Full opinion text
Opinion & Order Cross-Motions for Summary Judgment WILLIAM K. SESSIONS III, District Judge. Plaintiffs filed suit for declaratory and injunctive relief to bar enforcement against them of provisions of Vermont’s campaign finance law. They contend the challenged portions of the law, which require disclosure of election-related speech and limit the amount donors may contribute to “political committees,” violate their constitutional guarantees of free speech and due process of law, U.S. Const, amend. XIV, § 1. Pending are the parties’ cross motions for summary judgment, ECF Nos. 166, 168. The Court heard oral argument on the motions on April 30, 2012. As this opinion explains, there are no genuine issues of material fact that warrant trial. On the undisputed factual record before it, the Court denies Plaintiffs’ motion and grants Defendants’ motion in full. Background I. The Parties Plaintiff Vermont Right to Life Committee, Inc. (“VRLC”) is a Section 501(c)(4) organization engaged in educational and political work “ ‘to achieve universal recognition of the sanctity of human life from conception through natural death.’ ” First Am. & Verified Compl. (“FAVC”) ¶ 10, ECF No. 132. Plaintiff Vermont Right to Life Committee — Fund for Independent Political Expenditures (“FIPE”), formed by VRLC in 1999, is a registered Vermont political committee. FIPE’s formation documents indicate that it would not “make monetary or in-kind contributions to candidates and it will not coordinate” with candidates. Defs.’ Mot. for Summ. J. Ex. C (“Organizational Docs.”), at 3, ECF No. 168-5. FIPE was active in the 2010 election cycle, but asserts that, prior to that time, it had not been active since at least 2002. Although not a party in this action, a noteworthy player is Vermont Right to Life Committee, Inc. Political Committee (“PC”). PC was created by VRLC to engage in federal and state campaign activities, including making direct contributions to pro-life candidates. Defendants are Vermont officials with authority to enforce Vermont campaign finance law (the “State”). II. The Challenged Statutes For the last century, Vermonters’ concerns about the influence of money in politics have moved the Vermont Legislature to enact and refíne a body of campaign finance law governing state elections. See Landell v. Sorrell, 118 F.Supp.2d 459, 464-70 (D.Vt.2000), aff'd in part, vacated in part, 382 F.3d 91 (2d Cir.2004), rev’d in part sub nom., Randall v. Sorrell, 548 U.S. 230, 126 S.Ct. 2479, 165 L.Ed.2d 482 (2006). This action relates to two classes of provisions contained in Vermont’s campaign finance statutes: (1) a series of disclosure requirements for election spending, and (2) a $2000 limit on the amount donors can contribute to political committees. A. Disclosure Provisions The first set of disclosure regulations are registration and periodic reporting required of organizations that meet the statutory definition of a “political committee” (referred to alternatively here as a “PAC”). A PAC is: any formal or informal committee of two or more individuals, or a corporation, labor organization, public interest group, or other entity, not including a political party, which receives contributions of more than $500.00 and makes expenditures of more than $500.00 in any one calendar year for the purpose of supporting or opposing one or more candidates, influencing an election, or advocating a position on a public question in any election or affecting the outcome of an election. Vt. Stat. Ann. tit. 17, § 2801(4). “Contribution” and “expenditure,” terms used in the PAC definition, are also defined by statute. A “contribution” is “a payment, distribution, advance, deposit, loan or gift of money or anything of value, paid or promised to be paid to a person for the purpose of influencing an election, advocating a position on a public question, or supporting or opposing one or more candidates in any election,” not including unpaid volunteer services or a personal loan from a lending institution. Id. § 2801(2). An “expenditure” is “a payment, disbursement, distribution, advance, deposit, loan or gift of money or anything of value, paid or promised to be paid, for the purpose of influencing an election, advocating a position on a public question, or supporting or opposing one or more candidates.” Id. § 2801(3). Attaining PAC status creates obligations on the part of the nascent political committee. The PAC must designate a single checking account to fund any expenditure and name a treasurer to maintain that account. Id. § 2802. Within ten days of surpassing the $500 contribution and expenditure threshold, it must register with the Vermont Secretary of State (the “Secretary”), providing its name, address, the location of its bank account, and its treasurer’s name. Id. § 2831(a). In addition to registering, it must file “campaign finance reports” with the Secretary at regular intervals. Vermont elects its state officials to two-year terms, such that every even-numbered year is an election year and every odd-numbered year is an off-year. In odd-numbered years, PACs file campaign finance reports once, on July 15. Id. § 2811(d). In election years, PACs must report five or six times, twice prior to the primary election, twice between the primary and the general election, and once or twice following the general election. Decl. of David Crossman, Vt. Elections Adm’r, Defs.’ Mot. for Summ. J. (“Crossman Decl.”) ¶ 9, ECF No. 71-30. Each campaign finance report must list the name, address, and date of contribution for each person who contributed more than $100, contain a description of every expenditure, and specify any loans, debts or obligations on the PAC’s books. Vt. Stat. Ann, tit. 17, § 2803(a). The law additionally requires PACs to total their expenditures and contributions for the campaign to date, itemized by monetary and non-monetary contributions. Id. §§ 2803(a)(2), (b). The Secretary makes campaign finance reports available for public inspection at its Montpelier offices and in a searchable form on its website. Separately, Vermont law mandates disclosure of two distinct categories of election speech. For these categories, it does not matter whether the speaker first qualifies as a PAC. One category is “electioneering communications,” which refers to: any communication, including communications published in any newspaper or periodical or broadcast on radio or television or over any public address system, placed on any billboards, outdoor facilities, buttons or printed material attached to motor vehicles, window displays, posters, cards, pamphlets, leaflets, flyers, or other circulars, or in any direct mailing, robotic phone calls, or mass e-mails that refers to a clearly identified candidate for office and that promotes or supports a candidate for that office, or attacks or opposes a candidate for that office, regardless of whether the communication expressly advocates a vote for or against a candidate. Vt. Stat. Ann. tit. 17, § 2891. An identification requirement attaches to most electioneering communications, as they must: contain the name and address of the person, political committee, or campaign who or which paid for the communication. The communication shall clearly designate the name of the candidate, party, or political committee by or on whose behalf the same is published or broadcast. Id. § 2892. Excluded from the electioneering communication identification requirement, however, are “lapel stickers or buttons,” as well as “electioneering communications made by a single individual acting alone who spends, in a single two-year general election cycle, a cumulative amount of no more than $150.00 on those electioneering communications.” Id. The other speech category is mass media activities (“MMA”), which covers “television commercials, radio commercials, mass mailings, literature drops, newspaper and periodical advertisements, robotic phone calls, and telephone banks which include the name or likeness of a clearly identified candidate for office.” Id. § 2893(a). In the lead up to an election, certain MMAs must be reported: In addition to any other reports required to be filed under this chapter, a person who makes expenditures for any one mass media activity totaling $500.00 or more within 30 days of a primary or general election shall, for each activity, file a mass media report with the secretary of state and send a copy of the mass media report to each candidate whose name or likeness is included in the activity within 24 hours of the expenditure or activity, whichever occurs first. For the purposes of this section, a person shall be treated as having made an expenditure if the person has executed a contract to make the expenditure. The report shall identify the person who made the expenditure with the name of the candidate involved in the activity and any other information relating to the expenditure that is required to be disclosed under the provisions of subsections 2803(a) and (b) of this title. Id. § 2893(b). The Office provides a standard, one-page MMA reporting form. Crossman Decl. Ex. 11. Unlike campaign reports, MMA reports do not require PACs to disclose the names of contributors. Vt. Stat. Ann. tit. 17, § 2893(b); Crossman Decl. ¶ 22. B. $2000 Limit on Individual Contributions to PACs Apart from the challenge to disclosure rules, at issue also is a restriction on finances. Vermont limits the amount a PAC may accept from any one contributor. Vt. Stat. Ann. tit. 17, § 2805(a). The law provides that: “A political committee ... shall not accept contributions totaling more than $2,000.00 from a single source, political committee or political party in any two-year general election cycle.” Id. III. Procedural History Plaintiffs filed their initial verified complaint on August 14, 2009, and later moved for a TRO, a preliminary injunction, and an expedited trial. ECF Nos. 1, 3, 5, 6, 36. The Court granted the request to consolidate the preliminary injunction hearing with a merits trial, and also approved a 45-day window for discovery. ECF No. 52. The parties filed cross-motions for summary judgment, ECF Nos. 70-71, just after the Supreme Court issued its decision in Citizens United v. Federal Election Commission, 558 U.S. 310, 130 S.Ct. 876, 175 L.Ed.2d 753 (2010). Plaintiffs moved to amend their complaint, reflecting changes in the law due to that seminal ruling and as a result of their voluntary dismissal of a plaintiff party. ECF Nos. 99, 120. The Court granted leave to amend and permitted time for supplemental discovery. ECF