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(October 2020)


Many right-wing politicians and think tanks funded by Charles Koch and his network of
billionaires are giving voice to false claims about the possibility of widespread voter fraud and
rigged elections due to expanded mail-in voting access by states seeking to minimize the spread of
COVID-19. Meanwhile, Koch’s consolidated political arm, Americans for Prosperity, has
announced that 2020 will be its biggest year ever in spending around the election and that it has
expanded door-to-door outreach during this pandemic.

However, there has been little coverage of the Koch network’s history of election violations or its
role in aiding voter suppression to help aid politicians that advance his political agenda. These
examples should be included in any coverage of Koch-funded electoral activities during this
election and during efforts by civic groups to ensure that Americans’ votes are counted. Here are
snapshots of some of the key parts of that history, with more detailed in this backgrounder:

✓ Vote-By-Mail Restriction Efforts [2020]. Koch-funded think tanks are currently

churning out pieces lamenting the supposed opportunities for voter fraud catalyzed by
increased accessibility of mail-in ballots. They fail to mention the Koch network’s past of
widely distributing false information about mail-in ballots. Meanwhile, Koch-funded
politicians are working to produce legislation that would restrict access to mail-in voting and
fighting efforts to limit the potential surge in COVID-19 cases due to crowded physical polling
stations in November.

✓ AFP Mailers [2010-2014]. Americans for Prosperity (AFP), one of the groups established
by Charles and David Koch, was involved in voter caging and misinformation campaigns
across multiple states from 2010-2014. In 2010, the Wisconsin branch of AFP was identified
as part of “a coordinated plot ... targeting minority voters and college students in a possibly
illegal ‘voter caging’ effort for voter suppression.” In 2011, AFP was accused of attempting to
suppress Democratic voter turnout in Wisconsin’s recall elections after AFP sent flyers to
Democratic voters encouraging them to vote by mail, but giving false information about the
deadline to submit ballots and giving a false return address; the address was actually the PO
box for the right wing group Wisconsin Family Action. Similar mailers relating to voter
registration deadlines were sent out by AFP in North Carolina in 2014, which provided the
wrong deadline for voter registration, the wrong state agency through which to register, and
the wrong ZIP code for returning registration forms.

✓ FEC Fines [2010/2016]. In 2013, another Koch front group, the Center to Protect Patient
Rights (CPPR), was found to have secretly channeled $11 million through Americans for
Responsible Leadership, an Arizona-based group, in order to oppose a tax increase and to
support a proposal that would restrict the political power of unions. Then-California Attorney
General Kamala Harris announced the civil settlement which ordered CPPR and Americans
for Responsible Leadership to pay a fine of $500,000 each--the largest election fine in
California history. Similarly, in 2010, the FEC agreed to a $233,000 fine for three Koch
network-funded groups for illegally hiding the sources of their funding for political ads in
California. The groups in question obtained the millions spent on 2010 advertisements from
CPPR, the main cash distributor for the Koch brothers’ political operations.

✓ Triad Investigations [1996-1997] In 1997, the U.S. Senate investigated Triad

Management Services, a shell corporation which had spent more than three million dollars to
fund attack ads in 29 House and Senate Races. Most of the races took place in states where
Koch Industries had refineries, offices, or pipelines, and Triad was especially active in Charles
Koch’s home state of Kansas. Koch money financed an obscure entity known as the Economic
Education Trust, which in turn financed two separate shell groups which themselves were
controlled by Triad Management Services to produce the ads. The Triad case exemplified the
Koch’s recurring strategy of setting up “disposable front groups” through which to funnel
money for political expenditure, ultimately using their shell corporations as tools to evade
contribution limits and financial disclosure requirements.

