, Category/

Typo

Candidate Name

i ii !L,,

Category/ Typo

Olltca Sought;

Slate:

Senate President

rid:

ptebUrearrienl For: Primary Other (spi Primary Q| C

lecily) y General

Date ol Distiursement

ij 11 ;i 21 !; !• 2014 j

Transaction 10; 2014G30L2iai057M


'i 2175.00 I

[MEMO ITEM)


n-ir-TM't ij b 't S'j . j;v:f?-.-Tt-v"3

uu L2?J Transaction ID; 2014G30L2161059


35000.00


I f o-v'o'i I i". Y-aY'j'y'--T-I li 11 I • 24 ji !• 2014 ^


/Unount ol Each Disbursement this Period

8853.40 , •.V.Wi.sl-nsiJJjiVrtinst'tJUiai'JJsir.

SUBTOTAL of Dlsbursomonls This Page {optional).. ;i 43653.40 ^ ^ zir-rr-AM •.*:*. jrn* •ia.'r-i'sw) .V--

TOTAL This Period (last page this line number only) KiT-'rT.T rrwO Vt

FE6A(«2a FEC Schedule B (Form 3X) Rev. 02/2003

1 6 0 4 4 1 J 2 8

Image# 14953191511

SCHEDULE B (PEG Form 3X) ITEMIZED DISBURSEMENTS Use separate schedule(s)

lor each category ol the Detailed Summary Page

FOR LINE NUMBER: (check only one]

I PAGE1.0654OF 111BZ

21b 22 23 24 25 27 2aa 2Bb 2Bc 29

26 30b

Any Inlormation copied-from such Reports and Slatcrnents may riot be sold or used by any person lor the purpose ol soliciting ccntrlbulions or lor commercial purposes, other than using Ihe narho and address pi any political committee to solicit contributions Irom such committee.



Full Nnmp.(Last, FirSl, Middle Initial)

A. FRAGER'S HARDWARE

Mailing Address ms PENNSYLVANIA AVE SE


jl 10 : f 29 •• 1- 2014

City WASHINGTON Purpose Ol Disbursement OFFICeSUPPLiES

Candidate Nemo

State tSC

Zip Code 20003

Cilice Soirght:

Stale: OIF

House' Senate President

riot:

Disbursement For: Primary General Other (spoclly) r

J -ii

Category/ . Type

Transaction ID: 2014G30L21002e8

Amount ol Each .Disbursement this Period'

ii 42.83 i fti:::.-r:"a

Puli Name (Last. First. MIddte Initial)

B- BOB GdODLATTE FOR CONGRESS COMMITTEE

Mailing Addrees 4208 BRAMBLETON AVE

City ROANOKE

State VA

Zip. Coda 24018

P.uipose oI 'Dlsbuisemeni RENT

Candidate Name Category/ Type


jnini-M j I f o f-o-i t jj'v-v'v-i.''f I.-

ILlJ

dllica Sought:

State: 5is

Senate President

riot:




!! 526.25 {

I I General Other (specily) r

Full Name (Last, First, Middle initial)

C. GOP DATA TRUST LLC


Date of Disbursoment

li-uV-u'-.l I rr'f-'v-5='3 / r; Y'ir=t-irV'ii-'»:'J !{ 10 '] S 29 i! L- 2014 1

City /^RLiNGTON Purpose .'of Disbursement. IT SgPPORT/MAINTENANCE

.Candldale Name

Slate VA

Zip Code 22219

Oflicc Sought:

State;

House Senate

^ President ^rlct:

Disbursement For: Primary Q General Other (specify) y

TransacUon ID: 2ai4G30L2100290


Category/ Type 45000.00 45000.00 .:

SUBTOTAL ol Disbursements This Page (optional)..

TOTAL This Period (last page this line number only)

45569;08 -•<

FE6AN026 PEC SchcdulQ B (Form 3X) RCK 02/2003

Image# 14953191580

k

9 1


(or each category of the Detallod Summary Page


I PAGE10723OF 11162

[XI 21b 27

22 288

23 280

24 28c

26 30b

Any Information copied from such Reports and Sla'tomchls may not be sold or used by any person for the purpose of soliciting contributions or (or commercial purposes, other than using the nemo and address ot any political commirteo to solicit conlribulions from such commitlea.



