Fully Executed Letter With Exhibits

Report - Online Campaign Finance
Online Campaign Finance
Amended 3rd Quarter

for CAS- Print Page Download Full Report Home
PAC submitted on 10/15/2018
Beginning Balance
Beginning Balance $135,814.77
Receipts
Monetary Contributions, $0.00
Unitemized
Monetary Contributions,
Itemized
Contributor C/P Date Amount
ABBVIE POLITICAL ACTION COMMITTEE
1 N. WAUKEGAN ROAD
P 09/15/2018 $1,000.00
NORTH CHICAGO
,
IL
60064
BIV-PAC
P.O. BOX 40424

P 08/29/2018 $1,000.00
NASHVILLE
,
TN
37209
CARLISLE
, CHANCELLOR
179 TUCKAHOE LN
MEMPHIS
,
TN
38117
08/03/2018 $1,000.00
BEST EFFORT MADE
BEST EFFORT MADE
https://apps.tn.gov/tncamp-app/search/pub/report_full.htm?reportId=80215[5/14/2019 9:22:32 PM]

CDP ARCHITECTURE
209 10TH AVE S

08/04/2018 $500.00
NASHVILLE
,
TN
37203
CENTURYLINK INC. EMPLOYEES' PAC
1099 NEW YORK AVE. NW, SUITE 250

P 08/04/2018 $1,000.00
WASHINGTON
,
DC
20001
CHARTER COMMUNICATIONS INC., TENNESSEE PAC
1774 HENRY G. LANE STREET

P 08/22/2018 $2,000.00
MARYVILLE
,
TN
37801
EARL SWENSON ASSC
1033 DEMENBRUEN
08/04/2018 $500.00
NASHVILLE
,
TN
37203
ELI LILLY & CO. PAC
LILLY CORPORATE CENTER

P 09/01/2018 $1,000.00
INDIANAPOLIS
,
IN
46285
FARRIS MATHEWS BRANAN BOBANGO & HELLEN PAC
ONE COMMERCE SQUARE, SUITE 2000

P 09/01/2018 $1,000.00
MEMPHIS
,
TN
38103
FRIENDS OF THA
5201 VIRGINIA WAY

P 08/29/2018 $3,500.00
BRENTWOOD
,
TN
37027
GOPAC ELECTION FUND
2300 CLARENDON BLVD

09/01/2018 $5,000.00
ARLINGTON
,
VA
22201
HASTINGS ARCHITECTURE
127 3RD AVE S.

08/04/2018 $250.00
NASHVILLE
,
TN
37211
HCA TRISTAR FUND
1000 HEALTH PARK DRIVE, SUITE 500

P 09/01/2018 $1,000.00
BRENTWOOD
,
TN
37027
JARRETT PAVING
1106 LEBANON PK
09/15/2018 $2,000.00
NASHVILLE
,
TN
37210
LAND TITLE PAC OF TN
414 UNION AVENUE, SUITE 1105

P 09/01/2018 $250.00
NASHVILLE
,
TN
37219
NAT'L HEALTH CORP. PAC
100 VINE ST.

P 08/04/2018 $2,000.00
MURFREESBORO
,
TN
37127
PIEDMONT NATURAL GAS TN CORPORATE
83 CENTURY BOULEVARD
P 08/04/2018 $1,000.00
NASHVILLE
,
TN
37214
PROPANE PAC
611 COMMERCE ST., STE. 2605

P 09/15/2018 $1,000.00
NASHVILLE
,
TN
37203
SAMMONS HOLDING LLC
208 ST.ALBANS FAIRWAY

08/04/2018 $1,000.00
MEMPHIS
,
TN
38111

TDG-PAC
P.O. BOX 158540

P 08/04/2018 $2,000.00
NASHVILLE
,
TN
37215
TENNESSEE APARTMENT PAC
2 INTERNATIONAL PLAZA, SUITE 201

P 08/03/2018 $1,000.00
NASHVILLE
,
TN
37217
TENNESSEE ARCHITECTS PAC
1105 GARTLAND AVE

P 08/04/2018 $1,000.00
NASHVILLE
,
TN
37206
TMP PARTNERS
221 FRANKLIN RD
08/04/2018 $500.00
BRENTWOOD
,
TN
37027
TOTAL CONTRIBUTIONS $30,500.00

(other than adjustments, loans, and
interest)
Contribution Adjustments $0.00
Loans Received $0.00
Interest Received This $0.00

Reporting Period
TOTAL RECEIPTS $30,500.00
Disbursements
Expenditures, Unitemized
Purpose Amount
FOOD / BEVERAGE $14.43

PARKING $3.00
PARKING $3.00
PUBLIC TRANSPORTATION $6.54
STORAGE OF SIGNS $86.00
Expenditures, Itemized
Vendor C/P Purpose In-Kind Independent S/O Date A

