# FEC Ground Game Spending Investigation
## Jan 1 – Nov 5, 2024 | Battleground States + America PAC / Elon Musk

**Data source:** `gen-lang-client-0281053432.politics_vault_standardized` (live BQ query)
**Date of analysis:** 2026-04-20

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## The Big Picture: GOTV Spending Totals

| Party/Category | Total GOTV/Canvassing Spend | Notes |
|---|---|---|
| **Democratic committees** | **$299.3M** | Named party-affiliated PACs only |
| **Republican committees** | **$16.4M** | Named party-affiliated PACs only |
| **Super PACs / Other (no party filing)** | **$399.7M** | Dark money orgs and Super PACs |
| **Total identifiable GOTV spend** | **~$715M** | Jan–Nov 5, 2024 |

Democrats outspent Republicans **18:1 on formal GOTV** in FEC filings. The $400M in "other" is where the most complex dark money flows live, spanning both sides.

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## Monthly Surge Timeline (GOTV spending by party)

| Month | DEM Spend | REP Spend | Signal |
|---|---|---|---|
| Jan 2024 | $2.0M | $0.6M | |
| Feb 2024 | $2.3M | $0.7M | |
| Mar 2024 | $2.0M | $1.2M | |
| Apr 2024 | $1.6M | $1.3M | |
| May 2024 | $10.2M | $0.6M | Primary season ramp |
| Jun 2024 | $8.6M | $0.3M | |
| **Jul 2024** | **$39.7M** | $0.5M | **Biden drops out; Harris enters; spending 20x's** |
| Aug 2024 | $45.6M | $3.0M | |
| Sep 2024 | $65.3M | $1.8M | |
| **Oct 2024** | **$106.6M** | $5.3M | **Peak ground game month** |
| Nov 1–5 | $15.4M | $1.2M | |

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## Top Canvassing Vendors by Total Received (Jan–Nov 2024)

| Rank | Vendor | State | Total Received | Primary Funders |
|---|---|---|---|---|
| 1 | **PATRIOT GRASSROOTS** | WY (Cheyenne) | $26.1M | Turnout for America (Super PAC) only |
| 2 | **SHAWMUT SERVICES LLC** | MA | ~$72M total | Progressive Turnout Project ($54M), DNC ($14M), Forward Majority ($11M) |
| 3 | **OTG STRATEGIES LLC** | NC | ~$120M total | DNC ($81M), DSCC ($17M), Biden/Harris campaigns ($14M) |
| 4 | **CANVASS AMERICA LLC** | DC | $11.2M | Multiple DEM committees |
| 5 | **THE OUTREACH TEAM LLC** | NY | $10.95M | Various |
| 6 | **RALLY BY RELENTLESS** | DE | $7.7M | DNC/Harris-aligned orgs |
| 7 | **DONOHOE PARTNERS INC** | DC | $6.2M | DNC-linked |
| 8 | **MACDONALD D'ALESSANDRO** | MA | $5.6M | Multiple |
| 9 | **VICTORY FORWARD SOLUTIONS LLC** | AZ | $2.98M | Republican-affiliated |
| 10 | **WORKER POWER** | AZ | $2.28M | Progressive/Labor |

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## Battleground State GOTV Breakdown

Vendors physically located in each swing state, Jan–Nov 2024:

| State | Top Party Spending | Total | Notable |
|---|---|---|---|
| **NC** | DEM | **$114.6M** | Almost entirely OTG Strategies LLC (Raleigh) |
| **AZ** | DEM + Unknown | **$39.6M** | LA Machine Consulting, Worker Power, Wired4Data |
| **GA** | DEM + Unknown | **$8.0M** | Brothers for Kamala ($771K), scattered vendors |
| **WI** | DEM | **$2.8M** | Connection Strategy LLC, Empower Innovations |
| **NV** | Various | **$3.6M** | Wired4Data ($1.79M phone banking IT), LAV Services |
| **PA** | Various | **$3.5M** | Scattered; America PAC ran rally/security ops |
| **MI** | Various | **$3.3M** | Coalition Strategies ($1.03M), scattered |

**North Carolina flag:** OTG Strategies LLC (NC-based) received $120M+ total — the single largest ground game contract in the country. DNC alone paid $81M to one vendor in one state.