Full. Name (Last-, Fiiist, Middle InlUal)

A. FLS CONNECT LLC

Mailing Addroas 7300 HUDSON BLVD SUITE 270

Cily SAINT PAUL

State Zip Code MN 55128

Purpose 01 uisbursement TELEMARKETING

uanoioaie Name

Olflce Soughl:

State: bli

House' Seriate President

rici:

Oisburserncnt For: Primary

J"!'..*. wW i. •'

Category/ type

I I General Other (specily) T


B- FULL HOUSE EVENTS LLC


City OLDWtCK Purpose 01 uisbursement FUNDRAiSING SERVICES

Candidate Name

State NJ

Zip Code 08858

Ollrce Sought:'

State:


3istricl:


r ir.-.r.'/RMiiAi.-e':

Category/ Type

Q General Other (specify) T

Full Name (Last, FIrsL Middle initial)

C. GOP DATA TRUST LLC


City ARLINGTON. Purpose of Disbursement nr SUPPORT/MAINTENANCE

Candidate Name.

State VA

Zip Code 22218

Office Sought;

State:

House-Senate President

ililrlct


Category/ TVPO.

General Other (specify) r


I.— till ] 19 . ffW.it. I.--*-...

2014



62629.11 i !'


- rv-rrv-.;v^v' 11 » 'R 19 i! i 2014 „ .

Transaction ID: 2014G30L210a859


7500.00 ^ -I—:: ::


UtiJ LJSJ

Transaction ID: 2014G30L21D0660

/Vnount of Each Dtsbursement this Period

j["" i.. •SS'U.HAJI.. ..-flitni. 'PJ?-* ^ury.I'.r'V.^

SUBTOTAL of Disbursements This Pago (optional).. ii '85l29.ii ?, it-r7:--7r7-:=.


PE6AN02S FEC Schedulo 6 (Fohn 3X) Rev. 02/2003

1

4

I

E

Imago# 14960472715

SCHEDULE B (FED Form 3X) ITEMIZED DISBURSEMENTS Use separate schedute(5)


FOR UNE NUMBER: (check only one)

I PAGE 1404 OF 1734

5?l2'b 27

22 28a

23 2Sb

24 28c

Any Information copied from such Reports and Sialemcnls may not be sold or used by any person for the purpose of soliciting contributions or for commercial purposes, other than using .the-namo and address of any political committee to solicit contrlbudons from such committee.

NAME OF OOMMITTEE (In Full)

• REPUBLICAN NATIONAL COMMITTEE

Pull Name (Last,. First, Middle Initial)

A. BLUEPRINT COMMUNICATIONS

Mailing Address 127 S. PEYTON STREET SUITE 200


! ! oc I'.-.", j-.ji:

I If Y 9 i.: V". S 2014

City ALEXANDRIA i^uipose Of- Disbursement' MEDIA SERVICES

Candidate Name

State VA

Zip Codo 22304

Transaction ID: 2ai4M02L21Aaa080

Ollice. Sought:

State:


Sisidct:

DIsbufsemeni For ^ Primary Q] Qenerai Other (specify) v

Category/ type


ji 1250.00 j|

Full-Name (Last, First, Middle InltlaQ

B. BOREL ESTATE COMPANY Date of Disbursement

Mailing Address 1700 S. EL C/WilNO REAL

City SAN MATEO

State CA

Zip Code 94402

Purpose 01 Uisbursomenl RENT r-"i

Candid.ale N.qmo Category/ •Type

!; 01 i ! p3 ii , 20)4 li

Stats:

Senate President

SlTrict:

Transaction ID: 2014M02L2tAOOOB1


ii 6286.00 !;

Primary General Other (specify) y

Full Name (Last, RrsI, Middle IniUal)

C. BORGER MANAGEMENT INC

Maning Address HILL HOUSE 110 D STREET SE

Date of DIsbursomcnt

. 01 03 !! I 2014 i

City WASHINGTON Purpose 01 .Disbursement

REI4T

Slate DC

Zip Code 20003

Landidalo Name

Uflica Sought;

State: 5i?


riot:

Disbursement Fon Prlmsry General Other (specliy) Y

Category/ Typo

Transaction ID: 2014M02L21A00082

Amount of Each Oisbursemonl ihls Period t^sBi ^,.sU;V.U •nw.'.,'!/'... T

ji " " 2050.00 I

SUBTOTAL ol Disbursements This Page (optional)..

TOTAL This Period (last page Ihis line number only)..

.li 9588.00 i

PESANCas PEC Schedule B (Form 3X) Rev. 02/2003

5 9

Itnogc# 14960547938

SCHEDULE B (PEG Form 3X) ITEMIZED DISBURSEMENTS Use sepaiate schadule(s]

for each category of the Oetailed Summary Page


PAGE 1.409 OF 1743

5^ 21b 27

22 28B

23 280

24 28c

26 30t)

Any Intormatlon copied from such Reports and Statements- may not b'o sold or used by any person (or the purpose of soliciting conlflbullons or for commercial putpdsos, other than using Ihn name and address of any political committee to solicit contributions Irom such committee.