Management, one of Koch’s earlier attempts
Introduction at influencing elections through massive,
secret contributions.
In recent weeks, multiple right wing
political organizations backed by dark It is the same formula followed in the many
money groups have launched advertising similar subsequent efforts of the Koch
campaigns opposing expansions of mail-in network, including the high-profile
voting access which would allow voters an campaign finance violations in California in
alternative way to participate in the election, 2010-2016 which landed Koch’s groups with
as coronavirus surges and voters are wary of the largest fine in state history.
crowded polling stations. The groups are
converging around attempts by President Equally egregious, if less convoluted, are the
Trump and many Republicans to restrict multiple instances of direct misinformation
access to mail-in ballots, buoyed by Trump’s campaigns in which Americans for
false claims that mail-in voting is more Prosperity (AFP), the group founded by
likely to be fraudulent or lead to a rigged Charles and David Koch, sent flyers to
election. Democratic voters in multiple states
providing them with false information about
Among the organizations opposing mail-in registration and voting deadlines, leading to
voting expansions is the Honest Elections accusations of attempting to suppress
Project (HEP), a right wing group which Democratic turnout.
emerged out of the network orchestrated by
Leonard Leo that helped secure the AFP Mailers [2011-2014]
nominations of Justices Brett Kavanaugh
HEP’s decrying of mail-in voter fraud is
and Neil Gorsuch. HEP, which has now
particularly jarring when taken into
turned its focus to increasing voting
consideration with the widespread mail-in
restrictions, is one of several groups funded
voting misinformation campaigns led by
by the Koch fortune.
Americans for Prosperity.
The current efforts of HEP and other
In 2011, AFP was accused of attempting to
Koch-funded organizations to restrict voting
suppress Democratic voter turnout in the
by touting false claims about fraud sit
state’s recall elections after it came to light
against a backdrop of decades of efforts by
that AFP had sent flyers to Democratic
similar Koch-funded coalitions to mislead
voters in Wisconsin encouraging them to
and disenfranchise voters at the local, state,
vote by mail, but giving false information
and federal levels.
about the deadline to submit ballots. Voters
Their organizational strategy today follows reported receiving absentee ballot
the Koch’s well-established pattern of application forms from AFP instructing
setting up a pipeline of corporate front them to mail the ballot back by August 11th,
groups that funnel millions of dollars two days after the true date of a contested
towards their political goals, protected from recall election set for August 9th. The
individual contribution limits by the ruse of mailers also instructed voters to mail their
their many non-profits. ballots to an address listed as “the absentee
ballot processing center,” but which was
This blueprint for circumventing actually the P.O. box for the conservative
anti-corruption laws was exposed in the group Wisconsin Family Action.
1997 Senate investigations of Triad

rules for voting, which echoed a priority of
the Koch-funded American Legislative
Exchange Council that makes it harder for
Americans to vote.

However, if mailers were returned to their

senders at Americans for Prosperity as
“undeliverable,” those voters would be
challenged at the polls by Tea Party recruits
for not legally residing at the addresses to
which their voter registration is attached.
The effort was exposed weeks before the
contested election as a consolidated effort to
strike as many as 70,000 voters from the
state’s voter rolls. The Tea Party Republican
candidate Ron Johnson won the race.

Americans for Prosperity has collaborated

with other groups with histories of voter
suppression and intimidation, including
True the Vote - a vote-monitoring initiative
Sample Fake “Absentee Ballot Application” sent by with a “horrendous record of filing
Americans for Prosperity to voters inaccurate voter registration challenges.” In
One year earlier, in 2010, the Wisconsin 2012, Rep. Elijah Cummings launched an
branch of Americans for Prosperity was investigation into True the Vote, which has
identified as part of “a coordinated plot by been accused of voter intimidation, and of
the Republican Party of Wisconsin, promoting inaccurate claims about the
Americans for Prosperity-Wisconsin and prevalence of voter fraud.
organizations in the so-called Tea Party Similarly, in 2014, thousands of North
movement targeting minority voters and
Carolina residents received mailers from
college students in a possibly illegal ‘voter
American for Prosperity which provided the
caging’ effort for voter suppression.”
wrong deadline for voter registration, the
The effort involved compiling a list of wrong state agency through which to
minority and student voters in targeted register, the wrong state office to which
communities using the Wisconsin voters should address questions, and the
Republican Party’s statewide voter file, and wrong ZIP code for returning voter
sending mailers to those individuals which registration forms. These, among other
threatened to remove them from voter inaccuracies in the mailers led to an official
registration lists unless they called to complaint by the North Carolina
confirm their information. Democratic Party against Americans for
Prosperity, stating that “the recipients of the
That same year, the Koch Brothers and communications would be misled,
Americans for Prosperity threw their intimidated, and/or discouraged from
influence behind the election of Wisconsin voting” and that the mailers “are designed
Governor Scott Walker. Walker quickly to effect that result.”
signed a law introducing new restrictive

