New FEC document released: what do they really think?
By krempasky Posted in FEC — Comments (23) / Email this page » / Leave a comment »
Update [2005-3-25 12:56:51 by krempasky]: - an important clarification - this post does NOT address the proposed rules voted on yesterday by the FEC (which signals the beginning of the public comment period. This post refers to a previously unreleased early draft of those rules - and they are horrible. It's educational to see where the FEC *started* in this process - but I repeat, these are NOT the rules released yesterday.
First let me say that I believe the Notice of Proposed Rulemaking governing activity on the internet released yesterday by the Federal Election Commission should provide little or no comfort to bloggers and online activists. As I was quoted in this CNet article, I believe it creates a “regulatory minefield” for bloggers.
Putting that aside for a moment, an earlier, previously unreleased FEC document raises VERY troubling questions about the manner and approach that the Commission (and the Commission’s staff) will take in fleshing out the final rules. CNet’s take on the earlier version is summed up here, with the headline, “Bloggers narrowly dodge federal crackdown.” Indeed.
To step back a moment, remember – on March 3rd, Commissioner Bradley Smith warned of some real potential problems with the upcoming rulemaking process. In return for ringing the alarm bell, he was dismissed as a crank, a partisan, an ideologue – and most of all, just plain wrong. The FEC would NEVER do something like regulate bloggers – heavens no! It’s inconceivable.
Well, I don’t think that word means what they think it means.
And now, we can prove that 1) Smith was right, and then some, 2) Had Smith not rung that bell, we may well have regretted it, 3) those on the FEC that criticized smith and told bloggers, in effect, to “chill out” weren’t being honest with us and 4) the FEC should be viewed with the highest suspicion throughout this regulatory process.
As late as yesterday, FEC Commissioner Ellen Weintraub said at the public hearing, “I am not aware of anyone here who views this rulemaking as a vehicle for shutting down the right on any individual to use his electronic soapboax to voice his political views.” From reading this, one has to wonder if Mrs. Weintraub even read the first draft of the rule, as provided by the FEC General Counsel’s office – on March 10th, 2005.
RedState has received a copy of that draft (.pdf only) – the Commission’s first attempt to craft a rule. And I can say – not only was Brad Smith right about the possible problems – the first draft was worse than he predicted.
Just how bad that draft rule was ought to serve as a filter for bloggers through which every statement by the FEC is screened. No media exemption. No volunteer exception. No clarification on coordination. Just a heap of anti-speech, anti-freedom regulations. Read on…
Remember, this rulemaking process is supposed to address what is, and what is not, a “public communication” and thus subject to the Bipartisan Campaign Reform Act. The rule released today, for all its faults – at least starts with the premise that the internet ought to be relatively free – and then imposes certain restrictions.
The FEC’s first draft, however, starts exactly backwards – with the presumption that the internet must be locked down tight, with only small outlets left open for some meager amount of private speech.
And we’re not forced to read very much into the 45-page rule till we find the principle guiding this bureaucratic effort to regulate the internet:
"Specifically, the definition of "public communication" in 11 CFR 100.26 would be amended to include certain Internet communications that are widely distributed or available to the general public. The proposed definition would specifically exclude Internet communications with a limited distribution, as well as communications on password-protected websites with restricted access, and internal communcations by corporations and labor organizations to their restricted classes and communications by membership organizations to their members." (Pg 7, line 7)
So, the original attempt to regulate started with the premise that everything was to be regulated except that with limited distribution or on password-protected sites. Now that’s pretty bold – but unfortunately, it’s only the beginning.
When discussing whether or not to require political disclaimers, the original draft read,
"However, websites and Internet communications by others [ed - not political committees] would need disclaimers only if they qualify as a "public communication," and either solicit contributions or contain express advocacy." (Pg 8, line 11)
Well – find me a political blog that wasn’t 1) open to the public and 2) expressly advocated for a candidate. I’ll show you a very poorly read blog.
Throughout the draft, you see a deep (and uninformed) suspicion about all the Terrible, Horrible, No Good, Very Bad things that might (and did, in the eyes of the authors) happen on the internet.