Full Name (test, First, Middle Initial)

A. BMD

Mailing Address INTELLEGENT OIRECT MARKETING 1420 KING STREET. SUITE 600

aty ALEXANDRIA

Stato VA

Zip Code: 22314

'Purpose-Of Disbursement MAIL PRODUCTION SERVICES

'Candidate Name

Ibllico Sought:

State:


Sistrlct:

Disbursement For; Primary

Category/ ' Type

I I General Other (specify) Y

Full Name (Last. First, Middle InlUal)

B- BORGER MANAGEMENT INC


^ 02 i " 26 ji 2014



a 10199.18 y

Mailing Address l to D STREET SE

City WASHINGTON Purpose 01 Disbursemont

RENT

Candidate' Namo

State DC

Zip Code 20003

OMIce Sought:.

State: pis

Houso Senate President

riot:

Disbursement For:. Primary

Category/ Type

Q General Other (specify) f

Full Name (Last, First, Middle InlUal)

C. BOREL ESTATE COMPANY

Mailing Address 1700 S. EL CAMINO REAL

City SAN MATEO Purpose, or Disbursemont REI4T

Candidate Name

State CA

Zip Code 94402

Ollice Sought:

Slate:


jiilrlct:

Category/ Typo

.Dlsburscrhent For; Primary Q General Other (specify) y


..,ai Transaction ID .: 2014MD3L21A00137


8 . .2050.00 i!

Data of Disbursemont

ml "•] I !;=v"TT">''=r-5T • I 03 h 1 2014



; ' 6286.00 -

SUBTOTAL of Disbursements This Page (opUonal)..


18535.18

I--. .r--<

rwaT.V.Ji.t'J

FE6AN026 FEC SehBdulo 8 (Form 3X) Rov. 02/2003

Imago# 14941116174


for each category of the Oetalled Summary Page


I PAGE 2570 OF 2949

r55l21b 27

22 2Ba

23 28b

24 28c

26 30b

Any Inlormallon copied from such Reports and Statements may not be sold or used by any person lor the purpose of solldllng contrlbutloiis or lor commercial purposes;'other than using' the name and address ol any political committee to solicit contributions Irom such committee. -

NAI4E OF COMMITTEE (In Full)

! REPUBLICAN NATIONAL COMMITTEE

Full Narho (Last,. Rrst, Middle Initial)

A- THE BOPP LAW FIRM

Mailing Address i SOUTH SIXTH STREET


irii-f-u v / ( 03 ! ;! 26 :l ? 2014 ^ ij

City TERRE HAUTE Purpose ot tiisbuisement TRAVEL EXPENSES

State IN

Zip Code 47807

corictidato Name

Olllce' Sought:

State;


XstricI;

Disbursement For; Primary Q General Other (specfly) y

Category/ TVPB

Transaction 10 ; 2014M04L21A00035


1 1394.85 ;i


B. BORGER MANAGEMENT INC Date ol Disbursement

Mailing Address 110 D STREET SE

City State Zip Code WASHINGTON DC 2G003 rfurposa ot Disbursement RENT • ; ' 1

4,, la BL

Candidate Name lA.U. .m mUMm Ir «J

Category/ type

Transaction ID: 2014Ma4L21AD0036

Amount ot .Each Disbursement this Period

State; 3fe

n • • • iS K-.I • 'V t ^ i

2050.00 .

Senate President

rict;

Primary General Other (spedly) y


C- BOREL ESTATE COMPANY



h-u-. -u-i 1 l^b'O-yji / E"v"'~v''i:\"'u~Y"r) I 03 : P 04 !i ° 2014 i fc» flt.'siTCn-s 1

city SAN MATEO Purpose- ol Disbursement RENT

candidate Name

State CA

Zip Code 94402

Ollii» Sought;

Slate; 5Is


net;

Disbursement For; Primary Other (specll

-i,-

i Category/

Typo

Transaction ID; 2014Ma4l21Aa0037


i 6286.00 !i

Ify) T General

SUBTOTAL ol Disbursements This Page (optional)


« 9730.85

FEC Schedule B (Form SX) Ren 02^003

i 5

S

Image# 14941280945

SCHEDULE B (PEG Form 3X) ITEMIZED DISBURSEMENTS Use separate scliedule(s)

for each cslcgory of iho Detailed Sumtnaty Page

FOR UNE NUMBER: (check only one)

PAGE 3271 OF 3636

[5?l21b 27

22 2Ba

23 2Bb

24 260

25 f—126 29 306

Any Information copied from such Reports and Statements may not be sold or used by any perst or for commercial purposos-, other than using the name and address of any political committee to

rn for the purpose of soliciting contrlbuUons solicit' contributions from such committee.