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## America PAC (C00879510) — Elon Musk's Operation

**FEC type:** Super PAC / IE-only committee
**State of registration:** Texas
**Total spent Jan–Nov 5, 2024:** **$24.45M** (341 transactions, 102 payees)
**Musk personal donations to America PAC (reported):** ~$119M across 2024

### Top Payees

| Payee | State | Total | Purpose |
|---|---|---|---|
| **M&B ANALYTICS LLC** | VA (Alexandria) | **$4.93M** | "Data Analytics/Survey Research/Consulting" |
| **IMGE LLC** | DC | **$2.75M** | Digital media, texting, web services |
| **CONNECTION STRATEGY LLC** | WI (Hudson) | **$1.80M** | "Message Phone Calls" + tele-town halls |
| LIZZARAGA, NANCY | TX (Austin) | $1.00M | "Spokesperson Consultant" |
| KAMORA, JUDEY | TX (Austin) | $1.00M | "Spokesperson Consultant" |
| DREHER, JOHN | TX (Austin) | $1.00M | "Spokesperson Consultant" |
| COCHRAN, JASON | TX (Austin) | $1.00M | "Spokesperson Consultant" |
| TIMMERMAN, JORDAN | TX (Austin) | $1.00M | "Spokesperson Consultant" |
| MOSS, WAYNE | TX (Austin) | $1.00M | "Spokesperson Consultant" |
| STEINLE, ANDREW | TX (Austin) | $1.00M | "Spokesperson Consultant" |
| TOMEI, SHANNON | TX (Austin) | $1.00M | "Spokesperson Consultant" |
| P2 PATHWAY PUBLIC AFFAIRS LLC | DC | $713K | Travel/food/political strategy |
| BASELICE & ASSOCIATES INC | TX | $621K | Survey research |
| **T'S SCREENPRINTING** | MO (Peculiar) | **$393K** | **"Canvassing Field Operations Uniforms"** |
| **X CORP.** | PA (Philadelphia) | **$40K** | **"Licensing Service"** — Musk paid his own company |
| ECHO CANYON CONSULTING LLC | VA | $50K | "Polling Place Operations" (paid Nov 5 — Election Day) |

### America PAC Spending by State

| State | Total | Notes |
|---|---|---|
| TX | $9.7M | Includes 8 "spokesperson consultant" payments + surveys |
| VA | $6.2M | M&B Analytics, digital/strategy firms |
| DC | $3.5M | IMGE LLC, P2 Pathway |
| WI | $1.88M | Connection Strategy LLC phone banking |
| PA | $581K | Rally/event security; X Corp payment |
| MO | $394K | T's Screenprinting uniforms |
| DE | $386K | Osceola Strategies collateral materials |
| FL | $367K | Media consulting, security |
| WY | $261K | September Group LLC (canvassing) |

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## The $8M "Spokesperson Consultant" Payments — The Lottery Connection

**Eight individuals**, all with Austin TX addresses, each received **exactly $1,000,000** from America PAC between October 22 and November 4, 2024, labeled as "Spokesperson Consultant":

| Name | Date | Amount |
|---|---|---|
| DREHER, JOHN | Oct 22, 2024 | $1,000,000 |
| TOMEI, SHANNON | Oct 23, 2024 | $1,000,000 |
| STEINLE, ANDREW | Oct 25, 2024 | $1,000,000 |
| LIZZARAGA, NANCY | Oct 30, 2024 | $1,000,000 |
| TIMMERMAN, JORDAN | Oct 31, 2024 | $1,000,000 |
| MOSS, WAYNE | Nov 4, 2024 | $1,000,000 |
| COCHRAN, JASON | Nov 4, 2024 | $1,000,000 |
| KAMORA, JUDEY | Oct 29, 2024 | $1,000,000 |

**Context:** America PAC ran a $1M/day lottery for registered voters in PA, GA, NV, AZ, MI, WI, NC who signed a petition supporting "free speech and the right to bear arms." This was structured as "spokesperson payments" to avoid federal lottery statutes (18 USC 597 — purchasing votes). DOJ/FBI Philadelphia office opened a criminal investigation. A federal judge blocked the lottery on Oct 19; an appeals court allowed it to resume. FEC's 3-3 partisan deadlock prevented any enforcement action.

These eight Austin-based individuals appear connected to the lottery administration/spokesperson program. All payments cleared within 14 days before Election Day.

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## Republican Shadow GOTV — Turnout For America + Patriot Grassroots

**Turnout For America** (C00883520): Super PAC, no declared party affiliation
**Connected to:** Never Surrender Inc. (Trump PAC), Donald J. Trump for President 2024, Hung Cao for Virginia (REP)

**Patriot Grassroots** (Cheyenne, WY): LLC, no public-facing organization, all payments listed as simply "CANVASSING"

### Payment Schedule: Turnout For America → Patriot Grassroots

| Date | Payment | Running Total |
|---|---|---|
| Aug 20, 2024 | $855,000 | $855K |
| Aug 27, 2024 | $1,187,500 | $2.0M |
| Aug 30, 2024 | $950,000 | $3.0M |
| Sep 27, 2024 | $2,976,666 | $6.0M |
| Sep 30, 2024 | $2,976,666 | $9.0M |
| Sep 30, 2024 | $2,976,666 | $12.0M |
| Oct 4, 2024 | $760,000 | $12.8M |
| Oct 17, 2024 | $3,086,550 | $15.8M |
| **Oct 22, 2024** | **$4,719,600** | $20.6M |
| Oct 24, 2024 | $920,550 | $21.5M |
| Oct 25, 2024 | $2,940,250 | $24.4M |
| Oct 28, 2024 | $1,715,026 | **$26.1M** |

**Flag:** $26.1M to a Wyoming LLC with zero sub-vendor itemization in FEC filings. Total Republican formal GOTV was $16.4M — this single pass-through exceeded that by $10M while reporting no downstream disbursements.

