by Abigail Crabtree, Associate Member, University of Cincinnati Law Review Vol. 93
I. Introduction
During a Trump campaign rally in Pennsylvania, Elon Musk pledged to give one million dollars to one swing state voter who signs his America PAC petition in support of the First and Second Amendments every day before the election.[1] Musk followed through on this promise, announcing the daily winners at rallies and on his social media platform, X. This article will discuss the legality of Musk’s daily one million dollar giveaway in swing states ahead of the 2024 presidential election. Further, it will discuss the history of campaign finance in the United States and how it should influence an analysis of Musk’s lottery. Section II will discuss the history of campaign finance in the United States, campaign finance jurisprudence, Political Action Committees, and Pennsylvania’s lawsuit against Musk. Section III will analyze the factors likely to influence a court’s decision on the giveaway’s legality, what Musk stands to gain and what he can give, and its implications for the future of American politics. Finally, Section IV will conclude by emphasizing the urgent need for legislative action in the face of courts determining the giveaway’s legality.
II. Background
The 2024 election saw an unprecedented level of billionaire involvement.[2] 150 billionaire families donated a total of $1.9 billion to presidential and congressional candidates of both parties.[3] Musk is, therefore, one of many billionaires using their wealth to influence the election, but his one million dollar giveaway was unique. Many legal scholars and politicians have raised issues about Musk’s giveaway, particularly regarding whether it violates campaign finance laws. The Justice Department warned Musk’s America PAC that this giveaway may violate federal law, and Musk and the PAC were subsequently sued by Philadelphia District Attorney Larry Krasner.[4]
A. The Gilded Age and Progressivism
Fears of corporate influence in the political process are not a new phenomenon. The Gilded Age was an era in American history marked by economic and social crises stemming from the rise of industrial capitalism.[5] Cities became polluted and overcrowded, employees were severely underpaid and worked in treacherous environments, and the gap between the working and upper classes widened substantially.[6] Moreover, U.S. polling places throughout much of the 19th century resembled an “open auction place,” where voters were threatened and bribed, and their votes were openly bought or coerced.[7] American society was characterized chiefly by a plutocratic structure dominated by wealthy industrialists like Andrew Carnegie and John D. Rockefeller.[8]
Progressivism emerged out of the resulting dismay with American society and defined the late 19th and early 20th centuries.[9] Along with the adoption of the secret ballot, this era ushered in change that resulted in the adoption of the 16th, 17th, 18th, and 19th amendments.[10] Progressivism was a wide-reaching movement that took many forms, but one of its most pronounced reform efforts concerned the rise of corporate power and influence in American society.[11] Rather than denounce the existence of large corporations, the movement sought to mitigate its worst effects on individuals, communities, and the political system.[12]
President Theodore Roosevelt spearheaded the national progressive movement and successfully implemented several reforms to American society, including workers’ compensation and food and drug inspections.[13] Roosevelt’s famous “Square Deal” sought to “equalize the power imbalance between corporations and common people” with the underlying philosophy of fair play and egalitarianism.[14] Historians have since condensed the Square Deal into three goals: consumer protection, conservatism, and corporate regulation.[15] Roosevelt famously stated that we must “prohibit the use of corporate funds directly or indirectly for political purposes.” He criticized the system’s cultivation of a “small class of enormously wealthy and economically powerful men, whose chief objective is to hold and increase their power” and attributed it to the “political domination of money.”[16] Roosevelt passed the Tillman Act in 1907, the first piece of campaign finance legislation, prohibiting direct corporate contributions to federal candidates.[17]
B. The Voting Rights Act on Paying Citizens to Vote
The Civil Rights Movement ushered in greater change to American society. One of the chief vessels for substantial reform came from the Voting Rights Act of 1965 (“VRA”). The VRA, a landmark piece of legislation, outlawed a number of egregious voting practices like literacy tests.[18] The VRA also criminalized voter intimidation, threats, and bribery, and established safeguards now seen as hallmarks of American democracy.[19] For example, Section 10307 of the VRA makes it a federal crime to pay or offer to pay an individual to vote or register to vote.[20] The punishment for violating Section 10307 is a $10,000 fine and five years of imprisonment.[21] This provision has been broadly interpreted, with the Department of Justice (“DOJ”) finding that “anything having monetary value” constitutes a bribe under the statute, including “lottery chances.”[22]
