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Posted on May 12 2018

Cambridge Analytica meet

Campaign Legal Center


Before I jump to the just filed Campaign Legal Center (CLC) Complaint, here are a few reminders of how we got here and how many tenticals this Cambridge Analytica octopus has:


See mini twitter thread 👀👇🏻👀 

When Facebook announced it had “banned” Cambridge Analytica from its platform. I still content that was Facebook’s attempt to mitigate their own liabilty and in a weird way control the narrative. I believe as of today’s Wall Street, closing bell Facebook has lost >$96 billion or roughly 20% of the value pre Cambridge Analytica.


That said none of us should be surprised that the CLC filed this complaint with the Federal Elections Commission (FEC). I also think many of us are NOT aware that the current CLC President, Trevor Potter was the former FEC Chairman, CLC Trevor Potter biography


To say Mr. Potter brings a lot of knowledge & veritas about our County’s current campaign laws, that just might be an understatement. And yes, I will totally admit I squealed just a tiny bit when this CLC Complaint landed in my email inbox.


Page 1, Paragraph 2

Senator Thom Tillis has a lot of explaining to do. As I previously discussed Sen Tillis was an early adopter of Cambridge Analytica “micro-targeting” and Cambridge Analytica & apparently their contractor Tim Glister were fairly braggadocious on their respective websites. Both of these entities touted their “psychographics” and targeted messaging. Further, it’s fairly well documented that Sen Tillis and John Bolton appear to be the main financial beneficiaries of the Mercer largesse.




Page 2, Paragraph 5 & 6:

What’s that sound I hear?

Could it be Senator Tillis running away from reporters or speed dialing Saul…which also makes the Sen Tillis’ joint statement with Sen Coons concerning Special Counsel Mueller, odd. I can’t help but wonder why would Sen Tillis issue a statement? As in what are his actual motives.




Page 3, Paragraphs 7-9 & Page 4 paragraph 10-12

I wish I had something witty or snarky to say. When you read this complaint as a whole, there’s a profound sense of what the bleeping bleep is this. How could this have happened and why didn’t the FEC or  non-Cambridge non-Bannon non-Mercer funded members of Congress catch this soooner? Yet here we are almost 16 months into this American Horror Story Political fubar.


Can we all agree that Becky with the shittyhair and her father are a large part of what’s wrong with our politics? If you add the Koch Brothers and Sheldon into the mix, these 3 families have poured hundreds of millions of dollars in to backing some really offensive candidates.

The fact that SCL & Cambridge Analytica essentially stole 50M Facebook users data and then aggregated that data into targeted poltocal ads and messaging. To me this is actually on par with Trump and his level of offensiveness.



Page 5 paragraph 13:

Last week when I pulled down the FEC reports and started reviewing each page, I was in fact struck at how much money the Mercers funneled to Cambridge and washed through Make America Number 1 PAC.


You can read the entire Campaign Legal Center’s March 2018 Complaint, here 

The Bracewell Giuliani 2014 Legal Memo

When the law firm you HIRED writes you a 10 page legal memo that specifically addresses the use of Foreign Nationals, Foreign Entities...said Attorney actually BOLDS the statutes of “greater concern” you are all in serious legal jeopardy. No really Becky with  the shittyhair, Steve “slovenly” Bannon, Becky’s daddy all of you are entirely SCREWED...


“We must start by reviewing the applicable law and regulations, which prohibits contributions, donations, expenditures, independent expenditures, and disbursements by foreign nationals, 2 USC. 4411 3, 36 USC 510. As detailed in the Federal Elections Commission (“FEC”) Regulations at, 11 CFR §110.20 (b), “A foreign national shall not, directly or indirectly, make a contribution or a donation of money or other thing of value, or expressly or impliedly promise to make a contribution or a donation, in connection with any Federal, State, or local election.”

‘Of greater concern is 11 CFR §110.20 (i)Participation by foreign nationals in decisions involving election-related activities. A foreign national shall not direct, dictate, control, or directly or indirectly participate in the decision- making process of any person, such as a corporation, labor organization, political committee, or political organization with regard to such person’s Federal or non- Federal election-related activities, such as decisions concerning the making of contributions, donation, expenditures, or disbursements in connection with elections for any Federal, State, or local office or decisions concerning the administration of a political committee. (emphasis added)”


 Oh Becky your attorney gave you multiple case law examples and a plethora of statues that supported his 10 page Legal memo to you and your “shell” companies that appear to have laundered campaign funds and entered into candidates coffers. Come on..this isn’t rocket science you and your ilk:


He even noted you’d be criminally prosecuted 

In Bluman v FEC 800 F. Supp 2d, 281,288 (D.D.C 2011), the court noted, “We read these cases to set forth a straightforward principle: It is fundamental to the definition of our national political community that foreign citizens do not have a constitutional right to participate in, and thus may be excluded from, activities of democratic self-government. It follows, therefore, that the United States has a compelling interest for purposes of First Amendment analysis in limiting the participation of foreign citizens in activities of American democratic self-government, and in thereby preventing foreign influence over the U.S. political process”(emphasis added). In 2012 the U.S. Supreme Court upheld the Bluman decision without further analysis. As an aside, I’ve read through the briefs and decisions in Bluman, both are almost entirely devoted to donations and expenditures of funds by foreign nationals, and only mention in passing campaign work by such individuals. The key connector appears to be the ability of campaign decision makers to expend federal dollars by making decisions about how to create and promote a campaign’s message. Moreover, the §110.20 (i) was expressly challenged and upheld by the Court.


In addition, violations of the aforementioned provisions are subject to criminal prosecution, punishable by fines and imprisonment, in addition to administrative action by the Federal Election Commission. As such, the Department of Justice has jurisdiction to engage in discovery of documents and emails, to question witnesses, and otherwise use all the tools at its disposal to investigate and prosecute alleged violations.‘


You can read the Bracewell Giuliani 10 page Legal Opinion written by Lawrence Levy* to Cambridge Analytica, Rebekah Mercer, Robert Mercer, Steve Bannon, and Alexander Nix via this link, here.

*and as if things couldn’t get anymore insane, Lawrence Levy is currently (operative word) with Greenberg Traurig. Notice how there’s zero mention of his time with Bracewell Giuliani? Link to his bio here

* also take a random guess who is “taking the lead” in defending Cambridge really take a guess? Here I’ll give you two hints, 1)rhymes with ex-strategic partnership with Michael D Cohen and 2) Brooks minus Dunn.

Cambridge Analytica represented by:

‘Gibson Dunn and Squire Patton Boggs Take Lead Roles Advising on Cambridge Analytica Facebook Scandal...”

Link to article, here


On a related note, here are the FEC aggregate reciepts for Makd America Number 1 (MAN1) PAC. At some point I have to assume watchdog groups like CLC and/or Crew will file a FEC complaint. Given how much money flowed to and out of MAN1 accounts. And the vast majority of those funds originated from Mercer and flowed back to companies owned by Mercer and/or Bannon. Wash. Rinse. Repeat As previously discussed this PAC  and the tactics they use = super questionable.

  • Rudy’s former law firm Bracewell Giuliani paid >$300K
  • Breitbart Paid >$100K
  • Glittering Steele, LLC (also owned by Bannon)


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