[EL] Deep Sea Not Deep News

[dmason12 at gmail.com]

This is my point: the organizer appears to be confused, he checked the boxes indicating that the committee is an SSF.
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-----Original Message-----
From: Steve Kolbert <steve.kolbert at gmail.com>
Date: Mon, 17 Oct 2011 16:24:27 
To: <dmason12 at gmail.com>
Cc: law-election at uci.edu<law-election at uci.edu>; Rick Hasen<rhasen at law.uci.edu>
Subject: Re: [EL] Deep Sea Not Deep News

Seems I made a critical typo! I meant that a *corporate SuperPAC* -- rather
than a corporate SSF -- might not have to comply with the usual solicitation
restrictions in light of the Club for Growth AO.

Deep Sea Burial seems to be forming a SuperPAC here -- not an SSF -- so it
seems that the Club for Growth AO applies, and the company's SuperPAC need
not follow the solicitation restrictions that would apply if it formed an
SSF.

Apologies for the confusion!

Steve Kolbert
(202) 422-2588
steve.kolbert at gmail.com
@Pronounce_the_T
On Oct 17, 2011 4:06 PM, <dmason12 at gmail.com> wrote:

> ** The Club AO specifically distinguished between the Club's SSF and the
> SuperPAC: two different types of committees.
>
> Sent via BlackBerry from T-Mobile
> ------------------------------
> *From: * Steve Kolbert <steve.kolbert at gmail.com>
> *Date: *Mon, 17 Oct 2011 16:01:31 -0400
> *To: *David Mason<dmason12 at gmail.com>
> *Cc: *law-election at uci.edu<law-election at uci.edu>; Rick Hasen<
> rhasen at law.uci.edu>
> *Subject: *Re: [EL] Deep Sea Not Deep News
>
> I'm not sure a corporate SSF would have to abide by those solicitation
> restrictions. See AO 2010-09 (Club for Growth) at 3-4 (granting a
> corporate-sponsored SuperPAC the right to solicit contributions from the
> general public).
>
> Steve Kolbert
> (202) 422-2588
> steve.kolbert at gmail.com
> @Pronounce_the_T
> On Oct 17, 2011 3:51 PM, "David Mason" <dmason12 at gmail.com> wrote:
>
>> Election law colleagues:
>>
>> What is one of the first rules on corporate SSFs?
>>
>> You can only solicit from the restricted class.
>>
>> Unless "deep sea" has a lot of employees or wealthy shareholders, this is
>> not a very good way to fund a SuperPAC.
>>
>> From the look of this Form 1, Mr. Benjamin could use some professional
>> help from someone on this list.
>>
>> Until he gets it, let's not assume this is some major legal development.
>>
>> Regards,
>>
>> Dave Mason
>>
>>
>>>
>>>  “Deep Sea Burial forms first corporate ‘super PAC”<http://electionlawblog.org/?p=24325>
>>> Posted on October 17, 2011 10:23 am<http://electionlawblog.org/?p=24325>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> *WaPo* reports<http://www.washingtonpost.com/politics/deep-sea-burial-forms-first-corporate-super-pac/2011/10/17/gIQABaRnrL_story.html>.
>>> My earlier coverage is here. <http://electionlawblog.org/?p=24304>
>>>
>>>
>>>
>>>
>>>
>>
>> _______________________________________________
>> Law-election mailing list
>> Law-election at department-lists.uci.edu
>> http://department-lists.uci.edu/mailman/listinfo/law-election
>>
>

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