"In light of the Shays decision, the Commission is reconsidering which Internet communications would qualify as "public communication." The Commission recognizes that the growing role of the Internet in public political discourse, particularly its use by Federal candidates and campaign committees during the 2004 election cycle, may now justify a somewhat broader interpretation of "public communication" to include certain Internet communications that are widely-distributed or available to the general public that are the equivalent of advertising on broadcast, cabe, satellite, and in the print media." (Pg 10, line 5)
See? It’s so clear. Since federal candidates use the internet, this may justify a broader “interpretation…to include” (read: regulation) of communications that are publicly available.
Further, the FEC draft rule takes the position that the general exemption is bad – it should be removed, and replaced with very specific exceptions and protections with I think all will agree are meager at best.
"Accordingly, the Commission proposes to change the definition of "public communication" in 11 CFR 100.26 by removing the categorical exclusion for all Internet communications and by replacing it with carefully tailored exclusions for certain types of Internet communications that are distributed or made available to specific audiences that do not constitute the public at large." (Pg 14, line 17)
I wish I could say that was the end of the disaster which is this draft, but we’re only getting started. In attempting to rationalize a bizarre requirement that emails to more than 500 people ought to trigger some additional regulatory scheme, the authors stretch far out of cyberspace – to a phone bank, and use it as an excuse to regulate some more.
"Based on this Congressionally established threshold for two types of general public political advertising [ed - mass mailing and telephone banks], the Commission proposes to revise the definition of "public communication" in 11 CFR 100.26(a) to include any communication over the Internet by means of mail, text, or voice messages where the communication consists of more than 500 messages of an identical or substantively similar nature transmitted within any 30-day period." (Pg 16, line 3)
Mail, text, or voice messages? I’d say that would handily include 1) any set of daily digest emails from a Scoop-powered blog, 2) text? Seems to be anything, and 3) goodbye podcasting.
And if we haven’t been clear enough – the next two highlights are even more damning – because they get a whole lot closer and a whole lot more specific about the web.
"3. WebsitesThe proposed rules in new paragraph (a) of section 100.26 would establish a general rule that websites are a form of "public communication" because of their availability to the general public. 2 U.S.C. 431(22). However, proposed paragraph (b)(1) of this section would specifically exclude password-protected websites accessible by not more than 500 persons within any 30-day period. The limited availability of these websites distinguishes them from websites available to the general public." (Pg 18, line 19)
That’s their general operating principle in black and white. Available to the public? Bad, and must be regulated. Private, with no real impact – well, dear subjects, you’re free to do whatever you’d like in this little sandbox we’ve provided.
By the way, if password-protection wasn’t a high-enough standard for the FEC attorneys, they explain why they went even further,
"The limitation on accessiblity also distinguishes these websites from websites with unlimited access, but that require a user name and password for any person who registers with the site. These latter websites, including some online newspapers and other free or paid subscription services, are intended for the public generally and would be treated as a form of "public communication," just as Congress has treated more traditional subscription services, such as newspapers, magazines, and cable and satellite television, as a form of "public communication." (Pg 19, line 9)
Finally, just when you thought they couldn’t find any other way to crack down on bloggers (remember friends, we’re to “Chill out” because we have nothing to fear from the FEC), they prove you wrong.
”5. Internet advertisements and other forms of third-party contentThe proposed definition of "public communication" would also include any third-party content placed on another person's website, unless access to the third party content is password protected and available to only 500 or fewer viewers, or is a communication under 11 CFR 114.3 or 114.7(h) to the restricted class of a corporation or labor organization or to members of a membership organization. Such content could take the form, for example, of paid advertisements, such as banner advertisements or "pop-up" advertisements that appear on a website. Such content could also take the form of blogs that appear on a "host" site, whether or not a blogger pays a fee for the hosting service. Thus, under the proposed rule, a "public communication" would include both a publicly available website and any publicly available content on that website." (Pg 20, line 3)
I encourage you, read the draft rule yourself – but remember a few things:
- This draft was written by the professional staff at the FEC - not, to my knowledge with the direction of any FEC commissioner. To the contrary, word is that Commissioners Weintraub and Toner deserve much credit for dragging this rule back from the brink of certain disaster.
- At the same time – the FEC staff and general counsel are very, very important players in this process. Who drafts advisory opinions to clarify rules and answer questions? Who will play a major role in deciding who gets the media exemption in the current rules? (determined on a case-by-case basis, of course)
- However, for Commissioners Thomas and Weintraub to repeat over and over again that the FEC didn't have any intention or wouldn't be entertaining any odious rules seem misleading, if not dishonest - considering, for instance, that when Chairman Thomas gave this speech at the IPDI conference on March 12th, he had received this very draft the day before.