Corporations like Ben & Jerry’s, Starbucks, and Krispy Kreme have been found liable for violating Section 10307 of the VRA.[23] In 2008, Ben & Jerry’s ran a promotion that offered everyone wearing an “I Voted” sticker on Election Day a free ice cream cone.[24] The DOJ sent Ben & Jerry’s a cease and desist letter and Ben & Jerry’s changed their promotion to give anyone wearing any type of sticker on Election Day a free ice cream cone.[25] These nonpartisan promotions have been constituted as a plainly illegal incentive to vote.[26]
C. Campaign Finance Jurisprudence
The Supreme Court decided the landmark federal campaign finance decision Buckley v. Valeo in 1976.[27] Put plainly, the Court decided in Buckley that money is a form of speech. The Court rejected the notion that campaign finance regulations regulate conduct rather than speech because of the inevitable impact such regulations have on political speech.[28] Consequently, campaign finance regulations are subject to the intense scrutiny that comes with First Amendment challenges.[29] Buckley upheld contribution restrictions while striking down campaign spending restrictions.[30] The outcome of the case therefore turned on the difference between campaign contributions and campaign expenditures. The Court reasoned that the former is a valid mechanism to control quid pro quo corruption, while the latter is not.[31] Campaign spending is not considered a corruption issue because there is no transaction between a donor and a candidate, and therefore there is no potential for a quid pro quo deal.[32]
Thirty-one years after deciding Buckley, the Supreme Court decided FEC v. Wisconsin Right to Life, Inc. In 2002, Congress passed the Bipartisan Campaign Reform Act (the “Act”) to restrict unlimited soft money donations and separate advocacy from campaign advocacy.[33] In addition to prohibiting all independent expenditures by corporations and unions, The Act prohibited “electioneering communications” –– political advertisements explicitly referring to a candidate broadcast within 30 days of a primary or 60 days of a general election.[34] In FEC v. Wisconsin, the Court ruled that the Act was an unconstitutional regulation of advertisements that do not expressly advocate for or against a candidate.[35]
Buckley and FEC v. Wisconsin laid the groundwork for the controversial, landmark decision Citizens United v. FEC in 2010. The Court ruled 5-4 that the Act’s prohibition of independent corporate and union expenditures violated First Amendment protection of free speech.[36] This ruling opened the door for corporations to spend unlimited money on elections, so long as that money is spent “independently” of the candidate.[37]
D. Super PACs
Political Action Committees (“PACs”) are organizations that pool campaign contributions for or against a given candidate.[38] Following Citizens United, corporations were no longer limited in the amount of money they could contribute to PACs, and “super PACs” were born.[39] Super PACs allow an organization to receive unlimited contributions to support a candidate that best serves their interests.[40] Citizens United and the subsequent creation of super PACs have quickly affected elections in the United States. Just two years after Citizens United, super PACs spent $609 million on U.S. elections.[41] The 2024 election cycle marks 14 years since Citizens United and super PACs spent $2.7 billion on U.S. candidates.[42]
Musk’s America PAC was organized as a super PAC and, thus, may receive unlimited contributions.[43] Following Citizens United, the Federal Election Commission (“FEC”) ruled that a PAC’s on-the-ground canvassing for, and in coordination with a political party is legal.[44] This ruling extended the power of PACs from only being able to independently source funding allowing them to coordinate directly with a political party to canvas for them. Following this ruling, Musk created America PAC and acted as the Trump campaign’s primary canvassing organizer in 2024.[45] America PAC has since spent over $171 million on independent expenditures for Republicans, mainly President-elect Donald Trump, and against Democrats, primarily Vice President Kamala Harris.[46] Although this article focuses on Musk’s contributions to the Republican Party, super PAC involvement in politics is decisively a nonpartisan issue. For example, Super PAC Future Forward USA Action donated $136 million to the Harris campaign alone.[47] Musk and his super PAC are therefore representative of a more significant trend of the rising levels of money in politics.
