The Lacuna Project

lacuna (n.) a gap in a record where something should be

Independent research. Not affiliated with any government, agency, or company.

Agency

Federal Election Commission

Findings that rest on exhibits naming this entity

  • POL-3.12: In the 2020 cycle WinRed reported $154.7 million in refunded individual contributions on $2.085 billion received, or 7.4 percent, and ActBlue reported $97.9 million refunded on $4.243 billion, or 2.3 percent.
  • POL-3.13: On 29 April 2021 the attorneys general of New York, Connecticut, Maryland and Minnesota wrote to WinRed about pre-checked recurring boxes, and on 6 May 2021 the FEC asked Congress to require affirmative consent for recurring contributions and to bar implied consent through pre-checked boxes. In 2023 the Eighth Circuit held in WinRed v. Ellison that federal election law did not block the Minnesota investigation.
  • POL-3.16: WinRed's published account states that ActBlue pioneered recurring and pre-checked boxes and that pre-checked boxes appeared on ActBlue pages for the Democratic Congressional Campaign Committee and the Democratic Senatorial Campaign Committee. One press account reports that ActBlue began phasing them out in July 2021.
  • INF-4.1: FBI, DHS and ODNI officials met regularly with platform staff about election content from 2017 and 2018, under the Trump administration, and the meetings continued through the 2022 midterms under the Biden administration.
  • INF-4.4: Twitter's chief executive told the Senate Judiciary Committee on 17 November 2020 that Twitter's 2018 hacked-materials policy was informed by conversations with the U.S. government. Twitter's head of Site Integrity stated in a declaration to the Federal Election Commission that Twitter's Trust and Safety leadership decided on 14 October 2020 to enforce the policy against the New York Post articles.
  • POL-5.1: In Citizens United (2010) the Supreme Court held, 5 to 4, that independent expenditures by corporations do not give rise to corruption or its appearance, and held, 8 to 1, that the disclaimer and disclosure requirements of the Bipartisan Campaign Reform Act are constitutional. In SpeechNow.org v. FEC (D.C. Circuit, en banc, 26 March 2010) the court held that contributions to groups making only independent expenditures cannot be limited and upheld the registration and reporting requirements for those groups.
  • POL-5.4: Independent expenditures reported to the FEC (support and oppose, derived from FEC bulk files) were $973 million in 2012, $683 million in 2014, $1,397 million in 2016, $1,041 million in 2018, $2,733 million in 2020, $1,750 million in 2022 and $4,029 million in 2024. Non-committee filers, the category in which an organization reports spending in its own name, reported $116 million (11.9 percent of the total) in 2012 and $67 million (1.7 percent) in 2024.
  • POL-5.5: Itemized contributions to super PACs and hybrid PACs from organizations whose names approximately match an IRS 501(c)(4) record (derived from FEC bulk files and the IRS exempt-organization master file) were $12 million in 2012, $13 million in 2014, $13 million in 2016, $91 million in 2018, $453 million in 2020, $126 million in 2022 and $969 million in 2024.
  • POL-5.6: Super PACs aligned with each party received itemized transfers from a paired 501(c)(4). In 2024 One Nation gave $36 million to Senate Leadership Fund and American Action Network gave $43 million to Congressional Leadership Fund; Majority Forward gave $82 million to Senate Majority PAC, House Majority Forward gave $47 million to House Majority PAC, and Future Forward USA Action gave $266 million to Future Forward PAC, 48 percent of that super PAC's receipts.
  • POL-5.10: The D.C. Circuit held on 21 August 2020 that 11 CFR 109.10(e)(1)(vi), which limited disclosure of donors to independent expenditures to donations earmarked for a specific expenditure, conflicts with the statute. In Van Hollen v. FEC the district court held 11 CFR 104.20(c)(9), a purpose-based limit on electioneering-communication donor disclosure, contrary to the statute in 2012 and 2014, and the D.C. Circuit reversed on 18 September 2012 and 21 January 2016 and upheld the regulation.
  • POL-5.11: The FEC ended enforcement matters against groups on both sides without finding violations. It split 3 to 3 in MUR 6396 and MUR 6696 (Crossroads GPS) and MUR 6589 (American Action Network); in MUR 7904 (Wyss, Berger Action Fund, Wyss Foundation, New Venture Fund and Sixteen Thirty Fund) it voted 6 to 0 to dismiss the political-committee allegations and split 3 to 3 and 2 to 4 on the foreign-national and name-of-another allegations.
  • POL-5.17: MAGA Inc.'s report for 1 to 30 April 2026 lists a $5,000,000 receipt from RAI Services Company dated 30 April 2026. Its itemized April receipts total $9,585,145.60, of which $585,145.60 is bank interest. The RAI Services receipt is 52.2 percent of the total.
  • POL-5.18: MAGA Inc.'s filings list $1,000,000 receipts from RAI Services Company on 5 February, 30 June and 29 December 2025, $1,000,000 from Altria Client Services on 9 May 2025 and $1,000,000 from JUUL Labs on 4 November 2025.
  • POL-5.19: MAHA PAC's reports list $500,000 from Botanic Tonics LLC dated 4 March 2026 and $500,000 dated 9 April 2026. Its reports through the pre-general report of 14 October 2026 list no later receipt from that name.