A. BMD

Mailing Address INTELLEGENT DIRECT MARKING 1420 KING STREET. SUITE 600

Clly ALEXANDRIA Purposo 01 DisDursomem

KIIAIL PRODUCTION SERVICES

Candidate Name

Slate VA

Zip Code 22314

pillco Sought:

Slate:


rilcl:

Disbursement For; Primary Q] General Other (specify) y

Category/ Type


B. BORGER MANAGEMENT INC

Mailing Address i 10 D STREET SE

City WASHINGTON Purposo Of OlsbuisemGnt

RENT

Candidate Name

State OC

Zip Code 20003

Ollice- Sought:

State: aTst


rict;

Dfsburseiiienl For: Primary General Other (specffy) y

Category/ Typo

Full Name (Last, First. Middle Initial)



City SAN MATEO

Stale OA

Zip Code 94402

Purpose of Disbursement RENT

Cendldalo Name ' Category/ Type

Ofllce Sought:

State: 5Ii

Senate President

/let:

Disbursement For: Primary Q General Other (specify} y


I 04 (L I 09 ; il ^014

Transaction ID: 2014M05L21A001B1


9 61086.36 it

Dato of Disbursement

••iTirYirJ / |j o :.JU L.BJ « -"I*



i 2050.00 I


LEJ! Transaction ID: 2014M05L21Aa0193


6266.00 :

SUBTOTAL of Disbursements This Page (optional) ^ 69422.36


FEGANOZS FEC Schcdufo B (Form SX) Rev. 02/2003

4 4 5

Image# 14961694536

SCHEDULE B (PEG Form 3X) ITEMIZED DISBURSEMENTS Use separata schedule(s)

for each category of the Detailed Summary Page


I PAGE 3376 OF 3764

rs?izib 27 260

23 28b

24

2BC

26 30b

Any Inlormatlon bdpled from such Reports and Statements may not be sold or used by any perst or for commercial purposes, olher than using'the name and address of-any pbilllcal committee to

>n for the purpose of soliciting contributions solldl contributions from such commlHee.



A. BORGER MANAGEMENT INC

Mailing Address no D STREET SE

City WASHINGTON Purpose oI'Disbureement RENT

Candidate Nemo-

State DC

Zip Code 20003

Ollico Sought:

State:

House-Senate President

SIstrtcl-:

Category/ Type

Disbursemettt For: Primary Q General Other (specify) y

Full Name (Last, Rrst, Middle Initial)

B. BOREL ESTATE COMPANY

Malllrig Address 1700 S. EL CAMINO REAL

City SAN MATEO

State CA

Zip Code 94402

Purpose of Disbursement REhft

Category/ Type


Olllce sought:

State;

Senate Prosldenc

Oisirlct:

Primary Q] General Olher (specify) Y

Full Name (Last, RrsI, Middle Inlllal)

C. BRING IT BACK PRODUCTIONS

Mailing Address .2275 WALNUT GROVE RD

City BOLIVAR

State TN

Zip Code 36008

Purpose ot'Ulsbursemani ENTERTAINMENT SERVICES

Candidate Name

Olllce Sought:

State:

Category/ Typo

Olaburaement For: ~ Primary General

Other (speclly) Y


I y'i'~ I 'i'i""'y'' \

.2014 . i :.i. '.si.-

il 05 ^ ! 01 il

Transaction ID : 2014M06 L2100001


i 2050.00 ij


l£j. fo'l'iD I PH

-=y^.rr-7ryr-

Transaction ID: 2014M06 L2100002

Amount el Each Disbursement this Period

I " 6286.00 ii


S-u-^"-"u

\ 0^ .?'

05 ^ .w.iw.ri

i"6-V'*o i! / 5«V*r~v-Kr*-01 !, ? 2014 .Jl.. t 'J Z. ..a.,-:


Amount of Each Disbursement this Period •(•sJtB'rwuKTui. .8

500.00 i

SUBTOTAU of Disbursements This Pege (opllone!)..

TOTAL This Period (last page this line number ortly)...

0836,00 H •• • .r-jr-r. s. . — h- .J • »e

j!

FECAN026 FEC Scliodulc B (Form 3X) Rev: 02A003

Image# 14941904581

1 6

9

SCHEDULE B (PEG Form 3X) ITEMIZED DISBURSEMENTS Use separate schedule(s]

for each categoiy of the Oelalled Summary Page


I PAGE 3650 OF 4106

21b 22 23 24 25

27 28a 2Bb 20o 20

26 30b

Any Inlo'rm'allon'copied from such Reports and Stotemonts may not bs sold or used by any perse 'or Iqr 'rn'mtfiercldl purposes, other than using the name and oddress of any political committee to

m lor the purpose cl solldling conlrlbullons solicit conlrlbullons from such commlltee.

