Updated 12/16/14, 5:15 p.m.

The organization that appears to be behind a majority of the recent anti-net neutrality comments filed with the Federal Communications Commission is affiliated with the Koch brothers’ network.

Sunlight’s latest analysis of recent comments on the FCC’s controversial proposed Internet regulations found that, unlike in an earlier round, most of them were opposed to net neutrality – and that “the form-letter initiatives of a single organization, American Commitment, are single-handedly responsible for 56.5 percent of the comments in this round.”

American Commitment, a 501(c)(4) social welfare group founded in 2011, has gotten money from and given money to a variety of groups with ties to Charles and David Koch, mega-wealthy siblings who have underwritten many conservative campaigns and candidates. American Commitment’s president, Phil Kerpen, was the vice president for policy for five years at Americans for Prosperity, another Koch-underwritten nonprofit.

In a Sept. 17 blog post, Kerpen explained that his group set up a website called StopInternetRegulation.org to “mobilize comments from regular Americans” on the Federal Communications Commission’s site. StopInternetRegulation.org, which has been taken down but is viewable through the Internet Archive, hosted an anti-net neutrality form letter. The bottom of the website states it is a “project of American Commitment.”

Kerpen’s post about StopInternetRegulation.org boasted:

When all was said and done, the huge liberal pro-regulation campaign, which dubbed itself “Battle for the Net” claimed they sent 777,364 comments to the FCC. StopInternetRegulation.org, in just three weeks, beat them by more than 30,000 comments. Our total was 808,363. We won the battle for the net.

Kerpen has deep ties to the Kochs. In addition to his time at Americans for Prosperity, Kerpen worked at Free Enterprise Fund, Club for Growth and the Cato Institute. He is also the head of the Internet Freedom Coalition, a group of 67 organizations that “share a desire to keep the Internet free from government interference.” The “Take Action” page on the coalition’s website links to an Americans for Prosperity page titled “Tell Congress to Stop the FCC Internet Takeover.”

From April to December in 2012, Kerpen received $174,000 in salary as the president of American Commitment. That year’s 990 form, which tax-exempt organizations have to file annually with the Internal Revenue Service, also indicates that Sean Noble was the director of the group during the first half of 2012, but did not receive any compensation.

According to its website, the group is “dedicated to restoring and protecting the American Commitment to free markets, economic growth, constitutionally limited government, property rights, and individual freedom.” The group does “direct advocacy, strategic policy analysis, and grassroots mobilization.”

On American Commitment’s “Issues” page, Internet regulation is listed under the “Protect the Free-Market Internet” tab. The page also lists topics like speech freedom, regulation, tax code, property rights, health care, energy, economic growth and limited government.

American Commitment’s 990 form from 2012 states that it received $11,722,579 in contributions and grants. The organization is not required to make its donors public, so it is not possible to ascertain exactly where that $11.7 million came from.

While nonprofit organizations do disclose the identities of donors to the IRS on Schedule B of the 990s, that information is redacted when the forms are made public. On page 14 of this document, for example, the identifying information has been whited out and replaced with the words “public inspection copy.”

The only way to learn about the source of American Commitment’s funds is by triangulation: Because nonprofits do have to disclose to whom they give grants and contributions, a look at the 990s of other tax exempt groups proved educational. These records, many turned up by other organizations’ reporting, reveal how deeply American Commitment is embedded in the Koch empire, as well as a link to one trade association that has been actively working against net neutrality.

• Freedom Partners Chamber of Commerce’s 990 from 2011 showed that it gave $6.26 million to American Commitment. (Freedom Partners’ fiscal year starts every November, so that grant shows up on American Commitment’s 2012 tax form.)
• In 2012, the Center to Protect Patient Rights gave American Commitment $4,781,559, according to the former’s 990 form. That $4.7 million grant to American Commitment was a sliver of the more than $100 million that the Center to Protect Patient Rights doled out to conservative groups in 2012. The center is run out of a Phoenix post office box by Noble, who is listed as the organization’s president, treasurer and executive director. Noble has been a key player in the Koch enterprise, funneling millions of dollars collected by various Koch-affiliated organizations into conservative groups.
• American Commitment also got a $25,000 grant in 2012 from Pharmaceutical Research & Manufacturers of America, or PhRMA, and $300,000 from Americans for Responsible Leadership. Americans for Responsible Leadership is the Phoenix-based group responsible for a “campaign money laundering” case in California. The group made an $11 million contribution to a campaign committee in the Golden State and did not divulge that it was an intermediary for the donation and not the initial source of the money.
• The National Cable & Telecommunications Association, the primary trade association for the cable industry, gave American Commitment $10,000 in 2012, according to a Center for Public Integrity article. And tax forms from 2013 indicate that NCTA gave American Commitment another $10,000 that year. A Sunlight analysis of lobbying data on net neutrality showed that, in 2012, NCTA spent $18,890,000 lobbying against net neutrality.

American Commitment received $1,023,339 in grants and contributions in 2013, according to the group’s most recent 990 form. As with previous 990s, donors are not identified, although the document’s Schedule B shows the group got two $150,000 contributions, one $140,000 contribution and one $100,000 contribution, in addition to multiple five-figure gifts.

Last year, the group handed out $135,000 in grants to four other tax-exempt groups. American Future Fund – an Iowa-based nonprofit that advocates a “conservative and free-market viewpoint,” according to its website – got the largest contribution, at $65,000. It is another Koch-connected organization: In 2012, it got 92 percent of its funding from the Center to Protect Patient Rights and Freedom Partners Chamber of Commerce, according to a Center for Responsive Politics article.

The other three beneficiaries are conservative organizations that focus on social issues like same-sex marriage and abortion. New Jersey Family First received $30,000, while FRC Action – the lobbying arm of the Family Research Council – got $28,000.

Catholic Advocate got another $12,000. According to its website, the D.C.-based 501(c)(4) engages “faithful Catholics to actively participate in the political process to support elected officials and policies that remain consistent with the teachings of the Catholic Church.” It released an e-book in 2012 titled “Issues for Catholic Voters,”, and the “Voter Guide” page on its website calls out specific issues and Catholic teaching on each topic.

The grants to the latter groups mark a departure in where American Commitment sends its cash. It is the organization’s first foray into social issues, since it has been focused primarily on fiscal issues and regulation.

Whether other corporate interests allied with the anti-net neutrality effort provided more recent grants to American Commitment is unknown. That’s because 990s are filed once a year with the IRS and reveal financial activity from the year prior. American Commitment’s 2012 document, for example, shows activity from that year and was filed in November 2013. As a result of that disclosure lag time, American Commitment’s finances from 2014 will not be made public until at least 2015.

In 2011, American Commitment reported revenue of $216,500. However, a recent article showed that Noble’s Center to Protect Patient Rights gave $1.6 million to American Commitment that same year, which was not reported on American Commitment’s tax forms.

The Noble-headed group Free Enterprise America (which dissolved in May 2012) gave $103,000 to American Commitment in 2011. The last page of Free Enterprise America’s 2011 990 form states that the “organization was initially called American Commitment and was created in 2010. It had no activity in 2010, no revenues or expenses, and no return was therefore filed.”

In 2011, American Commitment wrote checks to two 501(c)(4) groups. It gave $70,250 to Americans for Responsible Leadership and $40,000 to All Votes Matter, a Pennsylvania nonprofit that lobbied officials on a bill that would change how the state doles out its Electoral College votes in presidential contests. In 2012, American Commitment reported making no grants.