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Texas City, Texas 77590 Office of General Counsel Federal Texas City, Texas 77590 Office of General Counsel Federal Election Commission 999 E Street, N.W. Washington, D.C. 20463 RE: FEC Complaint enclosed To Whom It May COricerh: ^ Enclosed herein is a complaint I am filing with the Federal Election ^ Commission. If you have questions, you may reach me. at I Sincerely-, 8 4 2 Shawn C. Phillips c, o ro -n -n 2] nj 7—S O 0/V| rr. ofn . o CTP 1 '' VT) -rrii "'rn •J" .s .* ~ rn J:-" ms - ."b •rd _ CD r- CJl 'Dir. state of Texas § ^ County of Galveston § Affidavit of Shawn C. Phillips On this day, Shawn C. Phillips appeared before me, the undersigned notary public, and after 1 administered an oath to the said affiant, the affiant did swear and state as follows: 1. My name is Shavyn C. Phillips. I am over 18 years of age and am competent to make this affidavit. I have knowledge of the following facts, which are true and correct. Z. Attached hereto as Exhibit A are true and correct copies of mass marketing emails that were sent by an email service paid for by Heidi for Texas, Inc., a. 0 Texas specific puipose political committee with the sole designated, purpose ^ of electing Heidi Thiess to the Texas Legislature. Heidi for Texas, Inc. is not 4 registered with the Federal Election Commission. 3 8 3., Attached as Exhibit B are true and correct copies of mass marketing eniails 4 that were sent by an email service paid for by the Heidi Thiess campaign. The ^ Heidi Thiess campaign was a campaign to elect Ms. Thies.s to the Texas 4 Legislature in 2012. The Heidi Thiess campaign is not registered with the 5 Federal Election Commission. 4. The emails contained in Exhibit B contain references to and electronically piggybacked upori a website, www.heidifortexas.com. which according to campaign finance reports filed with the Texas Ethics Commission, was paid for by the specific purpose committee Heidi for Texas, Inc. Heidi for TexaSj Inc. is not registered with the Federal Election Commission. Campaign finance reports indicate further that the. campaigns purchased electronic advertising to drive additional traffic to the site. 5. Exhibit A and Exhibit B are political communications advocating on behalf of federal election candidates, including candidate for Texas Senate Ted Cruz, candidate for U.S. Congress Robert Gonzalez, candidate for U.S. Congress Felicia Harris, candidate for U.S. Congress Wes Riddle, and candidate for U.S. Congress Steve Stockman. 6. The Federal Election Commission defines regulated electronic communications to include emails of more than 500 substantially similar communications. Upon information and belief, the emails contained in Exhibit A and Exhibit B were distributed to more than 500 email addresses in substantially similar form and therefore were regulated communications. 7. As detailed in the Special Notices on Political Ads and Solicitations, published by the FEC in October 2006 and available via the FEC's website, "bulk electronic email (defined as electronic mail with more than 500 substantially similar communications)" must contain a disclosure.. Such disclosure, in the event the communication was not approved by the candidate being advertised, must state that they are "not authorized by any candidate or candidate's committee." The electronic communications attached as Exhibit A and Exhibit B contained no such disclaimers. 8., Further, upori information and belief, the total cost to maintain accounts with the mass email distribution services, maintain the website they were linked to, and purchase other electronic, advertising (including. Facebook ads) driving traffic to. those sites exceeded. $2.50. Such expenditures were used to promote the election, of candidates to federal office. Accordingly, Heidi Thiess and Heidi for Texas Campaign, Inc. should have filed FEC Form 5 with the Commission, reporting the contributions and expenditures from these campaigns, but no such reports were filed, apparently in violation of federal election law. Further affiant sayeth not.. Shawn C. P-hilllps. Subscribed and sworn to before me on the^^day of October, 201.2, by Shawn C. Phillips, in Galveston County, Texas. # i I 4 4 5 Subscribe Share Past Issues i Translate _L We're TRIGGERING THE VOTE at (he Arms Room on Saturday! Heidi is TRIGGERING the la LiKe on Facgijppk Vote on April 7th! b Follow on Twilter Forward to a Friend You are invited to stop by the Arms Room on Saturday, April 7th. from 9AM to 6PM. Heidi is undertaking a big push to register as many voters as possible. She believes that gun owners, especially, need to protect their