In response to the misinformation (Cain recently passed away from Covid-19
campaigns in Wisconsin and North after attending a Trump rally where few
Carolina, Americans for Prosperity simply people wore masks.)
stated that “it was a mistake,” blaming the
inaccuracies on both typographical errors
and on the printer for sending the mailers to
the wrong voting districts. AFP’s voting
mailer mistakes were among many
examples of “oversights” by the
billionaire-funded group while undertaking
efforts to influence public opinion.

In 2012, AFP funded a radio advertising

campaign in Pennsylvania regarding the
Affordable Care Act. The advertisements
invited listeners to AFP’s “HANDS OFF MY Herman Cain at CPAC by Gage Skidmore.
HEALTHCARE RALLY,” and described the
ACA as “an expensive, bloated law that puts Unlawful collaboration with outside groups
Washington bureaucrats between you and is a repeated tactic for Koch-funded
your doctor.” candidates. Similar charges were leveled in
2018 against Americans for Prosperity in
However, due to an alleged “inadvertent New Hampshire; lawmakers called for an
oversight” the advertisement did not include investigation into AFP, alleging that their
the disclaimers that are required of extensive political advocacy is a violation of
electioneering communications by the state regulations for nonprofit
Federal Election Commission. It also organizations.
omitted the fact that AFP was responsible
for the content of the advertising and that Later in 2018, Tennessee Citizen Action
the ad was not authorized by any candidate (TCA) filed an FEC complaint requesting an
or candidate’s committee. investigation into possible coordination
between Marsha Blackburn’s Senate
That same year, Herman Cain (the
campaign and “at least three outside
conservative lobbyist who described himself
groups,” which would be a “violation of the
as the Koch’s “brother from another
Federal Election Campaign Act.” Americans
mother”) launched an unsuccessful
for Prosperity is one of the groups in
campaign for the Republican Presidential
question, along with Club for Growth and
nomination. Cain’s chief of staff, Mark
the Senate Leadership Fund, both of which
Block, was the state director of the
also receive funding from the Koch brothers.
Wisconsin chapter of AFP.

Cain also founded the right-wing 2018 also saw a complaint from Montana
organization Prosperity USA, which was Republican Rep. Frank Garner, who filed
investigated by the IRS for potential with the Montana Commissioner of Political
campaign finance regulations by fronting Practices alleging that Montana Citizens for
tens of thousands of dollars for Cain’s Right to Work, the state affiliate of the
campaign expenses, violating their 501(c)(3) National Right to Work Committee
status. (NRTWC), was actively recruiting

candidates to oppose him in his district
race. Garner alleged that this was illegal
activity, given that the group was not
registered with state election officials as the
law requires.