- Without the public outcry, what sort of rule would have been released yesterday? This heinous draft, mind you – is only two weeks old.
To everyone that either criticized Commissioner Smith as a partisan or questioned his character, I assume you’ll be lining up to apologize to him, thank him, or at least acknowledge that he was right. In fact, feel free to post those sentiments here at RedState, we’re happy to make sure he gets them.
And to everyone who looks at the rules currently under debate at the FEC, I strongly encourage you to keep a copy of this draft. Just refer to it everytime the Commission refers to “clarifying something later” or a “case by case basis.”
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New FEC document released: what do they really think? 23 Comments (0 topical, 23 editorial, 0 hidden) Post a comment »
It's admittedly a contrarian viewpoint here, but given that (1) corporations are already heavily restricted in what political activities they may be involved in and (2) offical Washington's distate for outsiders mucking up the political landscape, I think it is very unlikely the FEC can - or should - carve out exceptions for bloggers.
For anyone interested, this post has much more on the matter at this link
Bottom line: Who cares about these regs? Do what you want to do. Say what you want to say. Let them throw you in jail if they must.
In Washington, this fight is already lost. A minor tactical victory here and there can not mask the fact that we now have a Federal government, with the full endorsement of the SCOTUS, openly discussing the ins and outs of regulating political speech.
It is frightening to realize how often I have accepted from government officials the "chill out" "those criticizing xyz are partisan, hysterical, etc." "the parade of horribles about which they are talking never come to pass" argument. Well no more. Each time these dialogues have occurred on topic about which I know a good deal (or about which I have been able to read informed analysis like that above) I find out that I've been lied to or deliberately mislead or at the very least deprived of the whole story.
The more I watch, the more it seems to me that it is all about power and the right to rape and pillage and not at all about ideology or the constitution or the rule of law (for either party). I'm beginning to think that the people need to reassert some control over this government and find a way to disempower it somewhat. Gridlock is beginning to look good.
While I appreciate the notion of fairness - what you fundamentally miss is this: the entire premise of regulating campaigns is the belief that the means to communicate with large numbers of people is a scarce resource. And with scarcity comes crowding out. If I use my money advantage to buy all the ads, you get none.
Not so on the internet - your spending has no effect on my ability to communicate - and in fact, it's an infinite resource with no barriers to entry. So, even though Bad people can spend millions on the internet - it doesn't impede anyone else.
Additionally - there's a truth in this: bloggers are the antidote for all the perceived problems with big money politics.
The first draft of any regulation comes primarily from staff attorneys, who, however professionally minded, still believe in the intrinsic worth of their regulatory existence. It's human nature -- What I do has value, so if I do more of it, there is more value, so I am more important in the scheme of things.
With vague instructions from their political overseers, the commissioners, these staff lawyers will therefore tend to produce the most intrusive, complicated, regulatory draft possible. It's only when the political appointees enter into the process that reason is restored.
So, that first draft? Just chill out.
..........
Well, now, "chill out" admonition was not intended seriously. The bureaucratic dynamic I just outlined is real, but staff often wind up dominating -- not just starting -- the creation of regulations. Depends on what kind of leaders are at the head of any regulatory agency, and the FEC does not fill me with confidence on that score.
Anyway, while I would not exaggerate the importance of this draft, it certainly reveals the institutional leanings of the FEC bureaucracy, leanings that can indeed influence and direct the commissioners. Thanks to Krempasky for taking the lead on this issue. Bloggers have First Amendment rights, too.
Freedom is rarely lost all at once, but rather, is chipped away in barely-discernible increments. Thus when the government banned so-called "assault weapons", few complained because few people were personally affected. But now the precedent has been set for stronger action in the future.
So it is with FEC regulation of the Net. It matters not at all whether the intentions of the bureaucratic staffers drafting these regulations are good or bad, because if we the people allow any regulation of internet 'speech' the end result will be the same: eventually some party in government will begin to tighten the rules until bloggers are effectively out of business.
Many of you believe it can't happen--that we defeated this proposed regulation and will do the same with the next one that attempts the same thing. You're kidding yourselves.