No. 129. Plaintiffs filed the twelve-count FAVC on July 19, 2010. During discovery, in August 2011, the Court entered a stipulated protective order that permitted the State to obtain internal meeting minutes and correspondence on the question of VRLC’s major purpose and FIPE’s activities, but required the State to file under seal any such evidence it referenced in its findings. ECF Nos. 157, 161. The parties filed their motions and briefing was completed on December 9, 2011. Plaintiffs either already are subject to or fear they will be bound by the disclosure and contribution limit provisions, restraining their speech and exposing them to criminal and civil penalties. VRLC alleges that while it is not currently registered as a PAC, its speech might bring it within the PAC definition’s compass. It has already or plans to distribute mass emails, newsletters, brochures, petitions, newspaper columns, fundraising letters, a web site, and a radio ad discussing pro-life issues and Vermont elected officials. VRLC contends Vermont’s PAC definition is unconstitutionally vague, in violation of the Fourteenth Amendment’s Due Process Clause, and overbroad, contravening First Amendment’s protection of political speech. It further states that some of the media it wishes to publish could incite enforcement against it of Vermont’s electioneering communications and MMA requirements. VRLC argues those requirements are unenforceable as well because they are unconstitutionally vague and overbroad. FIPE, already registered as a Vermont PAC, separately contests the $100 contribution reporting threshold for PACs as an unconstitutional burden on speech. In addition, FIPE contends the $2000 limit on individual contributions it may receive is unconstitutional as applied to it, since it alleges it makes only independent expenditures. Should the Court deem that part of the law unconstitutional as applied to FIPE, PC would make an in-kind contribution to FIPE of a supporter mailing list, valued at over $2000. Discussion I. Standard of Review Summary judgment is “ ‘only warranted upon a showing that theré is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.’ ” Allstate Ins. Co. v. Hamilton Beach/Proctor Silex, Inc., 473 F.3d 450, 455 (2d Cir.2007) (quoting Feingold v. New York, 366 F.3d 138, 148 (2d Cir.2004)); Fed.R.Civ.P. 56(a). “In determining whether there is a genuine issue of material fact, a court must resolve all ambiguities, and draw all inferences, against the moving party:” Beth Israel Med. Ctr. v. Horizon Blue Cross & Blue Shield of N.J., Inc., 448 F.3d 573, 579 (2d Cir.2006). The moving party will be “entitled to a judgment as a matter of law [if] the non-moving party ‘fails to make- a showing sufficient to establish the existence of an element essential to that party’s case.’” Tufariello v. Long Island R.R., 458 F.3d 80, 85 (2d Cir.2006) (quoting Celotex Corp. v. Catrett, 477 U.S. 317, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986)). Plaintiffs appended a statement of undisputed material facts to their motion for summary judgment. ECF No. 166-4. The State’s motion included its own statement of undisputed facts, ECF No. 168-2. The State also attached to its response brief a statement of disputed facts, which contested Plaintiffs’ showing. ECF No. 170-1. Plaintiffs did not file an opposing statement of disputed facts in return. Instead, they made clear in their briefing and at oral argument that they believe there are no genuine issues of material fact for the Court to resolve and that they are entitled to judgment as a matter of law regardless of the State’s evidence. Pis.’ Summ. J. Resp. Br. 2, ECF No. 171; Pis.’ Summ. J. Reply Br. 1-2, ECF No. 176; Pis.’ Supp’l. Filing 6, ECF No. 193. The Court accordingly considers the record before it undisputed, and it finds the issues ripe for decision on summary judgment. See 10A C. Wright, A. Miller, & M. Kane, Federal Practice and Procedure § 2723 (3d ed.) (noting admissions in briefs may be used to determine whether there is an issue of fact for trial “since they are functionally equivalent to ‘admissions on file,’ which are expressly mentioned in Rule 56(c)” as accepted forms of proof for summary judgment). II. Citizens United Citizens United looms large over the discussion that follows. Before launching into a claim-by-claim analysis, it is worthwhile to set forth the holding and central reasoning in that case. Citizens United produced a two-fold ruling: “Government may regulate corporate political speech through identification and disclosure requirements, but it may not suppress that speech altogether.” 130 S.Ct. at 886. The Supreme Court made clear that there is no state interest sufficient to justify regulation that limits corporate and union independent political expenditures. It reasoned that the only valid governmental interest in regulating campaign expenditures is preventing the reality or appearance of quid-pro-quo corruption, and independent expenditures, precisely because they are uncoordinated with candidates, pose no such threat. 130 S.Ct. at 908-09. That take on campaign spending is at least as old as Buckley v. Valeo, in which the Supreme Court remarked that “[ujnlike contributions, such independent expenditures may well provide little assistance to the candidate’s campaign and indeed may prove counterproductive.” 