BLACKLIST
CONSULTING
GROUP
959 FISHER CONSULTING 07/30/2018 $1

ROAD
GROSSE POINTE
,
MI
48230
BLACKLIST
CONSULTING
GROUP

ROAD
GROSSE POINTE
,
MI
48230
BLACKLIST
CONSULTING
GROUP

ROAD
GROSSE POINTE
,
MI
48230
CEPICKY
,
SCOTT
3937 HOPEWELL C CONTRIBUTION 07/26/2018 $1

ROAD
CULLEOKA
,
TN
38451
COLEY
, JAMES
2498 KENWOOD
LANE
C CONTRIBUTION 08/20/2018 $1
BARTLETT
,
TN
38134
DOGGETT
, CLAY
1525 ELKTON
PIKE
PULASKI
,
TN
38478
FAULK
, WILLIAM
1554
COLLINGHAM CAMPAIGN 08/13/2018
DRIVE
WORKERS
COLLIERVILLE
,
TN
38017
GIBBONS
, EMILY
1020 BRADLEY CAMPAIGN
COURT
08/13/2018
WORKERS
KODAK
,
TN
37764
GRIFFEY
,
BRUCE I.
140 PAUL DRIVE
PARIS
,
TN
38242
HAMPTON INN
5368 WINNERS TRAVEL-VISIT

CIRXLE
08/11/2018
REPRESENTATIVES
MORRISTOWN
,
TN
37813
HASTON
, KIRK
P.O. BOX 171


LOBELVILLE
,
TN
37097
HURT
, CHRIS
514 W. TIGRETT C CONTRIBUTION 08/27/2018 $1

STREET
HALLS
,
TN
38040
LAFFERTY
,
JUSTIN
1509 MEETING C CONTRIBUTION 08/16/2018 $1

HOUSE ROAD
KNOXVILLE
,
TN
37931
LEATHERWOOD
,
TOM
5940 GRIFFIN C CONTRIBUTION 08/16/2018 $1

ROAD
ARLINGTON
,
TN
38002
LEE
, BILL
P.O. BOX 40392

NASHVILLE
,
TN
37204
MAFIAOZAS
230 FRANKLIN VOLUNTEER

ROAD
08/01/2018
LUNCH
FRANKLIN
,
TN
37064
MAPCO
EXPRESS
830 CRESCENT GAS CARDS FOR 08/13/2018

CENTRE DRIVE
CAMPAIGN STAFF
KNOXVILLE
,
TN
37921
MCCORMICK
,
SCOTT
1356 RAINSONG C CONTRIBUTION 08/27/2018 $1

COVE SOUTH
CORDOVA
,
TN
38016
MURPHY USA
584 ENON GAS CARDS FOR

SPRINGS ROAD
08/15/2018
CAMPAIGN STAFF
SMYRNA
,
TN
37167
PARTHENON
GRILLE
1962 S CHURCH
FOOD / BEVERAGE 09/24/2018
MURFREESBORO
,
TN
37130
RAGAN
, JOHN
119
MORNINGSIDE C CONTRIBUTION 08/16/2018 $1
DR.
OAK RIDGE
,
TN
37830
RED IVORY
STRATEGIES,
LLC
DANIEL,
ADVERTISING S 09/30/2018 $1

PO BOX 330913
MARTIN
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
CURCIO,
PO BOX 330913
MICHAEL G.
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
ADVERTISING RUDD, TIM S 09/30/2018 $1
PO BOX 330913
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
ADVERTISING DUNN, BILL S 09/30/2018 $1
PO BOX 330913
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
BRICKEN,
PO BOX 330913
RUSH
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
ADVERTISING RAGAN, JOHN S 09/30/2018 $1
PO BOX 330913
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
BAUM,
PO BOX 330913
CHARLIE
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES, TERRY,
LLC
ADVERTISING GREGORY S 09/30/2018 $1
PO BOX 330913
BRYAN
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
MOODY,
PO BOX 330913
BRENT
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
CEPICKY,
PO BOX 330913
SCOTT
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
ADVERTISING REEDY, JAY D. S 09/30/2018 $1

PO BOX 330913
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
ADVERTISING SMITH, EDDIE S 09/30/2018 $1
PO BOX 330913
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
ADVERTISING HURT, CHRIS S 09/30/2018 $1
PO BOX 330913
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
VALLEJOS,
PO BOX 330913
TOMMY
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
MCCORMICK,
PO BOX 330913
SCOTT
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
SHERRELL,
PO BOX 330913
PAUL
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
SPARKS,
PO BOX 330913
MICHAEL
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
MOODY,
ADVERTISING S 09/26/2018
PO BOX 330913
BRENT
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
VALLEJOS,
PO BOX 330913
TOMMY
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
ADVERTISING BYRD, DAVID S 09/26/2018 $1
PO BOX 330913
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
QUILLEN,
ADVERTISING O 09/24/2018 $1