The National Right to Work Committee has

deep ties to the Koch brothers; at least three
former Koch associates work as attorneys at
the NRTWC’s legal foundation, and the Sean Noble in an interview on Dark Money campaigns.
Koch’s Freedom Partners group gave $1
million to the group in 2012.
Then-California Attorney General Kamala
FEC Fines [2010/2016] Harris announced the civil settlement in the
case which ordered CPPR and Americans
A few years later, the “oversights” of the for Responsible Leadership to pay a fine of
Koch network resulted in multiple $500,000 each. Sean Noble and the Kochs
Koch-funded groups being ordered to pay denied wrongdoing. This million dollar fine
what was then the largest election fine in was then the largest election fine in
California history for campaign finance California history.
In 2016, the Federal Election Commission
In 2013, a group then known as the Center (FEC) agreed to a $233,000 fine for three
to Protect Patient Rights (CPPR) was found other Koch network-funded groups for
to have secretly channeled $11 million illegally hiding the sources of their funding
through Americans for Responsible for political ads in California.
Leadership, another Arizona-based group,
in order to oppose a tax increase and to The groups named in the FEC complaint are
support a proposal that would restrict the the American Future Fund (AFF),
political power of unions. Americans for Jobs Security (AJS), and the
60+ Association. In 2010, the Arizona-
The CPPR is the main cash distributor for based CPPR funneled $25.5 million into
the Koch brothers. It was formed in 2009 by California elections by first sending the
Sean Noble, who served as the political money to AFF, AJS, and 60+; these three
consultant to the Koch brothers and groups then spent tens of millions of dollars
attended their retreats. Noble founded the on advertisements supporting Republican
group in conjunction with Republican donor House candidates.
Randy Kendrick with the purpose of
opposing the Affordable Care Act, which the
Kochs also spent huge sums opposing
directly and through grassroots lobbying.

therefore required to be disclosed as the
source of funding.

In response to the California fines, CPPR

claimed that their violations of campaign
finance rules were accidental and due to the
fact that they had “never before made
contributions in California.”

CPPR has also misrepresented millions of

dollars in donations to other organizations
which were purportedly given for “tax
exempt education and social welfare
Excerpt of FEC complaint vs. AFF, AJS, CPPR, and 60+.
purposes,” but which were spent on political
Source: advertisements and campaign activities.

Despite creating an artificial sense of The revelations about the extent of Noble’s
distance between CPPR and the political ad involvement in the ad campaigns, and the
campaigns by first channeling the money extent of his own financial profit as a result
through AFF, AJS, and 60+, Noble and of the undisclosed sub-contracting of Noble
CPPR had extensive involvement in the ads. Associates, came to light in 2014 when
Noble himself gave a detailed description of
Noble selected which races to get involved the situation to the National Review.
in, researched and produced the ads
themselves, and made the decisions of when Shortly before the FEC complaint against
to air the ads. Noble’s consulting firm, CPPR was filed by CREW in May, 2014,
Noble Associates, also worked as an Noble dissolved the group and re-formed it
undisclosed subcontractor to the vendors under the name American Encore.
who produced the ads, and secretly received
millions of dollars for their involvement. This new iteration of the group continued to
fund many of the same organizations within
This level of participation by a donor in the the Koch network, including the 60+
use of their grant would normally qualify Association, the Legacy Foundation Action
the donation as an “earmarked” Fund, and the Trees of Liberty -- a
contribution -- a contribution made with the short-lived front group for various Koch
specific purpose of supporting an enterprises set up in order to influence the
electioneering communication or a reported 2014 Iowa Senate Republican primaries.
independent expenditure. Recipients of
earmarked funds are required under FEC The Center for Media and Democracy filed
rules to disclose the funds’ donors; however, an official complaint against the group,
AJS, AFF, and 60+ all failed to report any citing facts and circumstances indicating
earmarked contributions from CPPR. After that “Trees of Liberty was operated
investigation, the FEC found that Noble’s primarily to advance the private interests of
deep involvement in the ad campaigns was Sen. Ernst and of the Koch political network
sufficient grounds to categorize CPPR’s that created and funded Trees of Liberty, in
donations to the three groups as earmarked violation of its section 501(c)(4) tax-exempt
for specific political expenditures and status.” Ernst and other Republican Senate
candidates later directly credited the

intervention of the Koch network with evade contribution limits and financial
securing her “trajectory.” disclosure requirements.