Here are a few ways they'll come at you next time: Blogs will be free to say what they want, EXCEPT that 'hate speech' will be prohibited. Since no one thinks such a restriction will affect them, the reg passes. But then the definition is gradually expanded.
Or: You can link to whoever you want, BUT...the principle of non-discrimination demands that bloggers offer "essentially" the same number of links to left-wing and right-wing sites. Sound ridiculous? But the government now routinely requires employers to hire people they wouldn't otherwise have hired. As an owner of rental property I can be jailed if I refuse to rent my home to people I just don't want to have as tenants. Tell me there's a difference in the underlying principle.
--sf
I applaud Krempasky (and all the others) for shining a strong light on the FEC rule-making, and urge everyone leaving comments -- and everyone reading but not leaving comments -- to let the FEC know what you think. Don't sit this one out.
This traces back to fundamental constitutional rights, regardless of an erroneous judgement. The long-term goals should be the repeal of McCain-Feingold and putting a rein on judges who run amok. Until the long-term goals can be met, bloggers should take heart from the example of other dissidents, such as Vladimir Bukovsky:
We had grasped the great truth that it was not rifles, not tanks, and not atom bombs that created power, nor upon them that power rested. Power depended upon public obedience, upon a willingness to submit. Therefore each individual who refused to submit to force reduced that force.
Don't stop with the FEC. Write or email everyone you can think of, from your local paper's op-ed page to your Congressional reps to Senator McCain his own sorry self. If you have a blog of your own, write your ISP and insist that the ISP comment to the FEC.
McCain-Feingold delenda est. Pass it on.
MUR 4624 (Matter Under Review)
STATEMENT FOR THE RECORD COMMISSIONER BRADLEY A. SMITH
When a person decides to make independent political expenditures, he opens himself up to two potential burdens under the Act. The first burden is to report those independent expenditures in excess of $250.00. See 2 U.S.C. § 434(c). The second is to defend against allegations that the advocacy was somehow authorized by or coordinated with a candidate which, if true, would lead to still greater limits on the person's political activity. See 2 U.S.C. § 431(17). Respondents can spend substantial sums defending themselves against such allegations, and this possibility will cause many speakers to avoid engaging in what ought to be constitutionally protected speech.
Despite the fact that the Commission has now found no violations in this case, I strongly suspect that the original complainant, the Democratic National Committee, considers its complaint to have been a success. The complaint undoubtedly forced their political opponents to spend hundreds of thousands, if not millions of dollars in legal fees, and to devote countless hours of staff, candidate, and executive time to responding to discovery and handling legal matters. Despite our finding that their activities were not coordinated and so did not violate the Act, I strongly suspect that the huge costs imposed by the investigation will discourage similar participation by these and other groups in the future.[5]
We cannot fault the complainant DNC for pursuing its political goals through the legal tools made available to it, but nor can we on the Commission blind ourselves to the fact that the substantial majority of the complaints filed with the Commission are filed by political opponents of those they name as respondents. These complaints are usually filed as much to harass, annoy, chill, and dissuade their opponents from speaking as to vindicate any public interest in preventing "corruption or the appearance of corruption."[6] This knowledge makes it particularly important that we be sensitive to the possibility that our interpretations of the Act can, and sometimes do, chill what is and ought to be constitutionally protected political speech.
McCain-Feingold is unconstitutional. So are all limits on spending money to express your views.
Ah, wise man, while your point that the Internet not crowding out other voices is valid, I think it is you who is mistaken about the premise of regulating campaigns. Me thinks it is all about incumbents trying to ensure their re-election by ensuring a fair campaign (fair, of course, will be defined by the incumbents).
My point actually wasn't about fairness - it was that the FEC, given the restrictions placed on corporate involvement - would be hard pressed to carve an exception for the Internet/blogging. Combine that with the fact that incumbents (McCain) aren't fans of the wild, wild blogosphere, and the fact that the blogosphere is anything but a cohesive force, and there is an almost total lack of support for the blogging community on Capitol Hill.
perhaps there's a distinction between motivations and justification?
From my experiences with law professors regarding technology, Glenn Reynolds being one notable exception on the conservative side, and Lawrence Lessig being the other most notable one on the liberal side.
In my opinion many law professors are (or at least were as of two years ago) traditional technophobes who want to study this "new situation" as they see it, and then determine what laws and regulations apply to it, or need to be created to regulate it, and thereby make it something they comprehend from a rigorous statutory legal perspective, so that it can be codified in a treatise and they can teach classes about it.