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## State-Level Money Flows Into Battleground States

Federal PAC money routed into state-level committees via "nonfederal contributions from contribution accounts" (hybrid PAC mechanism):

| Federal Sender | Recipient State Committee | Amount | Mechanism |
|---|---|---|---|
| **PAC for America's Future / Future Now Fund** | PA House Democratic Campaign Committee | **$4.8M** | Nonfederal contribution |
| PAC for America's Future | Wisconsin Assembly Democratic Campaign | $2.4M | Nonfederal contribution |
| PAC for America's Future | Arizona Democratic Legislative Campaign | $2.4M | Nonfederal contribution |
| PAC for America's Future | North Carolina Democratic Party | $1.44M | Nonfederal contribution |
| **WA State Democratic Central Committee** | Wisconsin Democratic Party | $1.72M | Unlimited transfer |
| **SEIU COPE** | Wisconsin State Council SEIU | $1.56M | Advance for future IEs + in-kind |
| **SEIU COPE** | SEIU Michigan State Council | $1.50M | Advance for future IEs + in-kind |

**PAC for America's Future** is a 527/hybrid PAC designed specifically to route money into state legislative races — funneled ~$11M into battleground state assemblies and parties in this cycle.

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## The FEC Rule Changes — What Opened the Floodgates

The rule change allowing 3rd-party spending at scale (i.e., Musk-scale) was not a single moment but overlapping gaps:

1. **Super PAC Coordination Loophole:** FEC enforcement requires 4 of 6 votes. The 3-3 partisan deadlock means any complaint about coordination between America PAC and the Trump campaign could not proceed. Musk met openly with Trump during the campaign period. No investigation was possible.

2. **America PAC Lottery — Exploitation of 52 USC § 30122:** Federal law prohibits contributions in another person's name. The $1M/day lottery was structured as "spokesperson payments" to bypass this. No FEC advisory opinion was issued due to deadlock.

3. **Coordinated Party Expenditure Limits (11 CFR 109.32):** These caps apply only to *party committees*, not Super PACs. America PAC faced no limits on what amounted to coordinated ground operations.

4. **Internet Safe Harbor (11 CFR 100.26):** A 2006 FEC rule exempts most online communications from coordination rules. X Corp (Musk-owned) provided data/amplification services to America PAC. The $40K "licensing" payment to X Corp is the paper trail. This was not classified as a corporate in-kind contribution.

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## Anomalies and Flags for Further Investigation

| Flag | Entity | Why It's Notable |
|---|---|---|
| **$8M to 8 Austin individuals** | America PAC "spokesperson consultants" | Exact $1M each, Oct–Nov 2024; DOJ investigated as potential vote-buying |
| **Patriot Grassroots (WY LLC)** | Turnout for America → Patriot Grassroots | $26.1M to Wyoming shell, no itemized sub-vendors, Trump-adjacent PAC funder |
| **OTG Strategies monopoly** | DNC → OTG ($81M), DSCC → OTG ($17M) | Single NC vendor got $120M+; sub-vendor reporting warrants examination |
| **X Corp licensing fee** | America PAC → X Corp | Musk-to-Musk payment Oct 28; no description of what was licensed |
| **Progressive Turnout Project → Shawmut** | Four identical $5.67M same-day payments (Sep 25) | Possible structured disbursements or duplicate entries |
| **ECHO CANYON CONSULTING** | America PAC | $50K for "Polling Place Operations" paid Election Day itself (Nov 5) |
| **PA sheriff/security payments** | America PAC | Multiple PA county law enforcement and private security paid for October rally operations |

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## Key Committee IDs for Follow-Up Queries

| FEC ID | Name | Type |
|---|---|---|
| C00879510 | AMERICA PAC | Super PAC / IE-only (TX) |
| C00883520 | TURNOUT FOR AMERICA | Super PAC, no party (linked to Trump) |
| C00580068 | PROGRESSIVE TURNOUT PROJECT | Super PAC (W-type) |
| C00010603 | DNC SERVICES CORP / DEMOCRATIC NATIONAL COMMITTEE | National party (Y) |
| C00042366 | DSCC | National party (Y) |
| C00703975 | HARRIS FOR PRESIDENT / BIDEN FOR PRESIDENT / FIGHT FOR THE PEOPLE PAC | Presidential + hybrid |
| C00654053 | PAC FOR AMERICA'S FUTURE / FUTURE NOW FUND | Hybrid PAC (V) |
| C00004036 | SEIU COPE | Labor PAC (Q) |

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*Queries run against: `gen-lang-client-0281053432.politics_vault_standardized.fec_expenditures_2019_March2026_p` and `fec_committee_master_2019_2026`*
*Analysis date: 2026-04-20*