The extensive and multifaceted financial In the Triad case, the Kochs and their
maneuverings of the Koch political network affiliated organizations established layers of
exemplify the undue influence given to artificial separation between themselves and
ultra-wealthy individuals and corporations their financial manipulations of
as a result of the Supreme Court’s Citizens congressional races. The first layer of
United ruling. They also demonstrate the separation came from an obscure entity
tenacious expertise of those involved in known as the Economic Education Trust
side-stepping the remaining anti-corruption (EET). Over half of the money used for the
laws governing political contributions-- ad campaigns in question came from EET,
despite the Koch network’s repeated which was believed by the Senate
insistence of their ignorance of the rules and Committee to be “financed in whole or in
claims of unintentional violations. part by Charles and David Koch of Wichita,
Nevertheless, the influence of the Kochs in
American political systems was clear long
before Citizens United made their
electioneering legal. Their strategic
framework of financial sidestepping and use
of shadow groups in the CPPR scandal
takes after another effort backed by the
Kochs to influence elections in the early
1990s, when an unknown nonprofit -- Triad
Management -- financed two other
nonprofits to air $3 million in television ads
in twenty-six House races and three Senate

Triad Investigations [1996-1997] Excerpt from the Senate Committee’s Final Report. Source:
In 1997, the U.S. Senate undertook df/CRPT-105srpt167-pt5.pdf
investigations of Triad Management
The EET then gave money to two separate
Services, a shell corporation which had
shell groups, dubbed Citizens for Reform
spent over three million dollars to fund
and Citizens for the Republic Education
attack ads in 29 House and Senate Races.
Fund, which were controlled by Triad
Most of the races took place in states where
Management Services - thus creating a
Koch Industries had refineries, offices, or
second layer of separation. In a preview of
pipelines, and Triad was especially active in
the strategy that played out again in the
Charles Koch’s home state of Kansas. The
2010 campaign finance violations of Sean
Triad case exemplified the recurring
Noble and CPPR, it appears that the funds
strategy of the Kochs’ to set up “disposable
from EET were given to Citizens for Reform
front groups” through which to funnel
and Citizens for the Republic Education
money for political expenditure, ultimately
Fund with the understanding that EET’s
using their shell corporations as tools to
consultant would oversee the advertising

While the Kochs refused to comment at the who supported Triad and its affiliated
time, the Wall Street Journal confirmed in groups.
1998 that Republican political consultant
The Issues with Koch’s Stealth “Term
Kenneth Barfield, who was on the Koch’s
Limits” Campaigns
payroll, had indeed been involved in the
strategy. Furthermore, the Senate Two such organizations, which were (and
committee’s investigation uncovered a still are) involved in political activity while
corporate check for $2,000 from Koch claiming to be non-partisan, are Americans
Industries made out to Triad. for Limited Terms, and U.S. Term Limits
(USTL). Both founded in the early 1990s,
Beyond the shadowy nature of its funding,
the groups’ activities are nearly as similar as
Triad was found to have “used a variety of
their names.
improper and possibly illegal tactics to help
Republican candidates win election in USTL asks federal candidates to sign a
1996,” including providing “free services to pledge promising that they will vote to limit
Republican campaigns in possible violation House members to three two-year terms,
of the federal prohibition against direct and Senate members to two six-year terms.
corporate contributions to candidates.” ALT creates advertising campaigns labeled
as “issue advocacy,” targeting candidates
More egregiously, the report from the
who refuse to sign the pledge put forward by
Committee on Governmental Affairs
concluded that the evidence before the
committee suggested that Triad was The groups also shared a website, used the
involved in a scheme to allow supporters to same advertising agency, and shared many
circumvent the limits on maximum funders and board members. Howard
permissible contributions to campaigns. (Howie) Rich -- a long-time friend of
Triad obtained “names of supporters who Charles Koch, and a board member of the
had already made the maximum permissible Koch-funded Cato Institute -- was both a
contributions and solicited those supporters co-founder of Americans for Limited Terms
for contributions to a network of and the president of USTL. The president of
conservative PACs. the Cato Institute, Ed Crane, also served on
the board of USTL. Eric O’Keefe also
In many instances, the PACs then made
worked extensively on Koch’s term limits
contributions to the same candidates. As
efforts. And Mike Pompeo, who is now
reported by the committee: “Triad exists for
Secretary of State and who previously
the sole purpose of influencing federal
represented Wichita in Congress, even
elections. Triad is not a political consulting
worked on the litigation on behalf of the
business: it issues no invoices, charges no
Koch term limit operations when he was a
fees, and makes no profit. It is a corporate
new attorney at a law firm.
shell funded by a few wealthy conservative
Republican activists.” Contemporaneously with the 1996
campaign finance violations of Triad, USTL
In the course of the Committee’s
was being criticized by the Secretary of State
investigation into Triad, they also unearthed
for Washington State for “flouting state
information about the funding sources of
campaign disclosure laws for more than two
myriad other “issue advocacy,” tax-exempt
months.” USTL had pushed forward an
organizations funded by the same donors
initiative that would require state legislators