E. Pennsylvania Lawsuit Against Musk
Philadelphia District Attorney Larry Krasner filed suit against Musk on October 28th, 2024, calling his giveaway an “illegal lottery scheme.”[48] Krasner alleged that the lottery rules are “deceptive,” and highlighted that nearly half of the winners of this “random” lottery have not only been from Pennsylvania — a critical state in the 2024 election — but have been present at rallies where their victory is announced.[49] The suit did not focus on election bribery, but rather a violation of Pennsylvania lottery and consumer protection laws.[50] Chris Young, America PAC’s director, testified that the lottery was not random and that he was surprised to hear Musk describe it as such.[51] The winners were chosen based on video submissions, asked to sign a contract as a paid spokesperson for America PAC, and signed non-disclosure agreements preventing them from speaking of the contract’s terms.[52]
Although the legal reasoning has not been made public yet, the judge ruled on November 4, 2024, the day before the election, that the contest was not an illegal lottery.[53] The judge’s ruling was a blow to those hopeful that the lottery’s legality may successfully be challenged on non-campaign finance grounds. David Kass, executive director of Americans for Tax Fairness, called Musk’s lottery “one of the most obvious and disturbing consequences of the growth of billionaire fortunes” and sees its legality as a “prime indicator that the system regulating campaign finance has collapsed.”[54] If something marketed as a lottery, but was admitted to being non-random does not constitute deception, it is tough to imagine a non-campaign finance related state law that would hinder future similar actions.
III. Discussion
Election law scholar Rick Hasen believes that Musk’s giveaway is “clearly illegal.”[55] Others believe that Musk is taking advantage of a legal loophole by paying individuals to sign a petition, with registering to vote in a decisive swing state being merely a requirement for eligibility.[56] In response to Pennsylvania Governor Josh Shapiro expressing deep concern over Musk’s giveaway and stating that it is something law enforcement “could” look into, Musk wrote on X that it is “concerning that [Shapiro] would say such a thing.”[57] Musk is certainly free to donate as much money as he wants to whomever he pleases, but offering one million dollars to swing-state voters crosses the line from protected political speech to voter coercion.
A. Considering Context (Or Not)
Musk and his defenders are framing the issue as merely rewarding voters for signing a petition supporting the Constitution.[58] Facially, this does not seem to run awry of any campaign finance laws. A mere second glance, though, shows that there is far more attached to this PAC petition than signaling support for the freedom of assembly. Only registered voters in swing states are eligible for the giveaway, which ends on election day and is being run by a political organization responsible for over $171 million in contributions to a single candidate.[59] Musk’s intention behind the giveaway is clear: to entice eligible unregistered voters in decisive districts to cast their vote for Musk’s preferred candidate. If one could, say, pierce the political veil, Musk’s giveaway would constitute a lottery to entice voter registration, a clear violation of Section 10307. As such, both Musk’s defenders and opposition seem correct. The giveaway appears to take full advantage of a legal loophole, while the intentions behind the giveaway amount to election bribery.
If a court were to take the giveaway at face value, it would likely be upheld as a legal PAC action. However, there is still an argument that the giveaway is illegal on its face. The explicit limitation on eligibility to registered voters in swing states itself calls for an interpretation of what constitutes payment for registering to vote under Section 10307. There have been instances of people and organizations giving money to encourage voter registration. However, those efforts were given to organizations supporting general mobilization, not directly to voters.[60]
The broad interpretation of 10307 could also pose a similar issue for Musk as it did for Ben & Jerry’s in 2008. Ben & Jerry’s Election Day promotion that gave a free ice cream cone to anyone wearing an “I Voted” sticker constituted a clear violation of 10307 because Ben & Jerry’s was explicitly rewarding voting.[61] Although Musk’s intent is clear, his means are not as explicit as Ben & Jerry’s. Rather than rewarding voters because they voted, Musk is rewarding certain registered voters who sign a petition. The Director of the Brennan Center’s Elections & Government Program stated that the issue will come down to “whether entering a specific group of people in a contest if they sign a petition counts as paying people to register to vote.”[62]
B. What Musk Can Gain and What He Can Give
Musk has everything to gain from a second Trump term. Trump tapped Musk to co-lead the “Department of Government Efficiency” to regulate government spending.[63] This statement came despite Musk holding $3.6 billion in sensitive military contracts with the U.S. government while also retaining commercial investments in China and having telephone conversations with Putin on numerous occasions.[64] Moreover, Musk openly expressed his desire for a Trump presidency because his policies are most likely to maximize the profit of and reduce regulatory burdens on his companies.[65] Moreover, if Musk’s one million dollar giveaway is eventually found in violation of campaign finance laws, legal scholars have suggested that Musk will be “in much less trouble in a Trump administration” than he would have been under a Harris administration.[66]
The Department of Government Efficiency (DOGE) could bring about positive change. Both Democrats and Republicans believe the government is incredibly inefficient. President Obama unsuccessfully attempted to reorganize and consolidate the government and now President-Elect Trump plans to create DOGE to tackle the issue.[67] Musk is a successful businessman with the potential to bring about change in an area that desperately needs reform. Those statements would be foolish to debate, as would his ability to donate money to a presidential campaign in a post-Citizens United world. The precedent that Musk’s lottery and his subsequent rise to power in the U.S. government is the concern being raised.