Exhibits naming this entity

  • Exhibit 732 accessed 9 November 2026. Federal Election Commission (OpenFEC API): OpenFEC committee totals, 2016-2024 cycles: WinRed, ActBlue, campaign and party committees
  • Exhibit 733 6 May 2021. Federal Election Commission: Legislative Recommendations of the Federal Election Commission 2021
  • Exhibit 734 7 February 2023. U.S. Court of Appeals for the Eighth Circuit: WinRed, Inc. v. Ellison, 59 F.4th 934 (8th Cir. 2023), No. 22-1238
  • Exhibit 735 26 January 2018. Federal Election Commission: MUR 7201 (Ted Cruz for Senate), Factual and Legal Analysis
  • Exhibit 893 as in force 2026. United States Congress: 52 U.S.C. ยง 30104 (reporting requirements), subsections (c) and (f)
  • Exhibit 894 21 January 2010. U.S. Supreme Court: Citizens United v. Federal Election Commission, 558 U.S. 310
  • Exhibit 896 26 March 2010. U.S. Court of Appeals for the D.C. Circuit: SpeechNow.org v. FEC, 599 F.3d 686 (D.C. Cir. en banc)
  • Exhibit 898 30 March 2012. U.S. District Court for D.C. (Judge Amy Berman Jackson): Van Hollen v. FEC, Civil Action 11-0766 (ABJ), Memorandum Opinion
  • Exhibit 899 1 February 2016. Federal Election Commission: FEC Record: Van Hollen v. FEC (Appeals court 2016)
  • Exhibit 900 3 August 2018. U.S. District Court for D.C. (Chief Judge Howell): CREW v. FEC (Crossroads GPS intervenor), No. 16-259 (BAH), Memorandum Opinion, 316 F.Supp.3d 349
  • Exhibit 901 21 August 2020. U.S. Court of Appeals for the D.C. Circuit: Citizens for Responsibility and Ethics in Washington v. FEC, No. 18-5261, 971 F.3d 340
  • Exhibit 902 certification 3 December 2013. Federal Election Commission: MUR 6396, Crossroads GPS
  • Exhibit 903 certifications 17 December 2015 and 28 August 2018. Federal Election Commission: MUR 6696, Crossroads GPS (complainant CREW)
  • Exhibit 904 statement of reasons 19 October 2016. Federal Election Commission: MUR 6589, American Action Network (complainant CREW)
  • Exhibit 905 20 March 2018 decision. Federal Election Commission: FEC Record: CREW v. FEC (16-2255 / 18-5136), American Action Network
  • Exhibit 906 certification 28 July 2022. Federal Election Commission: MUR 7904, Hansjorg Wyss et al. (complainant Americans for Public Trust)
  • Exhibit 918 run 10 November 2026. Lacuna derivation from FEC bulk files: Dataset: FEC independent expenditures 2012-2024 by committee type and benefiting party
  • Exhibit 919 run 10 November 2026. Lacuna derivation from FEC bulk files and IRS EO BMF: Dataset: FEC contributions by organizations to super PACs 2012-2024, matched to IRS EO BMF
  • Exhibit 1119 17 December 2020 (response letter of 21 December 2020). Twitter, Inc. (counsel Covington & Burling) to the Federal Election Commission: Declaration of Yoel Roth (Twitter Head of Site Integrity), 17 December 2020, Exhibit A to Twitter's response in FEC MUR 7821 / MUR 7827
  • Exhibit 1293 2025-07-31 to 2026-05-20. Federal Election Commission (electronic filings, docquery.fec.gov): MAGA Inc. (C00892471) Form 3X reports 2025 to April 2026: receipts from RAI Services Company, Altria Client Services and JUUL Labs
  • Exhibit 1294 2026-04-20 to 2026-06. Federal Election Commission (electronic filings, docquery.fec.gov): MAHA PAC (C00821439) Form 3X reports, March and April 2026: receipts from Botanic Tonics LLC