to call for a constitutional convention of mail-in ballots, despite their own past
Congress in order to propose congressional efforts to incentivize mail-in voting through
term limits. Any delegate or legislator who fraudulent means. Meanwhile, Koch-funded
voted against the plan would be specifically politicians are working to produce
indicated by a notation on voting ballots, legislation that would legally restrict
marking them as someone who “disregarded vote-by-mail efforts that are underway to
voter instruction on term limits.” limit the potential surge in COVID-19 cases
due to crowded physical polling stations in
This followed on the heels of a 1995 November.
Supreme Court decision in U.S. Term
Limits, Inc. v. Thornton, a case petitioned
by USTL in which the Court ruled that state
constitutions could not adopt
“qualifications” for congressional
representatives (such as term limits) in
addition to the qualifications enumerated in
the Constitution.

USTL continued to be active in political

activities in the following decades, and in
2008 was again hit with a complaint of
violating campaign finance laws. Citizens for
Wisconsin voters lining up to vote in April. Source: Henry
Responsibility and Ethics in Washington C. Jorgensen/Shutterstock.
(CREW) filed a complaint against USTL’s
advertising activity in Colorado, based on an In Ohio, a state currently experiencing a
ad for U.S. Senate candidate Bob Schaffer surge in cases of COVID-19, a freshman
which failed to include a statement that the legislator introduced a bill in the state
person responsible for financing the House that, as originally written, would
advertisement was responsible for the have prevented the state from mailing
content of the advertisement. Furthermore, absentee ballot applications with pre-paid
USTL failed to file a report describing their postage to every registered voter.
expenditure within the 48-hour window
The legislator, Republican Rep. Cindy
after the ad first aired.
Abrams, is a member of the Koch-funded
These are the same campaign finance American Legislative Exchange Council
violations which have been repeatedly cited (ALEC), a corporate bill mill where state
in FEC complaints against numerous front legislators vote as equals with corporate
groups tied to the Koch brothers, including lobbyists and special interest groups on
the 2012 complaints against Americans for “model” bills that advance legislation that
Prosperity mentioned above. benefits the corporate bottom line.

Vote-By-Mail Voter Restriction Koch Industries and Charles Koch’s fortune

Efforts [2020] are key funders of ALEC, which has a long
history of promoting voter suppression
Today, Koch-funded think tanks are legislation; their 2009 Voter ID Act
churning out pieces lamenting the disenfranchised many low-income,
supposedly fraudulent possibilities minority, elderly, and student voters by
catalyzed by increased accessibility of