V NAME OF COMMITTEE (In Full)



Mailing Address 110 0 STREET SE

City WASHINGTON

State OC

Zip Code 20003

Purpose 01 Dlsbursomenl RENT

lis-isiii-rir.-. Category/

Type

Csndidale Name lis-isiii-rir.-. Category/

Type rsoupf

stale;

Senate President

Blslrlct;

Primary Qeneral Other (specily) T

Full Name (Last, Hrst, Middle Initial)

B- BOREL ESTATE COMPANY


City SAN MATEO Purpose 01 oisbursemenl

RENT

Candidate' Namo

Slate CA

Zip Code 94402

Odiee Sought;

State;


rict;

Dlsburisomonl For; Primary

u.> .•ritc-.-Ai

Category/ Type

I I Qeneral Other (specify) T

Full Name (Last, First, Middle Inlllal]

C. BOZZUTO MANAGEMENT

Mailing Address 701 STREET SE

City WASHINGTON

State DC

Zip Code 20003

Purpose 01 Disbursement RENT


Olllce Sought:

Slate; 3IB

Senate President

ricl:

Primary [~~] General Other (speclty)"*T

Date 01 Disbursement

ii'iri'M /

t 06 H I 02 !! i _20U ^ H

Transaction ID ; 2014MD7 L21000D4


i! 2050.00 ' h


3=5, ij-b-'-.r#" i < r-v-^^rv^v

lJ£j IJij

TransacUon ID: 2014MO7 L2100006


6Z86:oo •: ...OL-,,'*


."iVrj'ti , , E-~vTv~-'Y."it i: r^t: H •;! m I! p 2014 i!



4180.08 l! .3r.:K5!*3fT-jf!r---Xr5rU.-s^

SUBTOTAL of Disbursements This Page (optional)


J • 12516.08 !

: -wrstiVaSsfiaar,-

FE6AN0Z6 FEC Sehedulo B (Form aX) Rev. 02^2003

Imsgefl 1497068SS85


tor oacli category ol the Detailed Summary Page

FOR LINE NUMBER: I.PAGE 5718 OF 6221

21b 22 23 24 25 27 2ea '28b 28c 29

26 30b

Any Inlormatlon. copied from such Reports and Statements may not bs sold or used by any porson lor tho purpose, of sollcliing contributions or lor commercial purposes, olhor than using the name and address ol any political •committoo to solicit contributions from such eommlltae.

) NAME OF COMMITTEE (In Full)



A- BORGER MANAGEMENT INC

Mailing Address 11 o O STREET SE


07 i ii 02 .? I; 2014 • > •.Mittu.rsA;."- -M.-T

City WASHINGTON Purpose 01 Oisburaoment RENT

State DC

Zip Code 20003

Candidate Name

Ollice Sought:

State:


rict:

Disbursement For: ^ Primary Q] General

Olher (specily) T

Catego^/ typo.



I ^ ' j; i


B- BOREL ESTATE COMPANY Date of Disbursement

Mailing Address 1700 S. EL CAMINO REAL fu'-.TS''; I ' rvTv^r.y'rr'vT

Clly SAN MATEO Purpose 01 Disbursement

RENT

State CA

Zip Code 94402


Candidate Name

OIIIco sought:

State:

House Disbursoment For Senate Q Primary Q] General President Olher (specily) y

K i

Category/ Type

Amount ol Each Olsbursoment this Period j;sr.srj.--:*v'

6286.00 !

Full Name (Last, First, Middle Inilial)

C- BOZZUTO MANAGEMENT

Mailing Address 701 STREET SE

City WASHINGTON

Stats DC

Zip Code 20003

Purpose ol Disbursement RENT

Category/ TVpe

Candidate. Name Category/ TVpe


07j J 2014

Office Sought:

Stale: 5i?

Senate President

ricl:

Oisbursemenl For:-Primary Q] Generai Other (specify) y

Transaction ID: 2014MG8L2100015


I 4193.29 I

SUBTOTAL ol Disbursements This Page (optional)

TOTAL This Period (last page this lino number only)..

i; 12529.29 |

i'-TKJ'J r T\r.rr JSI: .t,-;?.'.'.'::

FE6AN026 FEC Schedule B (Form 3X) Rev. 02/2003

Imagei) 14970B89861

k

SCHEDULE B (FEC Form 3X) ITEMIZED DISBURSEMENTS Use separate sch'edule(s)

(or each category of the Oetalled Summary Page

FOR UNE NUMBER; (check only one)

I PAGE 6969 OF 7442

5?l2ib 27

22 2ea

23 29b

24 28c

26 30b

Any Information copied from such Repotis and Statements may not be sold or used by any person for the purpose of solfcfting contributions or for commerclaf pijrposes, other than using the namo and address of oriy polillcal committee to solicit contributions from such commltteo.