Reynolds was also right on the mark because blogs are "power breakers" -- they make enforcing party discipline more difficult. The Internet has traditionally been a disruptive technology in this way.
I've had professors ask me questions, in all seriousness like: "haven't we created a monster with this internet thing?" and I've had a dean of a law school express to me her personal disdain for "people sitting around in front of computers all day long." Those are actual quotes.
Legal academia is a pretty conservative world (I mean that in the sense of its deliberateness) and when you start thinking about the implications for the internet in terms of being able to change the power balance and shift it away from centralized "authority" figures, it really does scare some of them. I think a lot of that mentality translates into the culture on Capitol Hill.
I was astonished, and encouraged, to see Gary Becker and Richard Posner start a blog (I think at the urging of Lessig.)
Maybe "scare" isn't the right term. But there is still a lot of skepticism and wariness, even moreso in 2005 because the Internet was, for the first time in the last election, much more than a blip on the radar in terms of activism and fundraising. It went from being something negligble to something capital-I Important in one election cycle, basically. For that reason alone we should be very concerned about these proposed rules.
And I can't wait to finish reading all of the proposed regs. in their final form...
If I run a website off a webserver in my house that serves a single page with a political message endorsing a federal candidate, let's just say the simplest of the simple "hello world" websites with a blank white page with the words:
VOTE FOR MELVIN KABOTNIK, HE'S AWESOME
at a URL like: melvinkabotnikforpresident.com, as long as he's a candidate...
...I have to lock it down and make sure that it's password-protected and only 500 people a month can see it? And the onus, I presume, would be on me to prove that only 500 people a month saw it? ...I suppose by building a timebomb counter into the webserver so that when it trips over 500 authenticated page views in a 30 day period it timestamps it and starts sending 500 FORBIDDEN error messages so that I can comply with the law? Wow, that's gonna be a lot of fun.
BTW, John Edwards is Podcasting right now (so is the GOP.) Boy, is he gonna be upset.
I couldn't have - and didn't - say it any better. Of course, in their minds, they are one and the same...
If it ever comes to the point where I find myself the object of this sort of investigation (and I have no reason to think that it will...I don't have a Messiah complex about this...I realize I'm small potatoes). I won't respond or participate in any way. I will not voluntarially go to any hearings, trials or other tribunals. If they force me to a tribunal at the point of a gun, I will offer no defense. If they find me guilty, so be it.
This whole attempt to exclude blogs is just dressing up a pig. This is a bad, unconstitutional law. Exemptions that selectively blunt the impact of it only hide that fact.
The thing that really needs to go is the "media exemption". It creates a special class of "journalists" that have free speech rights while the rest of us don't. I want to see the New York Times et al whacked with huge fines and criminal penalties for their undeclared, WAY over the legal limit, in-kind contributions every time they run an op-ed piece criticizing or praising a candidate. I want the nightly news hauled into court whenever a story ends up playing in one candidates favor over another.
McCain-Feingold looked great to them because they want to be a special class with rights others don't have and a monopoly on expressing their opinion and shaping the public debate. We'll see how long campaign finance "reform" would last if the MSM was subject to it's rules.
Reminds me of a movie, wherein a college student wrote a paper about how the internet could actually bring about a true democracy; I guess the powers that be saw it too.
The basis of argument from that article regarding regulated speech are incorrect.
For any of it to make sense, it requires the reader to accept the notion that corporate involvment in politics is regulated to the point that it doesn't exist... which is far from the truth.
corporations can't donate money or resources to political campaigns, they can't pressure employees or suppliers to contribute money or time to campaigns, corporations can't endorse candidates. Pretty much everything is off-limits
Are these monetary contributions somehow not direct involvement politics?
Microsoft
http://www.opensecrets.org/indivs/search.asp?NumOfThou=0&txtName=micros
oft&txtState=%28all+states%29&txtZip=&txtEmploy=&txtCand=&a
mp;txt2004=Y&txt2002=Y&txt2000=Y&Order=N
General Electric
http://www.opensecrets.org/indivs/search.asp?NumOfThou=0&txtName=genera
l+electric&txtState=%28all+states%29&txtZip=&txtEmploy=&txt
Cand=&txt2004=Y&txt2002=Y&txt2000=Y&Order=N
Chevron
http://www.opensecrets.org/indivs/search.asp?NumOfThou=0&txtName=chevro
n&txtState=%28all+states%29&txtZip=&txtEmploy=&txtCand=&
;txt2004=Y&txt2002=Y&txt2000=Y&Order=N
Billions of dollars are pumped into our political system by corporations... and this doesn't count the billions more they spend to have lobbyists try to influence politicians.