requiring specific forms of identification to Judge Amy Coney Barrett, President
be presented at polling stations. Trump’s nominee to fill the vacancy on the
Supreme Court caused by Justice Ruth
The Heritage Foundation, a right wing think Bader Ginsburg’s death, has refused to
tank which has received millions of dollars recuse herself from any cases involving this
from the Koch fortune, recently published a election. She has refused to commit to doing
piece on “the vulnerabilities of absentee and so even though Trump has expressly said he
mail-in ballots,” which makes needs her on the Court to help rule on
unsubstantiated arguments that “universal challenges to ballots he plans to bring.
absentee or mail-in voting leaves America’s
electoral system vulnerable to fraud, For decades, the many arms of the Koch’s
forgery, coercion, and voter intimidation.” political network have evaded
anti-corruption laws. Their vast financial
The piece is by Hans von Spakovsky, a power makes them practically immune to
Republican lawyer who served in the Bush violation fines, leaving them free to continue
administration and who has long been an their extensive suppression efforts and
advocate of voter suppression laws. He most corrupt lobbying practices.
recently served on President Trump's
disbanded "election integrity" commission, Today, groups funded and founded by the
and has been a presenter at ALEC Koch brothers are attacking mail-in voting
conferences. Von Spakovsky’s piece profiles in the 2020 election by reprising their
four elections (two mayoral elections, one previous methods: propagating myths about
Congressional race, and one race for the mail-in ballot fraud, hiding behind many
Fresno County school board) in which the lines of shadow groups, and flooding
results of the election were overturned by political campaigns with millions of
courts after finding evidence of voter fraud corporate dollars to prop up individuals who
with mail-in ballots. will support policies that benefit the Koch’s
bottom line, at the expense of American
Setting aside the hypocrisy of citing these democracy.
examples when the Koch network itself has
been behind significant efforts to Any story covering the role of Koch groups
disenfranchise and misinform voters, the in our election should make clear to readers
structure of von Spakovsky’s argument that Koch’s political operations have a long
foreshadows a troubling strategy. The and deep history of violating election laws,
examples of elections in which the results misleading voters, and serious allegations of
have been overturned by courts lay the practices that damage our electoral process.
groundwork for precedent this fall, when
President Trump may contest election
results on the grounds of fraudulent ballots,
if the results are not in his favor. This would
leave the verdict to the courts, which his
administration (made up of Koch-funded
politicians and lobbyists) has methodically
stacked with conservatives over the past
four years.


Chronological list of complaints or reports of violations by Koch network groups (including

those not elaborated in this report)

✓ 1996 backlash against US Term Limits in Washington

✓ 1998 Triad investigation
✓ 2008 FEC complaint against US Term Limits
✓ 2010 voter caging accusations against AFP
✓ 2011 accusations of voter suppression against AFP
✓ 2011 false absentee ballot applications - AFP
✓ 2011 Mark Block/Prosperity USA campaign violations
✓ 2012 investigation of True the Vote
✓ 2013 fines for ARL, CPPR
✓ 2014 North Carolina Democratic Party complaint against AFP
✓ 2014 FEC complaint against AFF, AJS, 60+, CPPR
✓ 2015 FEC complaint against Freedom Partners Action Fund (among others)
✓ 2015 FEC complaint against American Crossroads, Crossroads GPS, AFP, i360 (among
✓ 2016 FEC fines for AFS, AJS, 60+
✓ 2016 complaint against Charles Koch, Charles Koch Trust (among others)
✓ 2018 investigation into AFP for violation of nonprofit status
✓ 2018 FEC complaint against Marsha Blackburn’s Senate campaign including Club for
Growth, Americans for Prosperity and Senate Leadership Fund.
✓ 2018 CREW v. FEC lawsuit against American Crossroads/Crossroads GPS
✓ 2018 complaint against Montana Citizens for Right to Work
✓ 2019 lawsuit against AFP for text message campaign
✓ 2020 Heritage Foundation thought pieces on mail-in ballot fraud
✓ 2020 ALEC bills restricting mail-in ballot access

About Us
This backgrounder has been prepared by Lisa Graves and Caroline Jones for True North Research. Graves is the
Executive Director of True North Research, a watchdog that investigates corporate interests distorting American
democracy. She is also the co-curator of and a co-leader of the Ben Franklin Project. She has previously
served as the Chief Counsel for Nominations for the U.S. Senate Judiciary Committee, a Deputy Assistant Attorney
General at the U.S. Department of Justice (where she worked on judicial selection and fair courts), and Deputy Chief
of the Article III Judges Division of the Administrative Office of the U.S. Courts (where she advised on anti-
corruption measures). She began studying the Federalist Society in 1989 and the nomination and confirmation
process in 1991. Her analysis has been cited in many books, articles, and interviews. Jones is a researcher with True North, whose work primarily focuses on climate
change deniers, like many of the Koch groups, which have tried to obstruct efforts to mitigate climate change. True
North Research’s Evan Vorpahl and Alyssa Bowen also contributed to this report.

To arrange for an interview, please contact Kyle Moler at, p: 321-345-1758