\ l^iAME OF COMMITTEE (In Full)


Full N8rho (Ust, First, Middio Initial)

A- BAAN 0 YEEL KON CORPORATION


Chy FAIRBANKS Purpose of' tJisbursement RENT

Cendidalo Name

State AK

2ip Code 99707

bffico Sought:

Slate:


iiitrict:

Disbursemonf For: _ Primary Q General

Other (specify) >

!; -1.-.

Category/ Type


B- BORGER MANAGEMENTINC

Mailing Address 110 0 STREET SE

City WASHINGTON Purpose Of Disbursemcnl

I^EKIT

[;andidale Name

State DC

Zip Code 20003

Office Sought:

State:

•RoDie Senate President

•Is rlcl:

Disbursement For; Primary

Category/ Type

Other (specify] y) T General

FijII Name (Last, First, Middio Initial)



City SAN MATEO Purpose of Disbursement RENT

State CA

Zip Code-94402

Candidate Name

Office Sought:-

State: 3i?


rict:

nisbursement For: Primary

Category/ Type

I I General Other (specily) y


•i 08 I 01 2014

TranEeetion fD: 2014IMOgL2lOOD04

Amount of Each Disbursement this Period :..r. p.;,'J :i•

1: 745.25 ;i


Tr*V"9^,i

Transaction 10: 2D14M09L2100005


. 2050.00 I rgSte;:rb='£==J---',"V;-:&:=^.


!] 08 5 ij 01 I I 2014 j

Transaction ID; 2014M09L2100006

/Vrnount oi Each Disbursement this Period

!l 6286.00 jj

SUBTOTAL of Disbursemenls This Page (optional).. fr— ,•!

TOTAL This Period (last page this line number only) ^

908T.25 jl

FEaANOze FEC Schedulo B (Form 3X} Rov. 02/2003

Image* 14970889870


lor each caiegoiy ol the Oolalled Summary Page

FOR LINE NUMBER: I PAGE 6978 OF 7442

5 21b 22 23 24 25 27 28a 28b ' 28c 29 3Cb

Any. information' copied from such Reports and Statomcnts may not be sold or used by any perst or lor corhmbrclal purposes, other than using; the name and address of any political commttteo to

in for tha purpose of soliciting contributions solldt contributions from such committee.

\ NAME OF COMMITTEE (In Full) ) REPUBLICAN NATIONAL COMMITTEE

A- BOREL ESTATE COMPANY


SAN MATEO Ifurposo 01 ulsbursameni

RENT

Gandrddis Name

Slate OA

Zip Code 94402

blfice Soiiglil:.-

Slale;


})ilrlcl:

Disbursement For: Primary Q General Other (speclly) y

.» . • •JT.

Category/ lypB

Full Name (Ust, First, Middle Iniltal)

B. TIM BUTLER

Mailing Address 1678 SHAOY CREEK ROAD

City AYDEN Purpose'oi uisljursemont MANAGEMENT CONSULTING SERVICES

State NC

Zip Code 28513

.Condldpte Name

Olflce Sought:

State;


Slilrlcl:


I," ! L

Category/ Type

Q General Other (speclly) y

Full Name (Lest. First, Middle Initial)

C. TIM BUTLER

Mailing Address 1676 SHADY CREEK ROAD

City AYDEN Purpose 01 uisbursement TRAVEL EXPENSES

Oandidetc' Name

State NC

Zip.Code 28513

Oltlce Sought:

Slate: biF


rict:

i Category/

Typo Disbursemdm For:

Primary [ | General Other (speclfyT'Y


:• 08 i I- nrs '• " onia ? ...•J 06 ;•

Transaction iD: 2014M09L2100086

/Vncunt of Each Disbursement this Period

i| 188.58 I

Date of Disbursement.

TransacUon ID : 2014M09L2100087

Amount of Each Disbursement, this Period .. . . . ,

j 2500:00 I

Dele ot Disbursement

h 08 i S 08 ^ I- 2014 sV. S f»rs'sf.-4*rjfc i--—-js—



773J28 ? r

rt!. ."....i.r.::..:..i..~,..i:-.:_";.^'J.i!;f

SUBTOTAL ol Disbursements This Page (optional).. 3461.86 i

TOTAL This Period (last page this line number only)...

