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75 Maiden Lane / Suite 505 / MW^.l 10038 (212) 727-8610 / fax: (212) 60^-6955" / ww.dsausa.org
2001 MAY 2b A 10 59
May 21,2009 Honorary Chairs
Bogdan Den itch Barbara Ehrenreich Dolores Huerta Eliseo Medina Eugene "Gus " Newport Frances Fox Piven Gloria Steinem Cornel West
Daniel Buckley FEC Frank Llewellyn Treasurer DSA PAC Response to Your Letter Dated April 24,2009, Concerning Democratic Socialists of America PAC's October Quarterly Report (7/1/08-9/30/08)
Elaine Bernard Edward Clark Jose LaLuz Steve Max Harold Meyerson Maxine Phillips Christine Riddiough Rosemary Ruether Joseph Schwartz Ruth Spitz Moll Zelmanowicz
The $1,704.37 expenditure paid for a portion of the postage, printing and mailing expenses of Democratic Left, the newsletter of Democratic Socialists of America (DSA), DSA PAC's connected organization. The 16-page Fall 2008 issue of Democratic Left included two articles that arguably expressly advocated for the election of then-presidential candidate Barack Obama and against the election of John McCain (primarily the latter). The newsletter was first distributed in September of 2008, and the vast majority of the copies (approximately 90% of the 7000 copies printed), were sent to bona fide members of DSA or were not used. The newsletter did not solicit any contributions, as defined by Commission regulations. Nevertheless, the Democratic Socialists of America PAC paid the portion of the expenses allocable to express advocacy in advance of the newsletter's publication and distribution. The portion of the expenses allocable to express advocacy was determined on the basis of the number of pages the articles containing express advocacy occupied relative to the newsletter's total number of pages. The $1,000 expenditure was an advance payment made to DSA to cover a portion of the compensation of a DSA employee who was organizing students on college campuses. At the time of the payment, it was believed that the employee would at times expressly advocate for the election of Barack Obama. After DSA PAC made the expenditure, and the October quarterly report was filed, it was determined that the employee engaged in hardly any express advocacy and that the fair market value of the time involved was $250. Moreover the employee never solicited contributions, as defined by Commission regulations. We did not amend the report to remove the over-expenditure from Schedule E and report it as an "other disbursement" on line 29 of Schedule B simply because it was a relatively small amount and we did not think the public interest was harmed by this type of "over-reporting." Finally, I understand that you spoke with our attorney, Paul J. Murphy, who verified with you the adequacy of this response. If you should require any additional information, however, please do not hesitate to contact me.
Michael Harrington (1928-1989)
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