C. Implications for PACs, Politics, and the Nation Going Forward
Musk’s involvement in the 2024 election and the direct utilization of his staggering wealth to influence its outcome exemplifies how the American political system is entrenching itself in a borderline kleptocratic regime. Elections are increasingly expensive, with the cost of the federal races this year amounting to nearly $16 billion.[68] Super PACs ran by the cryptocurrency industry poured $40 million into Bernie Moreno’s successful campaign against Ohio Senator Sherrod Brown alone.[69] After Moreno, a pro-cryptocurrency candidate was announced the winner of the Senate race, a spokesman for a crypto super PAC mass sent out an email with the subject line: “Crypto’s big bet pays off.”[70] Super PACs continue to make races more expensive, as wealthy individuals like Musk give more money each year to influence American politics.
Democratic and Republican Congressmen have criticized the level of money involved in our political system, in fact, they passed the Bipartisan Campaign Reform Act in an attempt to regulate money in politics. In response, the Supreme Court legalized unlimited corporate independent expenditures. [71] Whether the Supreme Court was correct in its Citizens United holding is irrelevant to the current discussion; it is the state of the law either way. It can be said, though, that billionaires directly paying voters based on a legal loophole is a step too far. Buckley, FEC v. Wisconsin, and Citizens United all concern the value of speech despite it taking the form of money and despite it coming from a corporation. Musk’s lottery goes past mere speech and falls into the category of coercion. A First Amendment test should not govern his lottery; rather it should be seen for what it is, an egregious violation of Section 10307 of the VRA covering itself with a First and Second Amendment petition wrapping.
If individuals like Musk are deemed able to directly pay voters based on a legal loophole, the implications would be astounding. The costs of political races would exponentially grow, making the average citizen’s contribution even more negligible. The number of PACs would grow alongside their contributions, and politicians would be even more compelled to pass legislation to benefit the wealthy donors, appoint them to government positions, and keep them out of legal trouble. This is exactly the situation President Theodore Roosevelt fought relentlessly to prevent in the face of a rapidly changing economy and society.
IV. Conclusion
If courts determine that Musk’s giveaway does not violate federal law, a plausible outcome, it will be imperative for Congress to expand the scope of the VRA. Loopholes like the one Musk is taking advantage of render well-meaning legislation futile and disrupt the efficacy of the legal system. The United States cannot undo the plutocratic structure it has created, but it can refrain from descending further into a kleptocratic regime. Upholding Musk’s sweepstakes without reform would come at a severe cost to the American political system and, consequently, the non-billionaires of the nation.
[1] Alana Wise, Philadelphia DA sues Elon Musk Over $1 Million Giveaway to Registered Voters, NPR (Oct. 28, 2024, 4:54 PM), https://www.npr.org/2024/10/28/g-s1-30423/philadelphia-da-sues-elon-musk-over-1-million-giveaway-to-registered-voters.
[2] Zachary Basu, Billionaires’ New Playground, Axios (Oct. 31, 2024), https://www.axios.com/2024/10/31/billionaires-election-spending-trump-musk-bezos.
[3] Id.
[4] Alison Durkee, Philadelphia DA Sues Elon Musk’s Pro-Trump PAC Over $1 Million Giveaway, Forbes (Oct. 28, 2024, 10:37 AM), https://www.forbes.com/sites/alisondurkee/2024/10/28/philadelphia-da-sues-elon-musks-pro-trump-pac-over-1-million-giveaway/.
[5] Kirsten Swinth, The Square Deal: Theodore Roosevelt and the Themes of Progressive Reform, The Gilder Lehrman Institute of American History, https://www.gilderlehrman.org/history-resources/essays/square-deal-theodore-roosevelt-and-themes-progressive-reform (last visited Nov. 23, 2024).
[6] Id.
[7] Doe v. Reed, 561 U.S. 186, 226 (2010) (Scalia, J., concurring).
