We already examined [Clinton’s biggest super PAC supporters earlier this week](http://sunlightfoundation.com/blog/2015/12/01/super-pacs-dark-money-and-the-hillary-clinton-campaign-part-1/), Priorities USA Action and Ready PAC, plus her official campaign PAC. Now we’re going to dive deeper into the dark money supporting Clinton: the money in groups that don’t have to disclose their donors, and the money that moves from those groups to super PACs that support Clinton.

The groups we’re looking at here are all founded by David Brock, a Clinton [enemy-turned-ally](http://www.nytimes.com/2015/09/27/books/review/david-brocks-killing-the-messenger.html) who runs a number of liberal super PACs and nonprofits. Some of these groups are directly supporting her; others aren’t, but have donated to the groups that do support her. In addition to the groups we’ve outlined here, Brock is also on the board of Priorities USA, and he’s president of a group called the [American Independent Institute](http://www.politico.com/blogs/media/2014/06/david-brock-to-launch-journalism-institute-190746), which funds “individual journalism projects, with an emphasis on exposing the nexus of conservative power in Washington.” Just a few weeks ago, Brock bought the progressive news site [Blue Nation Review](http://www.huffingtonpost.com/entry/david-brock-blue-nation-review_564f0f3de4b0879a5b0a7bc5?jedygb9), which will now be headed by Peter Daou, Clinton’s former digital strategist and founder of the Hillary Men project. In 2014, Brock became chairman of the board of the ethics watchdog Citizens for Responsibility and Ethics in Washington (CREW), which is now located at the same offices as all the groups listed below.

All the groups listed below are located in the same offices: 455 Massachusetts Avenue NW, Washington, D.C.

For this post, we used Sunlight’s [Real-Time Influence Explorer](http://realtime.influenceexplorer.com/newest-filings/#?ordering=-filing_number&time_range=2016_cycle), which allows you to view campaign filings as soon as they hit the Federal Election Commission. We also looked at various groups’ IRS 990 forms, which often only become available more than a year after they’re filed.

American Bridge 21st Century (super PAC)

Brock established American Bridge 21st Century in 2010. Much of its activity comes in the form of opposition research against Republican candidates — for example, [a recent post](https://americanbridgepac.org/in-academia-as-in-the-senate-marco-rubio-failed-to-meet-his-obligations/) on its website attacks Marco Rubio’s record as an instructor at Florida International University. It also [sends trackers to follow Republican candidates](http://www.thenation.com/article/how-david-brock-built-empire-put-hillary-white-house/) on the campaign trail, recording “almost every public utterance by prominent Republican politicians, using both DC-based researchers and a national network of professional trackers.” So far this cycle, it has raised $6.2 million and spent $5.2 million. While it has spent on races in the past, it hasn’t directly spent on any races so far this cycle. Most of its major expenses this year have been on staff and fundraising.

Until May 2015, Bridge had several staff dedicated solely to pushing back on attacks against Clinton as part of a project called Correct the Record, but that split off as a separate super PAC. This division of labor — opposition research at Bridge, pro-Clinton defensive work at Correct the Record — has been [described by Brock himself](http://time.com/4028459/david-brock-hillary-clinton-media-matters/), discussing his decision to leave Bridge for Correct the Record:

I essentially had to make a decision. Do I want to be involved in supervising and handling the research against the Republican candidates? … Or do I want to be involved in some combination of defense and offense for Hillary Clinton?

Notable donors this cycle to Bridge include American Bridge 21st Century Foundation (more on that in a minute), which gave $1.2 million; philanthropists George Soros and Steve Silberstein, who gave $1 million and $200,000, respectively. NextGen Climate Action Committee also [contributed $250,000](http://realtime.influenceexplorer.com/filings/1020146/SA/#C10571142). We’ve written extensively about how this 501(c)(4) is funded almost entirely by hedge fund manager and environmentalist [Tom Steyer](https://sunlightfoundation.com/blog/tag/tom-steyer/).

American Bridge has paid the executive vice president of Media Matters, Angelo Carusone, $3,000 a month for management consulting since January 2014.

