MUR #8002

RESPONDENTS: Tread Standard LLC; 34N22, Inc.; Gantt, Charles; Kilgore, Paul; Miller, Stuart; South Florida Residents First

COMPLAINANTS: Campaign Legal Center (1); Wieand, Roger G.

SUBJECT: Contributions-Prohibited; Contributions-In the name of another; Reporting

DISPOSITION: The Commission decided by a vote of 4-0 to take the following actions in MUR 8002:1. Accept the conciliation agreement with Tread Standard, LLC, as recommended in the Memorandum to the Commission dated February 19, 2025.2. Accept the conciliation agreement with South Florida Residents First and Paul Kilgore in his official capacity as treasurer, as recommended in the Memorandum to the Commission dated February 19, 2025.3. Take no further action with respect to 34N22, Inc., and Charles Gantt in his official capacity as treasurer.4. Approve the appropriate letters.5. Close the file effective 30 days from the date the certification of this vote is signed (or on the next business day after the 30th day, if the 30th day falls on a weekend or holiday).
The Commission decided by a vote of 5-1 to:Approve the Factual and Legal Analyses, as recommended in the Memorandum to the Commission dated March 13, 2024, as circulated by Vice Chairman Trainor’s Office on October 7, 2024 at 2:30 p.m. for: a. 34N22, Inc. and Charles Gantt in his official capacity as treasurer, b. South Florida Residents First and Paul Kilgore in his official capacity as treasurer, and c. Tread Standard, LLC.
The Commission decided by a vote of 4-1 to:Approve the Conciliation Agreements, as recommended in the Memorandum to the Commission dated March 13, 2024, as circulated by Vice Chairman Trainor’s Office on October 7, 2024 at 2:30 p.m. for: a. 34N22, Inc. and Charles Gantt in his official capacity as treasurer, b. South Florida Residents First and Paul Kilgore in his official capacity as treasurer, and c. Tread Standard, LLC.
The Commission decided by a vote of 5-1 to authorize conciliation with South Florida Residents First and Paul Kilgore in his official capacity as treasurer, prior to a finding of probable cause to believe, as recommended in the Memorandum from Commissioner Allen J. Dickerson dated March 6, 2024.
The Commission decided by a vote of 4-1 to:a. Find reason to believe that Tread Standard, LLC, violated 11 C.F.R. § 110.1(g)(5) by failing to provide attribution information.b. Direct the Office of General Counsel to draft an appropriate Factual & Legal Analysis reflecting that finding and circulate for Commission approval within fourteen (14) days.c. Authorize conciliation with Tread Standard, LLC, 34N22, Inc. and Charles Gantt in his official capacity as treasurer prior to a finding of probable cause to believe.d. Direct the Office of General Counsel to draft, and circulate for Commission approval within fourteen (14) days, appropriate Conciliation Agreements ...REDACTED...e. Approve the appropriate letters.
The Commission failed by a vote of 2-3 to:a. Find reason to believe that Tread Standard, LLC, violated 52 U.S.C. § 30122 by allowing its name to be used to make contributions in the name of another and that Stuart Miller violated 52 U.S.C. § 30122 by making contributions in the name of another.b. Take no action at this time with respect to the allegations that 34N22, Inc., and Charles Gantt in his official capacity as treasurer and South Florida Residents First and Paul Kilgore in his official capacity as treasurer violated 52 U.S.C. § 30122 by knowingly accepting contributions in the name of another.c. Enter into pre-probable cause conciliation with Tread Standard, LLC, and Stuart Miller.
The Commission decided by a vote of 5-1 to:a. Find reason to believe that 34N22, Inc., and Charles Gantt in his official capacity as treasurer violated 52 U.S.C. § 30104(b) and 11 C.F.R. § 110.1(g)(4) by failing to report attribution information.b. Find reason to believe that South Florida Residents First and Paul Kilgore in his official capacity as treasurer violated 52 U.S.C. § 30104(b) and 11 C.F.R. §110.1(g)(4) by failing to report attribution information.c. Direct the Office of General Counsel to draft appropriate Factual & Legal Analyses reflecting the foregoing and circulate for Commission approval within fourteen (14) days.