rights by voting in every election. So Heidi is sponsoring a voter drive and combining it with an opportunity to meet the most Conservative candidates for office in our area. All of the following candidates have been proudly endorsed by the Clear Lake Tea Head Count Partyl Call to Action... HEIDI THIESS for Texas State Rep. HD-24 ROBERT GONZALEZ for U.S. Congress, CD-14 We are going lo start DANIEL MCCOOL for Texas State Senate, SD-11 measuring our support in RACHEL OELGADO for Texas State Rep, HD-23 real numbers. If you live in MARY HULS for Texas State Rep, HD-129 HD-24,1 need you to go to this link and indicate how you GEORGE YOUNG for 10th District Court wi!l vote in the primary. MICHELLE SLAUGHTER for 405th District Court Please pass on to others in JOHN BENfTLEY for Galveston County Republican the district. It will help me get Chairman a handle on the true metrics of the vote. I Join us at the Arms Room: t How many of you trust paid pciling? Not II Your help in ; 3270 Gulf Freeway South League City. TX: 77573 getting our numbers right not only saves money (since it u$2.eatnpalgn-archlvel.oamAi=30S345c36609da3d3023ta8758ild=95c7a6bad3&e=2bbfbcf695 And remember something He-di's opponents have doesn't cost a thing), but it's already figured out; far more accurate! And it improves sourstretegy immeasurably. And as a military woman, you know I'm all about the strategy! Please chip in a few seconds by following this link and letting us know how you plan to vote in the primary. NRA Political Victory Fund Rates Heidi an "A"! ELECT It [PMlLSJf By Heidi Thiess Yard Signs Are Now Available! I'd like to thank the National Rifle Association for their kind letter that I received giving me an "A" for my strong yard sign or road sign; We and uncorripromising stance for the Second Amendment need your help In getting as of our Constitution. The right to keep and bear arms is a many signs out to our supporters in the fundamental right and as your next State Representative, community as posslblel I will work to undo the fede-ally regulated mandates handed down to the State tiat infringes on this You can always pick up inalienable right as well as ensure that our rights here in signs at the Victory HQ: our beloved Texas remain in place. There is a massive push from the gun. control advocates to not only take our 2045 Space Park Blvd. Nassau Bay, TX arms away from us but to regulate our ammunition as well. I will stand toe-to-toe and defend our rights! Remember, I don't just talk.aboul the Second Amendment -1 LIVE IT! Take, a look at the full letter from the NRA here. us2.campaign-archlvel.coin/7u»30S345c366O9da3d30Z31aB7S8ud=95c7aebad38ie=2bbrbcr69S • • .V! f •?-.r - (Picture Above - Hetdi Thfess with. Gunnery Sergeant R.- Lee Ermeyat the SHOrS/iowil Message from Gunny Ermey: 4 By R. Lee "Gunny" Ermey from the NRA's Trlaaer the 4 Vote Camoaian Listen up and hear me well! This is a critical time for our 8 nation, and too many people are sitting back to let others 4 ; do the hard work. So it's time for ail of us to put .some gas in it and. persuade ai.i eiigitDle gun owners to register. That's why i volunteered my time to film the ad shown here.. Now it's your turn and I want to see results! Start now by sending this message to everyone you know who ; supports the Second Amendment, i expect 110% right now from everyone who values our freedoms!' NO EXCUSES-o And remember - pain is Just weakness teawng the body! i Get started- us2.eampaign-archivel.po.m/?u=305345c36609da3d30231a87SUd=96c7a6bad3gii:>2bbnKf69S i I follow on Twitter | friend on Facebook [ forward to.a friend 4 ConyrighJ<Q;20r2 H&ldi ForTexms, All. rights fesBryed. 4 8 •UhsubsGribe from this listi update subseFiptibn p'reiFerenceS . «.• Mm JB--I J us2.campaign-atdiivel,oom/?u.=30S345c36609da3d30231a87SMd=9S(:7a6bad3&e=2bbfbcf695 Whool Big weekend - see Insde for details you don't want to miss! nw nXAS STATE tqcnWeSeMTATIVe A OrSTPBOT 84] Our Fantastic Signs Are In! n Like on Facebook t; Follow pn Twitter THE BEST LOOWN' SIGNS IN ALL OF TEXAS - AND M Forward to a Friend THEY ARE YOURS FOR THE TAKINGI We know you would you like to show your support for Heidi. That's great! Help us spread the word for Heidi by placing her campaign sign in your yard. And get a Head Count few extras to share. Call to Action... We have two sizes available; We are going to start measuring our support in 24" X 24" for private real numbers. If you live in yards HD-24,1 need you to go to this link and indicate how you 4' X4' for road signs will vote in the primary. or business frontage Please pass on to others in the district.
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