PO BOX 330913
ANNE F.
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
HELTON,
PO BOX 330913
ESTHER
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
HELTON,
PO BOX 330913
ESTHER
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
TODD,
PO BOX 330913
CHRISTOPHER
NASHVILLE
,
TN
37203
REEDY
, JAY D.
425 COLEMAN C CONTRIBUTION 08/20/2018 $1

LANE
ERIN
,
TN
37061
RIGHT WAY
MARKETING
TELEPHONE TOWN VALLEJOS,
PO BOX 3071
09/27/2018 $1
HALL TOMMY
BLOUNTVILLE
,
TN
37617
RIGHT WAY
MARKETING
TELEPHONE TOWN MOODY,
PO BOX 3071
09/27/2018 $1
HALL BRENT
BLOUNTVILLE
,
TN
37617
RUSSELL
,
LARRY LOWELL
104 CORN
TASSELL C CONTRIBUTION 08/16/2018 $1
SHORES
VONORE
,
TN
37885
SHELL
1040 S.
JEFFERSON GAS CARDS FOR 08/13/2018
AVENUE
CAMPAIGN STAFF
COOKEVILLE
,
TN
38501
SHULTS
,
HUNTER
CAMPAIGN
313 JUNE DRIVE
08/07/2018 $1
WORKERS
LEBANON
,
TN
37087
SMITH
, EDDIE
1508 CHARLES
DRIVE
KNOXVILLE
,
TN
37918

SMITHMIER
,
HOGAN
3991 BUNKER CAMPAIGN 08/13/2018 $1

HILL ROAD
WORKERS
COOKEVILLE
,
TN
38506
SPRY
STRATEGIES
3550 HOPE SPARKS,

LIVE CALLS S 08/06/2018 $2
CREEK ROAD
MICHAEL
LENOIR CITY
,
TN
37771
SPRY
STRATEGIES
3550 HOPE TODD,

LIVE CALLS S 08/06/2018 $3
CREEK ROAD
CHRISTOPHER
LENOIR CITY
,
TN
37771
SPRY
STRATEGIES
3550 HOPE RESEARCH / 08/06/2018 $16

CREEK ROAD
POLLING
LENOIR CITY
,
TN
37771
SPRY
STRATEGIES
3550 HOPE HELTON,

LIVE CALLS S 08/06/2018 $5
CREEK ROAD
ESTHER
LENOIR CITY
,
TN
37771
STANDARD
RESTAURANT
DUES /
150 8TH AVE. N.
09/01/2018
SUBSCRIPTIONS
NASHVILLE TN
,
TN
37204
STANDARD
RESTAURANT
DUES /
150 8TH AVE. N.
08/01/2018
SUBSCRIPTIONS
NASHVILLE TN
,
TN
37204
STANDARD
RESTAURANT
150 8TH AVE. N.

FOOD / BEVERAGE 08/16/2018
NASHVILLE TN
,
TN
37204
TILLIS
, THOMAS
R.
PO BOX 1396
LEWISBURG
,
TN
37091
VALLEJOS
,
TOMMY
705 WEST CREEK C CONTRIBUTION 08/27/2018 $1

DRIVE
CLARKSVILLE
,
TN
37040

Loan Payments $0.00
Obligation Payments $0.00
TOTAL EXPENDITURES $86,142.04

(other than adjustments)
Expenditures, Adjustments $0.00
TOTAL DISBURSEMENTS $86,142.04
Ending Balance
ENDING BALANCE $80,172.73
Outstanding Loans
TOTAL OUTSTANDING LOAN $0.00

BALANCE
In-Kind Contributions
In-Kind Contributions are not included in the report ending balance.
Unitemized $0.00
Itemized $0.00

TOTAL IN-KIND $0.00

CONTRIBUTIONS
Obligations
Obligations are not included in the report ending balance.
Unitemized $0.00
Itemized $0.00
Obligations, Outstanding from Previous Reports $0.00
TOTAL OBLIGATIONS $0.00

OUTSTANDING
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Online Campaign Finance
Pre-General
for CAS-PAC Print Page Download Full Report Home
submitted on 10/29/2018
Beginning Balance
Beginning Balance $80,172.73
Receipts
Monetary Contributions, $0.00
Unitemized
Monetary Contributions,
Itemized
Contributor C/P Date Amount
ATMOS ENERGY PAC
P.O. BOX 15441

P 10/01/2018 $1,000.00
WASHINGTON
,
DC
20003
CHS/COMMUNITY HEALTH SYSTEMS, INC.
4000 MERIDIAN BLVD.

P 10/01/2018 $2,000.00
FRANKLIN
,
TN
37067
CORECIVIC, INC. PAC
10 BURTON HILLS BLVD.