424 U.S. 1, 47, 96 S.Ct. 612, 46 L.Ed.2d 659 (1976). Citizens United also stands for the proposition that the First Amendment does not permit government to use a speaker’s corporate form as justification to regulate its independent expenditures. 130 S.Ct. at 913. The Court accordingly struck down 2 U.S.C.. § 441b’s total ban on corporate and union spending from general treasury funds for express advocacy or electioneering communications, forms of regulated independent expenditures. 130 S.Ct. at 913. It overruled Austin v. Michigan Chamber of Commerce, 494 U.S. 652, 110 S.Ct. 1391, 108 L.Ed.2d 652 (1990), and, in part, McConnell v. Federal Election Commission, 540 U.S. 93, 203-09, 124 S.Ct. 619, 157 L.Ed.2d 491 (2003), which had permitted limits on such speech. In reaching that result, Citizens United dispatched the counterargument that the law’s provision for forming a PAC was a suitable alternative to direct corporate or union speech. 130 S.Ct. at 897. Previously, a corporation like Citizens United could only engage in express advocacy or electioneering speech indirectly, by creating a PAC to which only its stockholders or employees could contribute. Id. at 887-88. The Court found the PAC approach did not alleviate the electioneering ban’s speech-repressive effects, because such PACs did not allow the corporation or union to speak for itself and were subject to extensive registration, reporting and disclosure requirements. Id. at 897-98. Thus, federal PACs were “burdensome alternatives,” and posed “onerous restrictions” that could hinder corporate and union speech during a campaign. Id. That critique reflected a longstanding skepticism of federally-defined PACs’ ability to substitute for pure political speech. See Fed. Election Comm’n v. Wis. Right to Life, Inc. (WRTL II), 551 U.S. 449, 477 n. 9, 127 S.Ct. 2652, 168 L.Ed.2d 329 (2007); MCFL, 479 U.S. at 253-56, 107 S.Ct. 616. At the same time, eight justices joined the portion of the opinion upholding the identification and disclosure requirements that also applied to Citizens United. 130 S.Ct. at 886, 913-16. That part affirmed another longstanding view: in spite of the burdens they pose to political speech, “disclosure requirements certainly in most applications appear to be the least restrictive means of curbing the evils of campaign ignorance and corruption that Congress found to exist.” Buckley, 424 U.S. at 68, 96 S.Ct. 612. At least since Buckley, the Supreme Court has recognized that different government interests support disclosure than support limits on spending in campaigns, namely: (1) informing voters as to the “sources of a candidate’s financial support,” enabling voters to better “evaluate] those who seek office”; (2) limiting corruption and its appearance by making large contributions and expenditures transparent; and (3) gathering data to discover any violations of the campaign finance laws. Id. at 66-68, 96 S.Ct. 612. The Supreme Court relied on the first rationale to justify the provisions applied to Citizens United. 130 S.Ct. at 914-16. To gauge their constitutionality, it applied Buckley’s “ ‘exacting scrutiny’ ” test, which requires a “‘substantial relation’ between the disclosure requirement and a ‘sufficiently important’ governmental interest.” Id. at 914 (citing Buckley, 424 U.S. at 64, 66, 96 S.Ct. 612); see also John Doe No. 1 v. Reed, — U.S. -, 130 S.Ct. 2811, 2818, 177 L.Ed.2d 493 (2010) (confirming exacting scrutiny applies to disclosure requirements). The provisions survived scrutiny. 130 S.Ct. at 915-16. In reaching that conclusion, the Court in Citizens United explicitly rejected the argument that disclosure could only cover express advocacy or its functional equivalent, a test distilled by prior cases for as-applied challenges to electioneering spending limits. 130 S.Ct. at 915. This statement assured the vitality of the part of McConnell in which the Court “rejected the notion that the First Amendment requires Congress to treat so-called issue advocacy differently from express advocacy.” 540 U.S. at 194, 124 S.Ct. 619. The Citizens United court made clear that the power to require disclosure extends beyond the power to limit speech, analogizing that although Congress “has no power to ban lobbying itself,” it may require registration and disclosure of lobbyists. 130 S.Ct. at 915 (citing United States v. Harriss, 347 U.S. 612, 625, 74 S.Ct. 808, 98 L.Ed. 989 (1954)). Indeed, Citizens United went further toward solidifying this principle, explicitly endorsing a system of relatively unrestricted political speech paired with “effective disclosure,” noting that many of Congress’s findings of influence-peddling in promulgating campaign finance legislation “were premised on a system without adequate disclosure.” 