The American Democracy Legal Fund has filed a supplemental complaint with the FEC against numerous Republican political campaigns and state parties, in addition to Data Trust, the RNC, American Crossroads, Crossroads GPS, the Koch-funded Americans for Prosperity, and i360, alleging illegal coordination.

The new complaint targets more than two dozen campaigns and state parties, including McFadden for Senate, Steve Daines for Montana, Cotton for Senate, Tom Reed for Congress, Scott Rigell for Congress, McSally for Congress, the Arizona Republican Party, the Montana Republican State Central Committee, and the West Virginia Republican Party, Inc., in addition to the RNC, American Crossroads, Crossroads GPS, Americans for Prosperity, GOP Data Trust LLC, and i360 LLC.

ADLF's previous related complaint is available here, and the new complaint is available in full below and here. The American Democracy Legal Fund holds candidates for office accountable for possible ethics and/or legal violations. It was established by David Brock and is run by Brad Woodhouse.

BEFORE THE

FEDERAL ELECTION COMMISSION

 

American Democracy Legal Fund

455 Massachusetts Avenue, N.W.

Washington, DC 20001

Complainant,

v.

 

Republican National Committee

310 First Street, SE

Washington, DC 20003

 

American Crossroads

P.O. Box 34414

Washington, DC 20043

 

Crossroads GPS

P.O. Box 34413

Washington, DC 20043

 

Americans for Prosperity

2111 Wilson Blvd, Suite #350

Arlington, VA 22201

 

GOP Data Trust LLC

735 8th Street SE, Suite #200

Washington, DC 20003

 

i360, LLC

2300 Clarendon Blvd, Suite #800

Arlington, VA 22201

 

Arizona Republican Party

Timothy Lee, Treasurer

3501 North 24th Street

Phoenix, AZ 85016

 

Montana Republican State Central Committee

Debra Brown, Treasurer

PO Box 935

Helena, MT 59624

 

West Virginia Republican Party, Inc.

Michelle Wilshere, Treasurer

700 Washington Street - East Suite 201

Charleston, WV 25301

 

Andrew Walter

Andrew Walter for Congress

Chris Marston, Treasurer

PO Box 13321

Tempe, AZ 85284

 

Ben Sasse

Ben Sasse for US Senate Inc.

Mark Fahleson, Treasurer

105 East 6th Street

Fremont, NE 68025

 

Bob Goodlatte

Bob Goodlatte for Congress Committee

Kenneth Lorenz Prickitt, Treasurer

PO Box 292

Roanoke, VA 24002

 

Bobby Schilling

Bobby Schilling for Congress

Mitch Heckenkam, Treasurer

367 Avenue of the Cities - Suite D

East Moline, IL 61244

 

Carl DeMaio

Carl DeMaio for Congress

PO Box 27227

San Diego, CA 92198

 

Elizabeth Cheney

Cheney for Wyoming

Mark Vincent, Treasurer

961 Recluse Ct

Casper, WY 82609

 

Tom Cotton

Cotton for Senate

Bradley Crate, Treasurer

PO Box 379

Dardanelle, AR 72834

 

Doug Ose

Doug Ose for Congress

Vona Copp, Treasurer

9321 Silverbend Lake

Elk Grove, CA 95624

 

Elise Stefanik

Elise for Congress

James Morris, Treasurer

PO Box 338

Willsboro, NY 12996

 

Paul Dietzel

Friends of Dietzel

Brandon Lagarde, Treasurer

PO Box 286

Baton Rouge, LA 70821

 

Karen Handel

Handel for Senate Inc.

Roger Santi, Treasurer

3970 Old Milton Parkway

Alpharetta, GA 30005

 

William Hurd

Hurd for Congress

Bradley Crate

PO Box 656

Helotes, TX 78023

 

Steve Lonegan

Lonegan for Senate Inc.

Scott B. Mackenzie, Treasurer

38 East Ridgewood Ave - Suite 181

Ridgewood, NJ 07450

 

Lynn Jenkins

Lynn Jenkins for Congress, Inc.

Paul Kilgore, Treasurer

PO Box 727

Huntington, WV 25711

 

Matt Rosendale

Matt Rosendale for Montana

Bill Vancanagan, Treasurer

1954 Hwy. 16

Glendive, MT 59330

 

Mike McFadden

McFadden for Senate

Paul Kilgore, Treasurer

PO Box 4039

Saint Paul, MN 55104

 

Martha McSally

McSally for Congress

James Thomas III, Treasurer

PO Box 19128

Tucson, AZ 85731

 

Mike Turner

Mike Turner for Congress

Kyle Walton Denham, Treasurer

615 N. Hudson - Suite 320

Oklahoma City, OK 73102

 

Rob Wittman

Rob Wittman for Congress

Steve Ralls, Treasurer

PO Box 999

Montross, VA 22520

 

Matt Schultz

Schultz for Iowa

David Overholtzer, Treasurer

PO Box 3522

Urbandale, IA 50323

 

Scott Rigell

Scott Rigell for Congress

Joseph B. Wood, Jr., Treasurer

915 First Colonial Road - Suite 100

Virginia Beach, VA 23454

 

Steve Daines

Steve Daines for Montana

Lorna Kuney, Treasurer

PO Box 1598

Helena, MT 59624

 

Dan Sullivan

Sullivan for US Senate

Eric Campbell, Treasurer

3705 Arctic Blvd. #447

Anchorage, AK 99503

 

Tom Reed

Tom Reed for Congress

Marc Valerio, Treasurer

PO Box 10847

Rochester, NY 14610

 

Respondents.

 

 

SUPPLEMENTAL COMPLAINT

The American Democracy Legal Fund files this complaint with the Federal Election Commission (the "FEC" or "Commission") under 2 U.S.C. § 437g(a)(1) against the above named respondents (collectively "Respondents") for numerous violations of the Federal Election Campaign Act of 1971, as amended (the "Act").  This complaint supplements a previous complaint submitted to the Commission on October 14, 2014, regarding millions of dollars in illegal "coordinated communications" facilitated through the ongoing, real-time exchange of non-public strategic campaign and party data with groups making purportedly "independent" expenditures (the "Complaint").

As detailed in the Complaint, the RNC has created a for-profit entity, the Data Trust, charged with maintaining and sharing a vast database of information about hundreds of millions of Americans for Republican parties and campaigns.  The Data Trust not only operates the RNC's voter file, however, but also provides the same data to American Crossroads, Crossroads GPS, and numerous other outside organizations that are legally required to operate independently of the Republican Party and its candidates.  Moreover, the RNC and the Data Trust have recently partnered with i360, a data management firm that supplies voter information to other conservative organizations, including the Koch brothers' Americans for Prosperity ("AFP"), one of the largest outside organizations supporting the Republican Party.

The Data Trust and i360 have implemented technical upgrades that allow the RNC, Republican campaigns, and any outside groups subscribing to either the Data Trust's or i360's voter database to not only "access voter information anytime . . . but update it instantly, so others viewing the voter lists can see the information immediately."[1] According to the terms of Data Trust/i360  partnership,

Clients of either The Data Trust or i360 can improve the data shared with all clients.  For example, if a client of either company conducting voter outreach identifies a voter attribute or preference, clients of the other organization will benefit from that information.  As a result, conservative groups and campaigns will have more information about voters at their disposal for their own activities than ever before.[2]

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