P 10/01/2018 $2,500.00
NASHVILLE
,
TN
37215
DAVITA

POB 2037
10/01/2018 $1,000.00
TACOMA
,
WA
98401
DELTA DENTAL OF TENNESSEE PAC
240 VENTURE CIRCLE

P 10/01/2018 $1,000.00
NASHVILLE
,
TN
37228
HARGETT
, JONAHAN
POB 371
MILAN
,
TN
38358
10/01/2018 $1,000.00
SMALL BUSINESS
HARGETT PAVING
INDEPENDENT PHARMACY PAC OF TENNESSEE
4525 HARDING ROAD, SUITE 200

P 10/01/2018 $6,500.00
NASHVILLE
,
TN
37205
SPRINT CORPORATION PAC
900 7TH ST., NW, SUITE 700

P 10/01/2018 $500.00
WASHINGTON
,
DC
20001
TITLEMAX
2313 E TRINITY MILLS RD

10/01/2018 $1,000.00
CARROLLTON
,
TX
75006
TN.AMBULATORYSURGERY CTR
1400 VILLAGE SQ
10/01/2018 $500.00
TALLAHASSEE
,
FL
32312
TOTAL CONTRIBUTIONS $17,000.00

(other than adjustments, loans, and
interest)
Contribution Adjustments $0.00
Loans Received $0.00
Interest Received This $5.93

Reporting Period
TOTAL RECEIPTS $17,005.93
Disbursements
Expenditures, Unitemized

Purpose Amount
DUES / SUBSCRIPTIONS $29.24
PARKING $5.00
PARKING $8.00

Expenditures, Itemized
In-
Vendor C/P Purpose Independent S/O Date Amount
Kind
BONE FISH GRILL

505 FOOD /
N.THOMPSON
10/09/2018 $107.11
BEVERAGE
MURFREESBORO
,
TN
37129
BUTLER
, ED
PO BOX 215
C DONATIONS 10/22/2018 $500.00
RICKMAN
,
TN
38580
FLAT IRON GRILL

1311 VANN DR
FOOD / 10/19/2018 $227.99
JACKSON
,
TN BEVERAGE
38301
HAMPTON INN
CAMPBELL
STATION RD
TRAVEL 10/12/2018 $139.20
KNOXVILLE
,
TN
37821
RED IVORY
STRATEGIES,
LLC
MOODY,
MAIL S 10/23/2018 $11,500.00
PO BOX 330913
BRENT
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
HELTON,
MAIL S 10/23/2018 $3,000.00
PO BOX 330913
ESTHER
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
DANIEL,
MAIL S 10/23/2018 $3,000.00
PO BOX 330913
MARTIN
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
VALLEJOS,
MAIL S 10/23/2018 $3,000.00
PO BOX 330913
TOMMY
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
MAIL RAGAN, JOHN S 10/23/2018 $3,000.00
PO BOX 330913
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,

LLC
LITTLETON,
ADVERTISING S 10/15/2018 $1,000.00
PO BOX 330913
MARY
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
QUILLEN,
ADVERTISING O 10/09/2018 $350.00
PO BOX 330913
ANNE F.
NASHVILLE
,
TN
37203
RED IVORY
STRATEGIES,
LLC
ADVERTISING BYRD, DAVID S 10/09/2018 $500.00
PO BOX 330913
NASHVILLE
,
TN
37203
SAMMY B
705 CADET ST
FOOD / 10/27/2018 $120.31
LEBANON
,
TN BEVERAGE
37087
SPRY
STRATEGIES
3550 HOPE LIVE CALLS RAGAN, JOHN S 10/26/2018 $3,177.82

CREEK ROAD
LENOIR CITY
,
TN
37771
ST.JOHNS
RESTAURANT
FOOD /
278 MARKET ST
10/12/2018 $256.99
BEVERAGE
CHATTANOOGA
,
TN
37402
STANDARD
RESTAURANT
DUES /
150 8TH AVE. N.
10/01/2018 $275.00
SUBSCRIPTIONS
NASHVILLE TN
,
TN
37204
TEXAS DE
BRAZIL
FOOD /
210 25TH AVE N.
10/08/2018 $180.20
BEVERAGE
NASHVILLE
,
TN
37203
TODD
,
CHRISTOPHER
P.O. BOX 12255

C DONATIONS 10/22/2018 $500.00
JACKSON
,
TN
38308
Loan Payments $0.00
Obligation Payments $0.00
TOTAL EXPENDITURES $32,114.86

(other than adjustments)

Expenditures, Adjustments $0.00
TOTAL DISBURSEMENTS $32,114.86
Ending Balance
ENDING BALANCE $65,063.80
Outstanding Loans
TOTAL OUTSTANDING LOAN $0.00

BALANCE
In-Kind Contributions
In-Kind Contributions are not included in the report ending balance.
Unitemized $0.00
Itemized $0.00
TOTAL IN-KIND $0.00

CONTRIBUTIONS
Obligations

Obligations are not included in the report ending balance.
Unitemized $0.00
Itemized $0.00
Obligations, Outstanding from Previous Reports $0.00
TOTAL OBLIGATIONS $0.00