130 S.Ct. at 916. With those principles in mind, the Court advances to Plaintiffs’ constitutional claims. As described in Part III below, Plaintiffs have not succeeded in showing that Vermont’s disclosure provisions are either vague or regulate in excess of First Amendment protections. Furthermore, as discussed in Part IV, below, FIPE’s as-applied challenge to Vermont’s limit on individual contributions to PACs also fails. The State has provided uncontested evidence to show that FIPE and PC are deeply interrelated, making it unclear whether contributions to FIPE are spent on independent expenditures or contributions to candidates. III. Disclosure-Related Challenges A. Vagueness A law is vague, violating the Due Process Clause, when it “fails to provide a person of ordinary intelligence fair notice of what is prohibited, or is so standardless that it authorizes or encourages seriously discriminatory enforcement.” United States v. Williams, 553 U.S. 285, 304, 128 S.Ct. 1830, 170 L.Ed.2d 650 (2008); see also Buckley, 424 U.S. at 77, 96 S.Ct. 612. The concern for vagueness is heightened in the context of the First Amendment. Vill. of Hoffman Estates v. Flipside, Hoffman Estates, Inc., 455 U.S. 489, 499, 102 S.Ct. 1186, 71 L.Ed.2d 362 (1982). The First Amendment requires “breathing space” and statutes that press on its protections “must be narrowly drawn and represent a considered legislative judgment that a particular mode of expression has to give way to other compelling needs of society.” Broadrick v. Okla., 413 U.S. 601, 611-12, 93 S.Ct. 2908, 37 L.Ed.2d 830 (1973). Still, “ ‘perfect clarity and precise guidance have never been required even of regulations that restrict expressive activity.’ ” Williams, 553 U.S. at 304, 128 S.Ct. 1830 (quoting Ward v. Rock Against Racism, 491 U.S. 781, 794, 109 S.Ct. 2746, 105 L.Ed.2d 661 (1989)); see also Grayned v. City of Rockford, 408 U.S. 104, 110, 92 S.Ct. 2294, 33 L.Ed.2d 222 (1972) (“Condemned to the use of words, we can never expect mathematical certainty from our language.”). A plaintiff may challenge a law as unconstitutionally vague both as applied to its own speech and facially. See Vill. of Hoffman Estates, 455 U.S. at 494-95, 102 S.Ct. 1186. A facial vagueness challenge, however, will succeed only on a showing that the law “is impermissibly vague in all of its applications.” Id. at 495, 102 S.Ct. 1186. Moreover, “‘[a] plaintiff who engages in some conduct that is clearly proscribed cannot complain of the vagueness of the law as applied to the conduct of others.’ ” Holder v. Humanitarian Law Project, — U.S. -, 130 S.Ct. 2705, 2719, 177 L.Ed.2d 355 (2010) (quoting Vill. of Hoffman Estates, 455 U.S. at 495, 102 S.Ct. 1186). While VRLC styles its claims as both as-applied and facial challenges, it does little to craft an as-applied vagueness claim, offering minimal explanation of how the law is unconstitutional as it pertains to the specific communications it either has made or hopes to publish. See Pis.’ Summ. J. Br. 13 & n. 11, ECF No. 166-1; Iowa Right to Life Comm., Inc. v. Tooker, 795 F.Supp.2d 852, 863 n. 16 (S.D.Iowa 2011). By largely proceeding as if vagueness is a question of law shorn of context, VRLC seems to argue the provisions here must be vague as applied to it because they are vague in all applications. That argument flips on its head the general “preference for as-applied review even where First Amendment rights are implicated.” United States v. Farhane, 634 F.3d 127, 138 n. 9 (2d Cir.2011). Furthermore, if the law were to clearly apply to VRLC’s conduct in some aspect, VRLC could not attack it facially for vagueness. Humanitarian Law Project, 130 S.Ct. at 2718-19 (stating for that reason, “[w]e consider whether a statute is vague as applied to the particular facts at issue”); Nat’l Org. for Marriage, Inc. v. McKee, 669 F.3d 34, 43 (1st Cir.2012) (noting, “[t]hus, appellants are not only unable to bring a facial vagueness challenge to section 1056-B, but their failure to develop their as-applied challenges also would allow us to reject those claims summarily if we were so inclined”). Putting that concern to one side, however, VRLC’s vagueness claims also do not succeed on their merits. 1. PAC, Contribution, & Expenditure Definitions VRLC contends the PAC definition and similar language in the definitions of contribution and expenditure are vague. With respect to PACs, the questioned language applies PAC status to those entities accepting contributions or engaging in expenditures “for the purpose of supporting or opposing one or more candidates, influencing an election, or advocating a position on a public question in any election or affecting the outcome of an election.” Vt. Stat. Ann. tit. 17, § 2801(4). VRLC argues first that the language “for the purpose of ... influencing an election ... or affecting the outcome of an election” is vague. Regardless of the stand-alone merits of that claim, “[i]n evaluating a facial challenge to a state law, a federal court must, of course, consider any limiting construction that a state court or enforcement agency has proffered.” Vill. of Hoffman Estates, 455 U.S. at 489 n. 5, 102 S.Ct. 1186. A state court already has had occasion to narrow the statutory language challenged here. Vt. v. Green Mountain Future, Civ. Div. No. 758-10-10 Wncv, slip op. (Wash.Super.Ct. June 28, 2011) (Crawford, J.), http://www.vermont judiciary.org/20112015 Tcdecisioncvl/20116-30-l.pdf. In that case, Vermont brought an enforcement action against Green Mountain Future, a Vermont organization funded by the Democratic Governors Association that aired advertisements critical of Republican gubernatorial candidate Brian Dubie prior to the 2010 election. Id. at 1. Vermont sought civil penalties