MUR #8071

RESPONDENTS: NRSC; Davis, Keith A.

COMPLAINANTS: Campaign Legal Center; Muller, Tiffany; End Citizens United; Ghosh, Saurav

SUBJECT: Contributions-Limitations; Soft Money

DISPOSITION: The Commission decided by a vote of 6-0 to take the following actions in MUR 8071:1. Close the file effective 30 days after 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).2. Send the appropriate letters.
The Commission failed by a vote of 3-3 to:Dismiss the complaint.
The Commission decided by a vote of 4-1 to:Find no reason to believe that the NRSC and Keith Davis in his official capacity as treasurer violated 52 U.S.C. § 30116(f) and 52 U.S.C. § 30125(a)(1) by disbursing funds from its legal proceedings account under 52 U.S.C. § 30116(a)(9)(C) to American Rising, LLC for “research”.
The Commission failed by a vote of 3-1 to:a. Find no reason to believe that the NRSC and Keith Davis in his official capacity as treasurer violated 52 U.S.C. § 30116(f) and 52 U.S.C. § 30125(a)(1) by disbursing funds from its legal proceedings account under 52 U.S.C. § 30116(a)(9)(C) to America Rising, LLC for “research”.b. Direct the Office of General Counsel to draft an appropriate Factual and Legal Analysis and to circulate it for Commission approval.
The Commission failed by a vote of 1-4 to:a. Find reason to believe that the NRSC and Keith Davis in his official capacity as treasurer violated 52 U.S.C. § 30116(f) and 52 U.S.C. § 30125(a)(1) by disbursing funds from its legal proceedings account under 52 U.S.C. § 30116(a)(9)(C) to OnMessage Inc., SRCP Media Inc., and The O’Donnell Group for “media placement,” “media production,” and “media,” to America Rising, LLC for “research”, and TAG LLC for “digital consulting.”b. Find no reason to believe that the NRSC and Keith Davis in his official capacity as treasurer violated 52 U.S.C. § 30116(f) and 52 U.S.C. § 30125(a)(1) by disbursing funds from its legal proceedings account under 52 U.S.C. § 30116(a)(9)(C) to Simio Cloud for “direct mail production.”c. Authorize the use of compulsory process.d. Approve the relevant sections of the Factual and Legal Analysis, as recommended in the First General Counsel’s Report dated October 26, 2023.e. Direct the Office of General Counsel to amend the Factual and Legal Analysis to substantiate the Reason to Believe finding for TAG LLC.f. Approve the appropriate letters.
The Commission failed by a vote of 3-2 to:a. Find reason to believe that the NRSC and Keith Davis in his official capacity as treasurer violated 52 U.S.C. § 30116(f) and 52 U.S.C. § 30125(a)(1) by disbursing funds from its legal proceedings account under 52 U.S.C. § 30116(a)(9)(C) to OnMessage Inc., SRCP Media Inc., and The O’Donnell Group for “media placement,” “media production,” and “media.”b. Authorize the use of compulsory process.c. Approve the relevant portions of the Factual and Legal Analysis, as recommended in the First General Counsel’s Report dated October 26, 2023.d. Approve the appropriate letters.
The Commission failed by a vote of 1-3 to:a. Dismiss allegations that the NRSC and Keith Davis in his official capacity as treasurer violated 52 U.S.C. § 30116(f) and 52 U.S.C. § 30125(a)(1) by disbursing funds from its legal proceedings account under 52 U.S.C. § 30116(a)(9)(C) to OnMessage Inc., SRCP Media Inc., and The O’Donnell Group for “media placement,” “media production,” and “media”.b. Close the file.c. Issue the appropriate letters.
The Commission decided by a vote of 5-0 to:a. Find no reason to believe that the NRSC and Keith Davis in his official capacity as treasurer violated 52 U.S.C. § 30116(f) and 52 U.S.C. § 30125(a)(1) by disbursing funds from its legal proceedings account under 52 U.S.C. § 30116(a)(9)(C) to Simio Cloud for “direct mail production.”b. Approve the corresponding sections of the Factual and Legal Analysis, as recommended in the First General Counsel’s Report dated October 26, 2023.
The Commission decided by a vote of 4-1 to:a. Find no reason to believe that the NRSC and Keith Davis in his official capacity as treasurer violated 52 U.S.C. § 30116(f) and 52 U.S.C. § 30125(a)(1) by disbursing funds from its legal proceedings account under 52 U.S.C. § 30116(a)(9)(C) to TAG LLC for “digital consulting.”b. Approve associated sections of the Factual and Legal Analysis for TAG LLC, as recommended in the First General Counsel’s Report dated October 26, 2023.