OUTSTANDING
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STATE OF TENNESSEE
OFFICE OF THE ATTORNEY GENERAL
August 14, 2018
Opinion No. 18-37
Applicability of Electioneering Disclaimer Requirements to Social Media Platforms
Question 1
Do the disclaimer requirements of Tenn. Code Ann. § 2-19-120 apply when a person
finances an election-related communication on a social media platform?
Opinion 1
Yes.
Question 2
Do any other financial disclosure or disclaimer requirements under state law apply to
election-related communications on social media platforms?
Opinion 2
Yes, Tenn. Code Ann. § 2-10-105 is also applicable to political communications on social
media platforms.
ANALYSIS
1. Section 2-19-120(a) of the Tennessee Code imposes a disclaimer requirement on

election-related communications. In pertinent part, it provides:
Whenever any person makes an expenditure for the purpose of financing a

communication that expressly advocates the election or defeat of a clearly identified
candidate, as defined by § 2-10-102 . . . , through any broadcasting station,
newspaper, magazine, outdoor advertising facility, poster, yard sign, direct mailing
or any other form of general public political advertising, a disclaimer meeting the
requirements of subdivision (a)(1), (2), (3), or (4) shall appear and be presented in
a clear and conspicuous manner to give the reader, observer or listener adequate
notice of the identity of persons who paid for and, where required, who authorized
the communication.
Neither “communication” nor “general public political advertising” is defined in § 2-19-

120 or in the definition section it incorporates, Tenn. Code Ann. § 2-10-102. Undefined words in
the Tennessee Code must “be given their natural and ordinary meaning, without forced or subtle
construction that would limit or extend the meaning of the language, except when a contrary
intention is clearly manifest.” Tenn. Code Ann. § 1-3-105(b).
The ordinary meaning of the word “communication” includes a message or advertisement

posted on a social media platform. The word “communication” means “the imparting or
exchanging of information or news.” New Oxford American Dictionary (3d ed. 2010); see also
Black’s Law Dictionary (10th ed. 2014) (defining “communication” as “the interchange of
messages or ideas by speech, writing, gestures, or conduct; the process of bringing an idea to
another’s perception”). A message or advertisement that expressly advocates the election or defeat
of a clearly identified candidate constitutes the imparting of information or news and the
interchange of a message or idea and fits easily within the ordinary meaning of “communication.”
The catch-all phrase “or any other form of general public political advertising” is also broad
enough to include social media platforms. “[W]here general words follow specific words in a
statutory enumeration, the general words are construed to embrace only objects similar in nature
to those objects enumerated by the preceding specific words.” Wash. State Dep’t of Soc. & Health
Servs. v. Guardianship Estate of Keffeler, 537 U.S. 371, 384 (2003) (quoting Circuit City Stores
v. Adams, 532 U.S. 105, 114-15 (2001)). The meaning of “general public political advertising” is
thus to be determined from the words that precede it. A “broadcasting station, newspaper,
magazine, outdoor advertising facility, poster, yard sign, and direct mailing” are all traditional
media through which to advertise and convey messages. See Citizens United v. Fed. Election
Comm’n, 558 U.S. 310, 373 (Roberts, C.J. concurring) (noting television and radio broadcasts,
pamphlets, posters, and newspapers as methods for expressing opinions on matters of public
concern). Section 2-19-120 enumerates all of these methods of communications and then includes
“any other form of general public” advertising.
As an important medium of speech and political advertising, social media platforms are
similar in nature to the other forms of advertising listed in § 2-19-120 and thus fall within its catch-
all provision for “any other form of general public political advertising.” Indeed, social media
platforms have overtaken the traditional methods of political advertising enumerated in § 2-19-
120—newspapers, posters, direct mailings, etc.—as the most effective means of communicating
with a target audience. Social media platforms are simply a new “form” of “general public”
advertising similar in purpose to the more traditional forms listed in the statute. Social media
platforms have, in fact, become the paramount form of political advertising, replacing many of the
traditional forms. See Packingham v. North Carolina, 137 S. Ct. 1730, 1735 (2017) (“While in
the past there may have been difficulty in identifying the most important places . . . for the
exchange of views, today the answer is clear. It is cyberspace—the vast democratic forums of the
Internet in general, and social media in particular.” (internal quotation marks omitted)); see also
Citizens United, 558 U.S. at 364 (“Today, 30-second television ads may be the most effective way
to convey a political message. Soon, however, it may be that Internet sources, such as blogs and
social networking Web sites, will provide citizens with significant information about political
candidates and issues.”). Section 2-19-120 accounts for such developments by including a catch-
all provision requiring disclaimers on “any other form” of public political advertising.
Section 2-19-120(b) does except from its disclaimer requirements “bumper stickers, pins,
buttons, pens, novelties, and similar small items upon which the disclaimer cannot be conveniently
2
printed.” This express exception for bumper stickers, pins, and other small items reinforces that
additional exceptions to the disclaimer requirement—e.g., for social media posts—should not be
implied. See TRW Inc. v. Andrews, 534 U.S. 19, 29 (2001) (“Where Congress explicitly
enumerates certain exceptions to a general prohibition, additional exceptions are not to be implied,
in the absence of a contrary legislative intent.” (internal quotation marks omitted)); Limbaugh v.
Coffee Med. Ctr., 59 S.W.3d 73, 83-84 (Tenn. 2001).
Social media platforms do not fit within the exception in subsection (b) for “similar small
things upon which the disclaimer cannot be conveniently printed.” The meaning of that concluding
phrase must also be determined from the words which proceed it. See Guardianship Estate of
Keffeler, 537 U.S. at 384. Bumper stickers, pins, buttons, pens, and novelties are all tangible items
with a limited space on which a message may be printed. Political messages posted on social
media platforms are not similar to these tangible forms of political advertisements and do not share
their physical limitations; on social media platforms, the required disclaimer requirements can
conveniently be included with the political message. 1
In sum, a message or advertisement that expressly advocates the election or defeat of a