from Green Mountain Future for failing to adhere to the PAC registration and reporting requirements and for not identifying itself in electioneering communications. Id. at 1-2. Green Mountain Future counterclaimed, challenging the disclosure provisions as vague and overbroad, but Judge Crawford rejected its arguments. Id. at 14. On the PAC definition, he found the phrase “for the purpose of ... influencing an election ... or affecting the outcome of an election” not vague and interpreted it to mean the same as simply “supporting or opposing one or more candidates.” Id. at 12. As the decision further noted, the language “ensures that if the ad cannot reasonably be viewed as referring to a candidate, the registration requirements are not triggered.” Id. Thus, the decision removed the significance of the “influencing” and “affecting” phrases that are subject to challenge here. VRLC urged at oral argument that Judge Crawford, while upholding the PAC definition against vagueness, was actually implying that the words “influencing” and “affecting” give “support” and “oppose” an expansive, and therefore less clear, scope. It referred the Court to the State’s characterization of the 1988 amendment that added “influencing,” as having “broadened” the PAC definition. See Defs.’ Summ. J. Br. 16, ECF No. 168-1. While creative, that argument does not square with the Court’s reading of Green Mountain Future. That decision goes on to characterize the PAC and electioneering communications definitions as “differ[ing] little in effect,” slip op. at 13, even though the latter uses “support,” “promote,” “attack,” and “oppose” without the words “influencing” or “affecting,” or their equivalent, see Vt. Stat. Ann. tit. 17, § 2891. Since Green Mountain Future, further developments have bolstered its narrowing construction. The Vermont Attorney General’s Office publicly affirmed the narrowing effect of Green Mountain Future and a subsequent decision by Judge Crawford, Vermont v. Republican Governors Association, Defs.’ Supp’l Filing Ex. 3, ECF No. 192-3, on the PAC definition in declining to press charges against a group that had failed to register as a PAC. See Office of the Attorney General, Press Releases: Attorney General’s Office Concludes Investigation (Feb. 29, 2012), Defs.’ Supp’l Filing Ex. 2, ECF No. 192-2. In addition, the State represents that, on the appeal of Green Mountain Future currently pending before the Vermont Supreme Court, it will advocate in favor of adopting and affirming Green Mountain Future’s narrowing construction, and that it is estopped from arguing for a different reading of the statute in any subsequent proceedings. Defs.’ Supp’l Filing 2, ECF No. 192. The Court accepts the ruling in Green Mountain Future as a limiting construction of Vermont law and adopts it here. See Nat’l Org. for Marriage v. McKee, 649 F.3d 34, 66-67 (1st Cir.2011), cert. denied, ■— U.S.-, 132 S.Ct. 1635, 182 L.Ed.2d 233 (2012) (relying on a Maine administrative guideline for a narrowing construction of “influencing”). Even further, were this Court in the same position as the Vermont court, it would have reached the same conclusion in interpreting otherwise expansive language like “influencing” and “affecting” in their statutory context. See id. at 65 (“Buckley’s concerns aside, the term ‘influencing’ does present some vagueness problems.”); see also Yamada v. Weaver, 872 F.Supp.2d 1023, 1045-48 & n. 18, Civ. No. 10-497 JMS-RLP, 2012 WL 983559, at *18-20 & n. 18 (D.Haw. Mar. 21, 2012) (adopting a narrowing gloss for “ ‘to influence’ ” and “ ‘for the purpose of influencing’ ” in a PAC definition without a state court decision on point). Neither party has asked the Court to stay consideration of this case pending the Vermont Supreme Court’s review, nor does the Court find a stay warranted in light of the lengthy delays in this case and the imminent approach of the 2012 elections. Accordingly, the Court reads “for the purpose of ... influencing an election ... or affecting the outcome of an election” as simply, “supporting or opposing one or more candidates.” VRLC also asserts the law as narrowly construed in Green Mountain Future remains vague. This Court agrees with the Vermont court that “supporting or opposing one or more candidates” is sufficiently clear. Green Mountain Future, slip op. at 13. The Supreme Court in McConnell determined that “[t]he words ‘promote,’ ‘oppose,’ ‘attack,’ and ‘support,’” in campaign finance law, “ ‘provide explicit standards for those who apply them’ ” and “ ‘give the person of ordinary intelligence a reasonable opportunity to know what is prohibited.’ ” 540 U.S. at 170 n. 64, 124 S.Ct. 619 (quoting Grayned, 408 U.S. at 108-09, 92 S.Ct. 2294); see also McKee, 649 F.3d at 63 (finding “promoting,” “support,” and “opposition” not vague in the context of several Maine campaign finance law definitions); Nat’l Org. for Marriage v. Daluz, 654 F.3d 115, 120 (1st Cir.2011) (finding the phrase “ ‘support or defeat a candidate’ ” was not vague when it referred to independent expenditures that must be disclosed under Rhode Island law); N.C. Right to Life, Inc. v. Leake (NCRL III), 525 F.3d 274, 318 (4th Cir.2008) (Michael, J. dissenting). It is true that the Fifth Circuit found vague Louisiana’s PAC definition, which also incorporated the phrase “ ‘supporting or opposing.’ ” Ctr. for Individual Freedom v. Carmouche, 449 F.3d 655, 663-66 (5th Cir.2006), cert. denied, 549 U.S. 1112, 127 S.Ct. 938, 166 L.Ed.2d 704 (2007). But in that statute, “ ‘supporting or opposing’ ” was paired with, “ ‘or otherwise influencing,’ ” a phrase that potentially broadened the definition’s scope and that had not been narrowed by state decision as in Vermont. Id. The decision in Green Mountain Future distinguishes this case from Carmouche. On the strength of the clear statement in McConnell and subsequent cases, the Court concludes “supporting or opposing one or more candidates” is not vague. Under the same reasoning, VRLC’s vagueness challenge to “contribution” and “expenditure,” which are separately defined constituent pieces of the PAC definition, does not succeed. See Vt. Stat. Ann. tit. 17, § 2801(4). Both terms refer to funds “for the purpose of influencing an election, advocating a position on a public question, or supporting or opposing one or more candidates.” Id. §§ 2801(2), (3). “Advocating a position on a public question” is both clear and plainly inapplicable to VRLC, since “public question” is separately defined to mean “an issue that is before the voters for a binding decision.” Id. § 2801(8). As relevant, the potentially vague language boils down to: “for the purpose of influencing an election ... or supporting or opposing one or more candidates.” Id. §§ 2801(2), (3). So limited, it is nearly identical to the language in the PAC definition Green Mountain Future construed narrowly and upheld. Even though Green Mountain Future did not discuss “contribution” and “expenditure,” its reasoning makes “ ‘such a construction ... reasonable and readily apparent.’ ” Stenberg v. Carhart, 530 U.S. 914, 944-945, 120 S.Ct. 2597, 147 L.Ed.2d 743 (2000) (quoting Boos v. Barry, 485 U.S. 312, 330, 108 S.Ct. 1157, 99 L.Ed.2d 333 (1988)). For the same reason that language is not vague in the context of the PAC definition, it is not vague as used in defining contribution and expenditure. The Court finds the PAC, contribution, and expenditure definitions, as limited in Green Mountain Future, not unconstitutionally vague. 2. Electioneering Communications & MMA VRLC argues three grounds for finding the electioneering communications and MMA provisions infirm for vagueness. First, it objects to essentially the same definitional language as the “supporting or opposing” clause from the PAC, contribution, and expenditure context. An electioneering communication “promotes or supports a candidate for that office, or attacks or opposes a candidate for that office, regardless of whether the communication expressly advocates a vote for or against a candidate.” Vt. Stat. Ann. tit. 17, § 2891. For the reasons just described, such language is not vague. Indeed, it is nearly verbatim the phrase interpreted in McConnell, 540 U.S. at 170 n. 64, 124 S.Ct. 619. Compare Vt. Stat. Ann. tit. 17, § 2891, with 2 U.S.C. § 431(20)(A)(iii). Second, focusing on the electioneering communications identification requirement, VRLC argues the phrase “on whose behalf’ is vague. That provision reads: All electioneering communications shall contain the name and address of the person, political committee, or campaign who or which paid for the communication. The communication shall clearly designate the name of the candidate, party, or political committee by or on whose behalf the same is published or broadcast. Vt. Stat. Ann. tit. 17, § 2892 (emphasis added). The Court finds the text straightforward. The first sentence requires the communication sponsor to include his or her name and address on the communication. The second sentence applies in the instance in which the sponsor is not also the communication’s beneficiary. When that is the case, the communication must include the name, but need not include the address, of the beneficiary. Crossman Deck ¶ 32 (“If the communication is not made on the behalf of the person or entity who paid for it, then the communication must also clearly designate the name of the candidate, party, or PAC on whose behalf it was published or broadcast.”). VRLC argues that the phrase leaves unclear when a communication is made “on behalf of’ another party so as to trigger the second sentence’s requirement. However, “on whose behalf,” as underscored by its use elsewhere in related Vermont law, contemplates an agreement between the sponsor and the beneficiary to run the communication, not incidental or uncoordinated aid. See Farhane, 634 F.3d at 142 (“we do not look at statutory language in isolation to determine if it provides adequate notice of conduct proscribed or permitted. Rather, we consider language in context”). For instance, a “related campaign expenditure made on the candidate’s behalf’ must be “intentionally facilitated by, solicited by or approved by the candidate or the candidate’s political committee.” Vt. Stat. Ann. tit. 17, § 2809(c); Randall, 548 U.S. at 238, 126 S.Ct. 2479. The same is true of lobbyist disclosure requirements. Vt. Stat. Ann. tit. 2, § 263(c)(4) (“the lobbyist shall provide the name of the employer, the name of the person, group or coalition on whose behalf he or she lobbies and a description of the matters for which