FESAN020 FEC Schedule B (Form 3X) Rev. 020003

1»19ra014 Schedules for Une#aiB

WILEY REIN LLP 1776 K. STREET N.W. WASHINGTON. DC 20006

09/10/2014 WILEY REIN LLP 1776 K. STREET N.W. WASHINGTON. DC 20006

LEGAL AND COMPLIANCE SERVICES 6007.80

WILEY REIN LLP 1776 K. STREET N.W. WASHINGTON. DC 20006

WSSC 14501 SWEITZERLANE LAUREL, Maryland 207075902

09/10/2014 WSSC 14501 SWEITZERLANE LAUREL, Maryland 207075902

UTILITIES 9.67 WSSC 14501 SWEITZERLANE LAUREL, Maryland 207075902

XEROX CORPORATION P 0 BOX 827598 PHILADELPHIA. Pennsylvania 19182

09/10/2014 XEROX CORPORATION P 0 BOX 827598 PHILADELPHIA. Pennsylvania 19182

EQUIPMENT RENTAL 10779.66 XEROX CORPORATION P 0 BOX 827598 PHILADELPHIA. Pennsylvania 19182

BRANCH BANKING & TRUST 1909 K STREET NW 2ND FLOOR WASHINGTON. DC 20006

09/11/2014 BRANCH BANKING & TRUST 1909 K STREET NW 2ND FLOOR WASHINGTON. DC 20006

MAIL PRODUCTION SERVICES 469500.00

BRANCH BANKING & TRUST 1909 K STREET NW 2ND FLOOR WASHINGTON. DC 20006

BOREL ESTATE COMPANY 1700 S. EL CAMINO REAL SAN MATEO, California 94402

09/11/2014 BOREL ESTATE COMPANY 1700 S. EL CAMINO REAL SAN MATEO, California 94402

RENT 6474.58 BOREL ESTATE COMPANY 1700 S. EL CAMINO REAL SAN MATEO, California 94402

COMMUNICATIONS CORPORATION OF AMERICA 13195 FREEDOM WAY BOSTON. Virginia 22713

09/11/2014 COMMUNICATIONS CORPORATION OF AMERICA 13195 FREEDOM WAY BOSTON. Virginia 22713

POSTAGE 76231.68

COMMUNICATIONS CORPORATION OF AMERICA 13195 FREEDOM WAY BOSTON. Virginia 22713

EXCLUSIVE CHARTER SERVICES INC 2221 SMITHTOWNAVE RONKONKOMA, New York 11779

09/11/2014 EXCLUSIVE CHARTER SERVICES INC 2221 SMITHTOWNAVE RONKONKOMA, New York 11779

TRANSPORTATION SERVICES

5490.00 EXCLUSIVE CHARTER SERVICES INC 2221 SMITHTOWNAVE RONKONKOMA, New York 11779

NGUYEN PROPERTIES LLC 3821 HIGH POINTED GREENSBORO, North Carolina 27407

09/11/2014 NGUYEN PROPERTIES LLC 3821 HIGH POINTED GREENSBORO, North Carolina 27407

VENUE RENTAL 700.00 NGUYEN PROPERTIES LLC 3821 HIGH POINTED GREENSBORO, North Carolina 27407

RHA MARKETING LLC 6910 CRESTWOOD BLVD FREDERICK, Maryland 21703

09/11/2014 RHA MARKETING LLC 6910 CRESTWOOD BLVD FREDERICK, Maryland 21703

POSTAGE 18432.64 RHA MARKETING LLC 6910 CRESTWOOD BLVD FREDERICK, Maryland 21703

ROYAL BANQUET HALL 3821-2B HIGH POINTED GREENSBORO, North Carolina 27407

09/11/2014 ROYAL BANQUET HALL 3821-2B HIGH POINTED GREENSBORO, North Carolina 27407

CATERING/FOOD AND BEVERAGE

1817.00 ROYAL BANQUET HALL 3821-2B HIGH POINTED GREENSBORO, North Carolina 27407

VIETNAM ENTERTAINMENT GROUP 09/11/2014

VIETNAM ENTERTAINMENT GROUP hllp-y/dacquery.fec.gcv/cgl-blnfdcdevfforms/C00003418n6303»sbf21B 11/48

4 2

Image# 14363180435

SCHEDULE B (FEC Form 3X) ITEMIZED DISBURSEMENTS Use separate schedule(s)

for each calegory of Ihia Oolalled Summary Page


[PAGE 7752 OF 8055

21b 22 23 24 25 27 2Sa 2eb 26c 29 30b

Any inlormalion copied from such Reports and Slatemanis may not be sold or used by any person for the purpose of soliciting contribulions or for commorclal purposes.--other than .uaifig-the name and address of ony .pglilical commiltee lo solicit contribulions from such cdmniiltee.