clearly identified candidate is a “communication” within the scope of Tenn. Code Ann. § 2-19-
120, and social media platforms are a form of “general public political advertising” within the
scope of the statute as well. Accordingly, a person who spends money to finance a
“communication that expressly advocates the election or defeat of a clearly identified candidate”
on a social media platform must comply with the applicable disclaimer requirements. 2
1
While some social media platforms—such as Twitter—may impose a maximum character limit, there exist many
ways in which a user can “conveniently” include a disclaimer, e.g. by using an image, a reply tweet, or profile
information to disclose the identity of the person who paid for, or authorized, the communication in a sufficiently clear
and conspicuous manner necessary to satisfy the requirements of § 2-19-120.
2
This Office previously concluded that § 2-19-120 violated the First Amendment in light of the Supreme Court’s
decision in McIntyre v. Ohio Elections Comm’n, 514 U.S. 334 (1995). See Tenn. Att’y Gen. Op. 95-090
(Aug. 29, 1995). Subsequent statutory amendments and case law have, however, rendered the conclusion of the 1995
opinion obsolete. In McIntyre, the Supreme Court held unconstitutional an Ohio law that prohibited the distribution
of anonymous campaign material for both referenda and candidate elections. See Majors v. Abell, 361 F.3d 349, 351
(7th Cir. 2004) (Posner, J.). When the 1995 opinion was issued, § 2-19-120 similarly applied to communications
supporting both candidates and ballot “measure[s].” But the statute was subsequently amended in 2004 to apply only
to communications supporting candidates. See 2004 Tenn. Pub. Acts, ch. 480, §§ 11, 12. McIntyre also expressly
limited its holding to “only written communications and, particularly, leaflets of the kind Mrs. McIntyre distributed.”
514 U.S. at 338 n.3. Although the previous opinion found it “certain that the Court would apply the same First
Amendment analysis to broadcast restrictions,” Tenn. Att’y Gen. Op. 95-90 (Aug. 29, 1995), some courts have in fact
interpreted McIntyre as limited to written communications, see, e.g., Worley v. Fla. Sec. of State, 717 F.3d 1238, 1254
(11th Cir. 2013). In addition, since McIntyre, the Supreme Court and lower courts have upheld limited disclaimer
requirements, some of which are similar to § 2-19-120. See, e.g., Citizens United 558 U.S. at 366–71 (upholding
disclaimer requirements that applied to electioneering communications funded by anyone other than a candidate);
Worley, 717 F.3d at 1253-55; Majors, 361 F.3d at 351-55; Ky. Right to Life, Inc. v. Terry, 108 F.3d 637, 647-48
(6th Cir. 1997). Moreover, the implications of McIntyre, Citizens United, and other cases for political advertising
done through the unique medium of social media platforms have not yet been addressed. The anonymity protection
provided by the First Amendment in the social media context remains an open question. See, e.g., Packingham,
137 S. Ct. at 1743 (Alito, J. concurring in the judgment) (cautioning against the “unprecedented degree of anonymity”
provided by the internet); In re Grand Jury Subpoena No. 11116275, 846 F. Supp. 2d 1, 4 (D.D.C. 2012) (“Mr. X has
a right under the First Amendment to post on the Internet, and to do so anonymously.”).
3
2. Tennessee law also requires that “all expenditures made by or on behalf of” candidates
for state public office and political campaign committees involved in state elections be filed in a
statement with the registry of election finance. Tenn. Code Ann. § 2-10-105(a). Similarly,
candidates for local public office and political campaign committees involved in local elections
must file an identical statement with the applicable county election commission. Id. § 2-10-105(b).
These statutes require disclosure of “all expenditures,” which would include expenses incurred in
promulgating political advertisements or communications on social media platforms. Any
expenses incurred for communicating via social media are thus required to be disclosed pursuant
to § 2-10-105.
HERBERT H. SLATERY III