American Bridge 21st Century Foundation (501(c)(4))

American Bridge 21st Century Foundation is another 501(c)(4) organization, also known as a dark money group. It runs [Bridge Project](http://bridgeproject.com/about/), which says it’s “dedicated to opposing the conservative movement’s extreme ideology and exposing its dishonest tactics.” The site has a database, “Conservative Transparency,” that allows users to search for conservative donors, recipients and organizations. Featured donors include the Koch brothers and The Lynde and Harry Bradley Foundation.

The hilarious part (if you find dodging transparency hilarious) is that the group has an entire database for uncovering the money behind conservative causes, documenting spending from their 990s, and blogging about conservative donors, but it does not disclose its own donors on that website, or anywhere else. We reached out to American Bridge for comment on this, and will update this post if we receive anything from them.

On that note: The foundation arm of American Bridge 21st Century has donated a lot of money to the Bridge super PAC, which does have to disclose its donors. In the first six months of 2015, the foundation gave $1.2 million to the super PAC. In 2014, they donated $2.5 million. That’s $3.7 million dollars funneled from the foundation to the super PAC in just the last two years — with donors safe in the knowledge that their names won’t be disclosed to the public.

Correct the Record (super PAC)

Correct the Record was originally part of the American Bridge super PAC, but was spun off in May 2015 to be its own super PAC. It’s headed by Brad Woodhouse, the past president of American Bridge 21st Century and former communications director of the Democratic National Committee. Correct the Record is located in the same offices as Media Matters and American Bridge; as [National Journal pointed out](http://www.nationaljournal.com/s/70878/meet-man-whos-making-super-pacs-extra-super), “When long­time Demo­crat­ic op­er­at­ive Brad Wood­house left his job head­ing one su­per PAC to lead an­oth­er, he didn’t even change desks.” Most of Correct the Record’s staff used to work at the super PAC arm of American Bridge, according to FEC filings.

The FEC has stated that it only regulates Internet activity when it is “communication placed on another person’s website for a fee.” So, Correct the Record says it actually can communicate with the campaign because all of its activity is on its own website. (This underscores the so-called [“Internet “blind spot”](https://sunlightfoundation.com/blog/2015/11/06/as-campaign-ads-move-online-the-public-gets-left-in-the-dark/) that we pointed out a couple weeks ago.)

In theory, Correct the Record could coordinate with the campaign, then coordinate with the other super PACs. We don’t know if that is true, and even if it was, it’s doubtful the FEC would do anything about it. But Campaign Legal Center’s Paul Ryan has [described the group’s activity](http://time.com/4028459/david-brock-hillary-clinton-media-matters/) as “creating new ways to undermine campaign regulation.”

The New York Times [has reported](http://www.nytimes.com/politics/first-draft/2015/07/17/david-brock-key-hillary-clinton-ally-to-work-more-closely-with-her-campaign/) that Brock, who officially left American Bridge for Correct the Record when it was formed, is “focused on paying attention to the activities of Correct the Record and Media Matters, which will play the biggest role in defending Mrs. Clinton throughout the campaign.”

Since it was formed in May, Correct the Record has raised $1.4 million from some of the same donors as American Bridge — big donors Steve Silberstein, Joan Cooney and Barbara Lee have donated to both. Correct the Record was only active for about a month before its first and only FEC filing, so we’ll know more about their finances in January. (Yes, super PACs go six months without divulging donor information some years.) The Clinton campaign itself is Correct the Record’s [single biggest contributor](http://realtime.influenceexplorer.com/filings/1020148/SA/#C6865882), at $275,615.

Correct the Record also has a joint fundraising committee with Priorities USA, called [American Priorities](http://realtime.influenceexplorer.com/committee/2016/american-priorities-joint-fundraising-committee/C00519918/), but it’s raised no money and spent only $1,200.

Franklin Forum (PAC)

[The Franklin Forum](http://thefranklinforum.org/about-us/) is a nonprofit “communications organization that provides media training and support, including message development and speaker promotion, to strengthen top progressive messengers and messaging.”

They also have a PAC, Franklin Forum PAC, which raises money from several of the same donors as American Bridge: Paul Egerman, Barbara Lee and Stephen Silberman have donated to both. The PAC’s single biggest expense was $60,000 given to American Bridge, which supports Clinton, in November 2014, and spent directly on a few races in 2014: Mark Warner, Ami Bera and Shenna Bellows’ campaigns all received contributions from the PAC. Most of [their expenses](http://realtime.influenceexplorer.com/filings/1021532/SB/) are in-kind contributions to non-federal candidates.