[8] Chuck Collins & Sam Pizzigati, A Century Later, Teddy Roosevelt’s Speech on Corporate Power, Institute for Policy Studies (Aug. 30, 2010), https://ips-dc.org/a_century_later_teddy_roosevelts_speech_on_corporate_power/.
[9] Swinth, supra note 5.
[10] Rideout v. Gardner, 123 F.Supp.3d 218, 224-25 (2015).
[11] Swinth, supra note 5 (Certain sects of progressivism supported reprehensive ideas and causes like eugenics and literacy tests.)
[12] Id.
[13] Id.
[14] The Square Deal, Theodore Roosevelt Center, https://www.theodorerooseveltcenter.org/Learn-About-TR/TR-Encyclopedia/Politics%20and%20Government/The%20Square%20Deal (last visited Nov. 23, 2024).
[15] Id.
[16] Collins, supra note 8.
[17] Jason S. Campbell, Down the Rabbit Hole with Citizens United: Are Bans on Corporate Direct Campaign Contributions Still Constitutional?, 45 Loy. L.A. L. Rev. 171 (2011).
[18] Milestone Documents: Voting Rights Act (1965), National Archives (Feb. 8, 2022), https://www.archives.gov/milestone-documents/voting-rights-act.
[19] Rideout v. Gardner, 123 F.Supp.3d 218, 226 (2015).
[20] 52 U.S.C. § 10307(c).
[21] Id.
[22] Department of Justice, Federal Prosecution of Election Offenses: Eighth Edition (December 2017), 44.
[23] Ellen Ioanes, Elon Musk Says He’s Giving Away $1 Million a Day to Voters. Is That Legal?, Vox (Nov. 4. 2024), https://www.vox.com/politics/378912/musk-trump-voting-contest-million-dollars-swing-state-lottery-pennsylvania.
[24] Byron Tau, Voting-Related Giveaways Clash with Federal Law, Politico (Nov. 5, 2012), https://www.politico.com/blogs/under-the-radar/2012/11/voting-related-giveaways-clash-with-federal-law-148481.
[25] Ioanes, supra note 23.
[26] Id.
[27] Buckley v. Valeo, 424 U.S. 1 (1976).
[28] Burt Neuborne, Campaign Finance Reform & the Constitution: A Critical Look at Buckley v. Valeo at 13, Brennan Center for Justice (1998), https://www.brennancenter.org/sites/default/files/legacy/d/cfr1.pdf.
[29] Id. at 7.
[30] Id.
[31] Id. at 14.
[32] Id.
[33] Dan McCue, George Washington to Citizens United: A History of Campaign Finance Reform, Common Cause (May 21, 2019), https://www.commoncause.org/articles/george-washington-to-citizens-united-a-history-of-campaign-finance-reform/.
[34] Id.
[35] Id.
[36] Id.
[37] Tim Lau, Citizens United Explained, Brennan Center for Justice (Dec. 12, 2019), https://www.brennancenter.org/our-work/research-reports/citizens-united-explained.
[38] Will Kenton, Political Action Committee (PAC): Definition, Types, Super PACs, Investopedia (Oct. 24, 2024), https://www.investopedia.com/terms/p/political-action-committee-super-pac.asp.
[39] Ian Vandewalker, Since Citizens United, a Decade of Super PACs, Brennan Center for Justice (Jan. 14, 2020), https://www.brennancenter.org/our-work/analysis-opinion/citizens-united-decade-super-pacs.
[40] Political Action Committees (PACs), Federal Election Commission, https://www.fec.gov/press/resources-journalists/political-action-committees-pacs/ (last visited Nov. 27, 2024).
[41] Outside Spending: Total by Type of Spender, 2012, OpenSecrets, https://www.opensecrets.org/outside-spending/summary?cycle=2012 (last visited Nov. 27, 2024).
[42] Outside Spending: Total by Type of Spender, 2024, OpenSecrets, https://www.opensecrets.org/outside-spending/summary?cycle=2024 (last visited Nov. 27, 2024).
[43] Alison Durkee, DOJ Reportedly Warns Elon Musk His $1 Million Voter Giveaways May Be Illegal, Forbes (Oct. 23, 2024, 3:20 PM), https://www.forbes.com/sites/alisondurkee/2024/10/23/doj-reportedly-warns-elon-musk-his-1-million-voter-giveaways-may-be-illegal/.