Attorney General and Reporter
ANDRÉE SOPHIA BLUMSTEIN

Solicitor General
JONATHAN DAVID SHAUB

Assistant Solicitor General
Requested by:
The Honorable Jason Powell

State Representative, District 53
418 Cordell Hull Building
Nashville, TN 37243
4
House Speaker put political operative on state payroll
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House Speaker put political

operative on state payroll
Posted: 5:44 PM, May 10, 2019
Updated: 5:12 PM, May 11, 2019
By:
Phil Williams
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https://www.newschannel5.com/news/newschannel-5-investigates/house-speaker-put-political-operative-on-state-payroll[5/14/2019 9:53:10 PM]

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NASHVILLE, Tenn. (WTVF) — House Speaker Glen Casada put one of his political
operatives on the state payroll earlier this year, giving him a $48,000-a-year job --
with no expectation that he work out of the legislature's offices, submit a formal time
card or even work 40 hours a week, a NewsChannel 5 investigation discovered.
Michael Lotfi, who was behind digital ads last year attacking women who had accused
Rep. David Byrd of sexual assault, has no state office, no state phone and - until last
month - no state email. He said that the only requirement was for him to "be
available."
"It's almost like a salary situation, I guess you would say," Lotfi told NewsChannel 5
Investigates in a telephone interview.
"Basically, I just report back to the Speaker's office what hours are sort of kept. But
for the most part, it's just I'm available during working hours if I am not up here [on
Capitol Hill] - or even after hours if anybody needs anything specific or has any
specific questions."
Lofti, 28, went on the state payroll on January 8, the day that Casada was sworn in as
Speaker, earning $4,000 a month with full benefits, according to state records.
His official title is "senior legislative advisor."
The political operative said that means helping to advise Casada, as well as House
Republicans, on policy as well as political strategy.
"I was hired by the Speaker and I advise the Speaker on policy and narratives -- and
Caucus members as well -- as far as if they have any policy questions or how is the
district going to react to this or how is the media going to react to this," Lotfi said.
"Then I am available for those conversations and then come in work on special
projects and research, stuff like that."

He called his arrangement an "alternative work schedule."
"Sure, you don't have to come in," Lotfi said, "but you just need to be available to take
calls if necessary or work whenever is necessary - and be available to come in at any
given time."
Rep. Bo Mitchell, a Nashville Democrat, said he had never heard of anyone in

legislative offices having that kind of arrangement.
"If you are getting a full-time salary and you are getting benefits, you should show up
full time,” Mitchell said.
"The question is: why is someone getting paid this type of money and not having to
show up? Everyone else has to show up for work. If he's not adding any value to the
Tennessee General Assembly, then why is he getting paid nearly $50,000 a year?"
Lotfi's other job is a company that he owns, Red Ivory Strategies.
Among the services it advertises: Digital Branding and Website Development,

Government and Public Relations, and Direct Mail.
Lotfi said his company has actually never done work attempting to influence
legislation and he does not believe he could do that as long as he is employed by the
state.
“One of the conditions of my employment was to obviously run anything that would
be a potential conflict ... by the Speaker and everyone else,” Lotfi said, adding that he
could not accept any work that would be “opposing members on a piece of legislation
or something like that.”
Financial disclosures show that, last year, Red Ivory Strategies got paid $529,417 for
working on state and federal political campaigns.
Of that, $123,300 came from Casada's political action committee, CAS-PAC.
Lotfi admitted that part of his job for CAS-PAC last year was running a shadowy

Facebook page, the Alliance for Tennessee Families, that was working to get Rep.
David Byrd re-elected. Three women had accused the Waynesboro Republican of
sexually assaulting them years ago.
Red Ivory Strategies created digital ads portraying Byrd's opponents as "socialist
Democrats" and suggesting "lies" were being told about him.
UPDATE: After NewsChannel 5's story aired, Lotfi responded, arguing

that the ad's reference to "lies" was generic language that was also used
in other races. "The ad you referenced absolutely makes no mention of
the women who accused Byrd, and never intended to." Women involved
in opposing Byrd, however, say that - in the context of his race - the
implication was clear.
"Those popped up on phones and computers in David Byrd's district - because you
can target them via Facebook,” said Emily Tseffos with the group Enough is Enough,
which targets candidates who have been accused of sexual harassment or sexual
assault.
Tseffos was among the women protesting Byrd this session on Capitol Hill.
She said the fact that Casada put the person behind those ads on the state payroll
speaks volumes.
"It's a lack of integrity that Casada has spoken about time and time again, this moral
integrity that he has. This is yet another example of how he, in fact, has none and he's
willing to reward the people for doing the dirty work for him."
Lotfi previously worked as a legislative aide and was fired by Speaker Beth Harwell in
2016 for his political consulting "being in conflict with his service in the legislature."
But Lotfi said, in this case, he has just been doing exactly what Speaker Casada asked
of him, insisting that he did not think his situation was all that unusual.
"You would not believe the amount of down time up here [at the legislature]. It's
totally ridiculous."