Media Matters (501(c)(3))

Media Matters For America (MMFA) is a media watchdog organization, “dedicated to comprehensively monitoring, analyzing, and correcting conservative misinformation in the U.S. media,” founded by David Brock in 2004. Since 2013, Bradley Beychok has been president of the organization; he was previously Campaign Director at American Bridge. It’s a 501(c)(3), meaning it can’t conduct political activity on behalf of a candidate. This means MMFA can’t explicitly advocate for Clinton’s election, but it can (and does) publish material about Clinton: for example, posts [criticizing media coverage of her](http://mediamatters.org/research/2015/11/08/major-news-outlets-fail-to-mention-report-debun/206703), or [highlighting positive coverage](http://mediamatters.org/video/2015/03/04/fox-legal-experts-agree-hillary-clinton-did-not/202756). Long-time Clinton adviser James Carville works for them, and fellow Clinton aide Sidney Blumenthal was also [reportedly paid $200,000 a year](http://www.foxnews.com/politics/2015/06/18/sources-clinton-confidant-who-sent-libya-memos-being-paid-200g-by-brock-network.html) by the organization.

Unlike PACs and campaigns, MMFA doesn’t have to disclose its donors or what it pays most of its staff (only executives and top-paid staff) because it’s a 501(c)(3). Correct the Record and American Bridge both pay rent to Media Matters for their office space.

According to its [2013 IRS 990 form](http://assets.sunlightfoundation.com.s3.amazonaws.com/blog/Form%20990%20for%20MEDIA%20MATTERS%20FOR%20AMERICA%202013.pdf), the most recent one available, David Brock draws an annual salary of $280,060 from Media Matters.

American Democracy Legal Fund (527 organization)

The American Democracy Legal Fund is a 527 organization set up in September 2014 to, according to its website bio, “hold candidates for office accountable for possible ethics and/or legal violations.” The group files legal complaints against Republican candidates for violating election law: For example, they [filed a complaint](http://americandemocracy.org/adlf-files-complaint-against-jeb-bush-and-right-to-rise/) with the FEC in October over Jeb Bush’s super PAC, Right To Rise, claiming “illegal coordination” between the campaign and the super PAC.

The group has only received two contributions: $50,000 from American Bridge, and $25,000 from the National Education Association. It’s worth noting that while they’re alleging illegal coordination between GOP campaigns and super PACs, the group is chaired by Brad Woodhouse, president of Correct the Record, which is (supposedly legally) coordinating with the Clinton campaign.

The Bonner Group (nonprofit fundraising firm)

This one is a little different. The Bonner Group is a fundraising consulting firm that raises money for American Bridge and Ready PAC, which we know from FEC filings, and other groups like Media Matters, which was [reported](http://www.nytimes.com/2015/02/06/us/in-invisible-world-of-political-donor-advisers-a-highly-visible-player.html) by The New York Times. Bonner solicits donations for these groups, who then pay Bonner a sizable cut — in the first six months of 2015, American Bridge super PAC paid Bonner $593,007. So we have no idea how much of American Bridge, Media Matters or Ready PAC’s money comes through Bonner Group fundraising, but we do know that Bonner makes a lot of money off it, and that David Brock thinks he’s getting “the best fund-raising product for the lowest cost.” Media Matters’ 2013 990 form reported they paid $1.4 million for fundraising services.

The New York Times report on The Bonner group notes that Brock and Mary Pat Bonner, who runs the Bonner Group, share a house in the Hamptons.

—–

Like we said last time, there’s still a lot we don’t know about these groups’ finances: We won’t have the relevant FEC filings for the second half of 2015 until January. And the 501(c)(4) nonprofits involved in the campaign won’t file 990 forms covering this cycle until likely 2017, well after voters have cast their votes. Even then, we still won’t know who donated to those groups because 501(c)(4)s don’t have to disclose their donors. And while the FEC is gridlocked, any enforcement action is unlikely. All of this leaves voters in the dark about exactly who is spending some pretty big money to support Hillary Clinton.