Fun NameTLasi, RrsI, Middle-Iniliol)


Mailing Address no b STREET SE

City WASHINGTON Purpose. 01 Ulsbursemcnl RENT

Candldaie Name

Stato DC

Zip Code 20003

Office Sought:

Slate: 5^

House Sonaie President

rtcl:

Disbursement Fon ""1 Primary Q General ~ Other (specify) Y

tff. yil

Calogdry/ Type

Full Name- (Last, First, Middle Inillal)

B. BOREL ESTATE COMPANY


City SAN MATEO.

State CA

Zip Code 04402

Purpose 01 utsbursernont RENT • !i

Category/ Type

Candidate Name. • !i

Category/ Type

State:

Senate President

tsliirlet:

Primary Q General Other (specify) Y

Full Name (Last, First, Middle Irililal)

c- BOZZUTO MANAGEMENT

Mailing Address 701 STREET SE"

City WASHINGTON Purpose of Disbursement RENT

State DC

Zip Code 20003

bandldata Name

bfllce Sought:

State: Di?


irict:

Dlsbursontanl For; Primary Q General Other (specify) Y

rni Category/

Typo


i! 10 i 11 01 j; i. 2014 J



i'j 2050.00 'j


/ irrv-V-a .• ilVu-V-Tf T-S-V" I io T ? 01 i R ,.2014 ' I,-. ;TL*:;-rr:


Amount Of Each Disbursement this Period

i' 6474.58


i Tl-rTu-;t / C' tf'-'.'o-E / i 10 3 ' 01 j

rvn'r'tv-v-r -! 2014

Transaction ID: 2D14Gi2L2100012


4162.88 I

SUBTOTAL Of Disbursements This Page (oplionel)..

TOTAL This Poriod (last page this line number only}..

: IT, !:=.=r!=":r.:z;:U

12887.46 i 7.-J.'. <—

FE0AN02e FEC Schedule B (Form 3X) Rev. 02/2003

I I 1

5

Imdge# 14953191524

SCHEDULE B (PEG Form 3X) ITEMIZED DISBURSEMENTS Use separata schedule(s)



I PA6E10667OF 11162

21b 22 23 24 25 27 28a 2Bb 28c 29 30b

Any information copied from such Reports and Slatemonls may not be sold or used by any pers or lor commercial purposos. other than using the name and address ol any poiiUcal committee tc

on for lha purpose ol soliciting contribulions 1 solicit contributions from such committee.



Full Narhe (Last, Rrsl. Middle Inlllal)

A. STATE OF ARKANSAS DEPARTMENT OF FINANCE AND ADMINISTRATION

Mailing Address 1509 WEST 7TH ST

City LITTLE ROCK Purpose 01 UlsDursomenI TAXES

Candldaie Naino.

State AR

Zip Code 72201

Olljco Sought:

State:

T?5use Senate President

District:

DisbursemOht For: Primary

-i'sL

Category/ Type

I I General Other (speclty) Y


B- BORGER MANAGEMENT INC

Mailing Address 110 D STREET SE

City WASHINGTON Purpose 01 uistjursement RENT

Candidate Name

State DC

Zip Code 20003

Olllce Sought:

State: 5is

TIBUii— Senate President

rid:

Disbursement For. Primary QJ General Other (speclly) •

lAv.rMi r.;;'

Category/ Type

Full Name (Last, First, Middio Initial)

C. BOREL ESTATE COMPANY


City SAN MATEO Purpose Of Oisbursemeni RENT

Candidate Name

Slate OA

Zip Code 94402

Olllce Sought:

State;


District:.

Olsbursetnanl For:' Primary

^ • Category/

Type

Q] General Other (speclly) Y


iL..iP ; 31 ;• !; .2014 . 1 .v..', :V.....X..

Transaction ID: 2014G30L21003g4

/bnount of Each Disbursement this Period

ii 491.08 ?


/ E'irv'vj: < 1 10 i ii 31 H 1; 2014 5

Transaction ID: 2014G3CL2100395

Amount of Each Disbursement this Period t|.-w ,T —r.'Sjts'fw'-C.iV-'j-.-u--J

ij 2075.00 I;


j! M••-i-M'•,! / y Ii 10 J i; 31 ; 2014 • •r-.'V-LT' I


Amount of Each Disbursement this Patiod

6474.58 5

SUBTOTAL ol Disbursements This Page (opilonal).. , 9040.66 'j tv.-.::-'.':! I!— i; .fJ-xT".-y y." • • V '•'v.—j-ai-:: . •-

TOTAL This Period (last page this line number only).. I!

FEC Sctiedute B (Form 3X) Rev. 02/2003

Republican National Committee Washington, DC 20003 … · RNC's voter daita collection ... for...

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