Additional stories:
NewsChannel 5 Investigates: Capitol Hill

Copyright 2019 Scripps Media, Inc. All rights reserved. This material may not be published, broadcast, rewritten, or redistributed.
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000768582: Limited Liability Company - Domestic Printer Friendly Version

Name: RED IVORY STRATEGIES LLC

Old Name: SOUTHERN TUSK MEDIA LLC
Status: Active Initial Filing Date: 08/19/2014
Formed in: TENNESSEE Delayed Effective Date:
Fiscal Year Close: December AR Due Date: 04/01/2020
Term of Duration: Perpetual Inactive Date:
Principal Office: 2160 VALLEY VIEW RD

JOELTON, TN 37080-9000 USA
Mailing Address: PO BOX 330913

NASHVILLE, TN 37203-7506 USA
AR Exempt: No Obligated Member Entity: No

Managed By: Member Managed Number of Members: 1
Assumed Names History Registered Agent

Agent Name: LOTFI, MICHAEL G

Agent Address: 2160 VALLEY VIEW RD
JOELTON, TN 37080-9000 USA
Division of Business Services

312 Rosa L. Parks Avenue, Snodgrass Tower, 6th Floor
Nashville, TN 37243
615-741-2286
8:00 a.m. until 4:30 p.m. (Central) Monday - Friday.
https://tnbear.tn.gov/Ecommerce/FilingDetail.aspx?CN=201118043091088021072129219103087180253010126111[5/14/2019 10:14:42 PM]

Directions | State Holidays | Methods of Payment
Business Filings and Information (615) 741-2286 | TNSOS.CORPINFO@tn.gov
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Trademarks (615) 741-0531 | TNSOS.ATS@tn.gov
Nonresident Fiduciaries (615) 741-0536 | TNSOS.ATS@tn.gov
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Report - Online Campaign Finance

Online Campaign Finance

Amended 3rd Quarter

PAC submitted on 10/15/2018

Contributor C/P Date Amount

ABBVIE POLITICAL ACTION COMMITTEE

P.O. BOX 40424

BEST EFFORT MADE

https://apps.tn.gov/tncamp-app/search/pub/report_full.htm?reportId=80215[5/14/2019 9:22:32 PM]

209 10TH AVE S

CENTURYLINK INC. EMPLOYEES' PAC

1099 NEW YORK AVE. NW, SUITE 250

CHARTER COMMUNICATIONS INC., TENNESSEE PAC

1774 HENRY G. LANE STREET

EARL SWENSON ASSC

ELI LILLY & CO. PAC

LILLY CORPORATE CENTER

FARRIS MATHEWS BRANAN BOBANGO & HELLEN PAC

ONE COMMERCE SQUARE, SUITE 2000

5201 VIRGINIA WAY

GOPAC ELECTION FUND

2300 CLARENDON BLVD

127 3RD AVE S.

HCA TRISTAR FUND

1000 HEALTH PARK DRIVE, SUITE 500

LAND TITLE PAC OF TN

414 UNION AVENUE, SUITE 1105

NAT'L HEALTH CORP. PAC

100 VINE ST.

PIEDMONT NATURAL GAS TN CORPORATE

611 COMMERCE ST., STE. 2605

SAMMONS HOLDING LLC

208 ST.ALBANS FAIRWAY

https://apps.tn.gov/tncamp-app/search/pub/report_full.htm?reportId=80215[5/14/2019 9:22:32 PM]

P.O. BOX 158540

TENNESSEE APARTMENT PAC

2 INTERNATIONAL PLAZA, SUITE 201

TENNESSEE ARCHITECTS PAC

1105 GARTLAND AVE

TOTAL CONTRIBUTIONS $30,500.00

Contribution Adjustments $0.00

Loans Received $0.00

Interest Received This $0.00

TOTAL RECEIPTS $30,500.00

FOOD / BEVERAGE $14.43

FOOD / BEVERAGE $19.55

FOOD / BEVERAGE $78.25

FOOD / BEVERAGE $70.37

https://apps.tn.gov/tncamp-app/search/pub/report_full.htm?reportId=80215[5/14/2019 9:22:32 PM]

FOOD / BEVERAGE $5.03

FOOD / BEVERAGE $21.24

FOOD / BEVERAGE $53.37

FOOD / BEVERAGE $80.75

FOOD / BEVERAGE $51.85

FOOD / BEVERAGE $69.70

FOOD / BEVERAGE $16.00

FOOD / BEVERAGE $50.94

FOOD / BEVERAGE $25.13

FOOD / BEVERAGE $13.28

PUBLIC TRANSPORTATION $6.54

PUBLIC TRANSPORTATION $5.00

PUBLIC TRANSPORTATION $6.55

PUBLIC TRANSPORTATION $6.54