October 14, 2020 Submitted via email and U.S.P.S. Federal Election Commission Office of Complaints Examination and Legal Administration Attn: Mary Beth deBeau, Paralegal 1050 First Street, NE Washington, D.C. 20463
[email protected] RE: Supplemental evidence for MUR 7147 Dear Ms. deBeau: On October 6, 2016, Campaign Legal Center (“CLC”) filed a complaint with the Commission alleging that the super PAC Make America Number 1 (ID: C00575373) had made illegal in-kind contributions to presidential candidate Donald Trump’s authorized campaign committee, Donald J. Trump for President, Inc. (ID: C00580100). The Commission designated the matter MUR 7147. CLC supplemented the complaint on December 2, 2016 and on April 12, 2017. We write to supplement the complaint with additional evidence in the form of newly published emails and other documents from the 2016 election. CLC’s original complaint alleged, among other things, that Make America Number 1 (also known as the “Defeat Crooked Hillary” super PAC) made unlawful and unreported expenditures in coordination with the Trump campaign by way of the common vendor Cambridge Analytica.1 The Trump campaign paid Cambridge Analytica $5.9 million in the 2016 cycle,2 and Make America Number 1 reported paying over $5 million to Cambridge Analytica after the super PAC began supporting Trump.3 Both Make America Number 1 and the Trump campaign contracted with Cambridge Analytica for similar services—such as developing the content of communications and targeting voters— and CLC’s original complaint alleged that Cambridge Analytica used or conveyed to Make America Number 1 information about the Trump campaign’s “plans, projects, activities or needs,” and that such information was “material to the creation, production, or distribution” of the super PAC’s ads supporting Trump or attacking his opponent, Hillary Clinton.