[44] Jonathan S. Berkon et al., Advisory Opinion 2024-01, Federal Election Commission (March 20, 2024), https://www.fec.gov/files/legal/aos/2024-01/2024-01.pdf.
[45] Durkee, supra note 4.
[46] America PAC (Texas) Recipients, 2024, OpenSecrets (Nov. 5, 2024),https://www.opensecrets.org/outside-spending/detail/2024?cmte=C00879510&tab=targeted_candidates.
[47] Top Contributors, Federal Election Data for Kamala Harris, 2024 Election Cycle, OpenSecrets, https://www.opensecrets.org/2024-presidential-race/kamala-harris/contributors?cycle=2024&id=N00036915&src=o&type=f (last visited Nov. 27, 2024).
[48] Marshall Cohen, Philadelphia DA Sues Elon Musk and His Super PAC Over $1M Sweepstakes, CNN (Oct. 28, 2024, 5:40 PM), https://www.cnn.com/2024/10/28/politics/elon-musk-philadelphia-lawsuit/index.html.
[49] Id.
[50] Id.
[51] Jack Queen, Pennsylvania Judge Allows Elon Musk’s $1 Million Voter Giveaway, Reuters (Nov. 4, 2024, 7:19 PM), https://www.reuters.com/legal/judge-weighs-challenge-elon-musks-1-million-voter-giveaway-2024-11-04/.
[52] Id.
[53] Id.
[54] Richard Luscombe, Pennsylvania Judge Declines to Block Elon Musk’s $1m voter Prize Giveaway, The Guardian (Nov. 4, 2024), https://www.theguardian.com/us-news/2024/nov/04/elon-musk-giveaway-winners-lawsuit.
[55] Rick Hasen, Elon Musk Veers Into Clearly Illegal Vote Buying, Offering $1 Million Per Day Lottery Prize Only to Registered Voters, Election Law Blog (Oct. 19, 2024), https://electionlawblog.org/?p=146397.
[56] Sam Cabral et al., Musk is Giving Some US Voters $1M. Is it Legal?, BBC News (Oct. 22, 2024), https://www.bbc.com/news/articles/ced0d1g5zyno
[57] Id.
[58] Id.; Emma Colton, Here’s How Elon Musk’s $1M a Day Giveaway to Battleground Voters Works, Fox News (Oct. 21, 2024, 12:09 PM), https://www.foxnews.com/politics/heres-how-elon-musks-1-million-day-give-away-battleground-voters-works.
[59] Wise, supra note 1; OpenSecrets, America PAC (Texas) Recipients, supra note 46.
[60] Cabral, supra note 56.
[61] Tau, supra note 24.
[62] Ioanes, supra note 23.
[63] Elena Moore et al., Trump Taps Musk to Lead a ‘Department of Government Efficiency’ with Ramaswamy, NPR (Nov. 12, 2024, 9:03 PM), https://www.npr.org/2024/11/12/g-s1-33972/trump-elon-musk-vivek-ramaswamy-doge-government-efficiency-deep-state.
[64] David Ingram et al., Elon Musk Could Be the Biggest Winner of a Second Trump Term, NBC News (Nov. 5, 2024, 9:36 AM), https://www.nbcnews.com/tech/tech-news/elon-musk-trump-endorses-pac-administration-cabinet-connection-rcna178549.
[65] Id.
[66] Id.
[67] President Obama Announces Proposal to Reform, Reorganize and Consolidate Government, The White House Office of the Press Secretary (Jan. 13, 2012), https://obamawhitehouse.archives.gov/the-press-office/2012/01/13/president-obama-announces-proposal-reform-reorganize-and-consolidate-gov.
[68] Fredreka Schouten, Spending in Presidential and Congressional Races Projected to Hit Nearly $16 Billion and Smash Records, New Analysis Shows, CNN (Oct. 8, 2024, 9:00 AM), https://www.cnn.com/2024/10/08/politics/2024-election-most-expensive/index.html.
[69] David Yaffe-Bellany, The Crypto Industry Spent Over $130 Million on the Election. It Paid Off., N.Y. Times (Nov. 8, 2024), https://www.nytimes.com/2024/11/06/technology/crypto-industry-spending-election.html.
[70] Id.
[71] Citizens United v. FEC, 558 U.S. 310 (2010).
Cover Photo by Clay Hensley on Flickr.