The scheme you refer to is the EARLY draft of the FEC rules, not the version currently under consideration.
Excerpt from Mitch McConnell's July 8, 1998 letter to a constituent:
Section 431(9)(B)(i) makes a distinction where there is no real difference: the media is extremely powerful by any measure, a "special interest" by any definition, and heavily engaged in the "issue advocacy" and "independent expenditure" realms of political persuasion that most editorial boards find so objectionable when anyone other than a media outlet engages in it. To illustrate the absurdity of this special exemption the media enjoys, I frequently cite as an example the fact that if the RNC bought NBC from GE the FEC would regulate the evening news and, under the McCain-Feingold "reform" bill, Tom Brokaw could not mention a candidate 60 days before an election. This is patently absurd.
Had the Senate debate on the McCain-Feingold bill advanced to the point of amendments, among the first I offered would have been one to delete section 431(9)(B)(i). Whenever the opportunity presents itself in the future, I look forward to doing just that. I believe it would be an enlightening discussion. Indeed, the issue was frequently raised during the floor debates in 1997 and 1998 and helped to crystallize for Senators and the C-SPAN viewing audience that the campaign finance debate is, indeed, a discussion of core constitutional freedom."
There is ample survey evidence that the American people are quite amenable to restrictions on the media. I am fond of citing these surveys to reporters as their newspapers eagerly note polls showing support for restrictions on everyone else's ability to participate in our democracy. A Rasmussen Research survey found that 80 percent of those polled would like to restrict the way newspapers cover political campaigns. 68 percent believe that newspaper editorials are more important than a $1000 contribution. 61 percent believe that a candidate favored by reporters will beat a candidate who raises more money. 42 percent believe that newspapers should be required to install a equal number of Republicans and Democrats on their editorial boards. A study by the American Society of Newspaper Editors found that a majority would require journalist to obtain a license to practice, as lawyers and doctors currently must. A majority would empower judges to impose fines for "inaccurate and biased reporting" and would establish government entities to compel the media to equalize coverage of controversial issues. Fortunately, the First Amendment precludes such regulation, but the presence of such and anti-media sentiment should be of some concern to the press. After all, it was only last year that the Senate defeated (incredibly, 38 Senators voted for it) a constitutional amendment to empower the federal and state governments to restrict all expenditures "by, in support of, or in opposition to" candidates. As the American Civil Liberties Union pointed out, that broad mandate encompasses the media.
I would urge you to watch the ongoing House campaign finance reform debate carefully. It has been a stop-and-go debate with a day or two of campaign finance amendments interrupted by as much as a week of other legislative business. However, there will be several days of debate in the next month and it is anticipated that there will be at least one vote on an amendment to delete the media exemption in FECA altogether. It promises to be a vigorous discussion. An amendment to refine the exemption to address the matter of foreign ownership would be a useful exercise, as well. With the increased interest on our side of the aisle with the media component in the campaign finance debate, I would not be surprised if such an amendment were offered.
The entire letter is displayed at: http://amendment10.tripod.com/mitch4.htm.
Read the complaint the FEC brought against Zack Exley and his response:
http://eqs.sdrdc.com/eqsdocs/00002399.pdf Complaint Against Zack Exley
http://eqs.sdrdc.com/eqsdocs/0000239B.pdf Notification of Complaint to Zack Exley
http://eqs.sdrdc.com/eqsdocs/0000239D.pdf Grant of Extension of Time to Zack Exley
http://eqs.sdrdc.com/eqsdocs/0000239E.pdf Response from Zack Exley
http://eqs.sdrdc.com/eqsdocs/0000239F.pdf General Counsel's Report
http://eqs.sdrdc.com/eqsdocs/000023A2.pdf Notification to Zack Exley
and when is the FEC going to come after my yardsigns as "public communications."
This turns the First Amendment on its head. The Federalist papers would never have been allowed under McCain-Feingolds Frankenstein monster-law.