lobbying has been engaged by the employer”). Since “on whose behalf’ requires coordination between the party benefited and the party paying for the communication, its application is relatively narrow and clearly defined. The Court does not find it vague. VRLC lastly contends that “relating to” in the MMA reporting requirement is vague. The law provides that persons engaging in MMA of greater than $500 within thirty days of an election must file a report with the Secretary and send a copy to each candidate who is mentioned or whose likeness appears in the communication. Vt. Stat. Ann. tit. 17, § 2893(b). The required report “shall identify the person who made the expenditure with the name of the candidate involved in the activity and any other information relating to the expenditure that is required to be disclosed under the provisions of sections 2803(a) and (b) of this title.” Id. (emphasis added). Sections 2803(a) and (b) enumerate requirements for all campaign finance reports. Moreover, they require the Secretary to provide a standard reporting form conforming to the requirements. Id. § 2803(a). The Secretary has produced a one-page, MMA-specifie form, and it sets forth the information “relating to the expenditure” required to be produced. Crossman Decl. Ex. 11. The law is itself clear and further clarified by administrative action, and the Court does not find it unconstitutionally vague. None of the above language “fails to provide a person of ordinary intelligence fair notice of what is prohibited, or is so standardless that it authorizes or encourages seriously discriminatory enforcement.” Williams, 553 U.S. at 304, 128 S.Ct. 1830. The Court denies VRLC’s vagueness claims. B. Overbreadth VRLC next asks the Court to overturn the PAC, electioneering communications, and MMA provisions for First Amendment overbreadth. A law is over-broad, and should be struck down, if “ ‘a substantial number’ of its applications are unconstitutional, ‘judged in relation to the statute’s plainly legitimate sweep.’ ” Wash. State Grange v. Wash. State Republican Party, 552 U.S. 442, 450 n. 6, 128 S.Ct. 1184, 170 L.Ed.2d 151 (2008) (quoting New York v. Ferber, 458 U.S. 747, 769-71, 102 S.Ct. 3348, 73 L.Ed.2d 1113 (1982)). More liberal standards apply to making overbreadth claims in the free speech context than to facial vagueness claims; even if a plaintiff fails to show a law is vague as applied to any of its own speech, it retains standing to assert the law is overbroad in violation of others’ free speech rights. See Broadrick, 413 U.S. at 612, 93 S.Ct. 2908. In addition, a law cannot be rescued from overbreadth by the government’s promises to enforce it narrowly. United States v. Stevens, — U.S. -, 130 S.Ct. 1577, 1591, 176 L.Ed.2d 435 (2010). Still, the plaintiffs mere conjecture as to hypothetical cases in which the law could be applied unconstitutionally is not enough. Williams, 553 U.S. at 303, 128 S.Ct. 1830. Moreover, courts are reluctant to invalidate laws on overbreadth grounds, since it is considered “strong medicine,” to be used “sparingly and only as a last resort.” Broadrick, 413 U.S. at 613, 93 S.Ct. 2908. 1. PAC Definition and Disclosure In arguing Vermont’s PAC definition is overbroad, VRLC relies on two contentions. It contends first that PAC status is an “onerous” burden as a matter of law, meaning any law that triggers it must be analyzed under strict scrutiny. Second, it contends that the PAC definition is not properly tailored to fit the government’s interest in regulating speech, as only entities with the “major purpose” of supporting or opposing candidates may be defined as PACs, a limit the Vermont statute does not reflect. VRLC’s first argument is based on the principle that PACs are “burdensome alternatives” to direct campaign spending by corporations or unions, Citizens United, 130 S.Ct. at 897-98. It emphasizes that Vermont’s PAC definition imposes a “package” of heavy restrictions on those groups falling within its reach, not just the disclosure requirements that are reviewed under exacting scrutiny, id. at 914. Thus, the PAC definition itself must be rigorously reviewed without focus on the type of regulation it may trigger, and, indeed, VRLC denies any assault on the PAC disclosure requirements themselves. Pis.’ Summ. J. Br. 38 n. 39. Prior to Citizens United, the Fourth Circuit appeared to adopt a similar approach, examining North Carolina’s PAC definition in light of its holistic burdens. NCRL III, 525 F.3d at 286, 299-300; but cf. Real Truth About Abortion, Inc. v. Fed. Election Comm’n, 681 F.3d 544, 547-50 (4th Cir.2012) (rejecting plaintiffs request to apply strict, instead of exacting, scrutiny to review definitional language that triggered PAC disclosure and organizational requirements). Respectfully, this Court finds the strong weight of authority post-Citizens United, as well as the late Judge Michael’s thoughtful dissent in NCRL III, more persuasive in showing that it is the underlying regulation, not the PAC definition, that counts. McKee, 649 F.3d at 56 (1st Cir.) (“NOM’s attempt to ascribe a free-standing significance to the PAC label is unpersuasive. It is not the designation as a PAC but rather the obligations that attend PAC designation that matter for purposes of First Amendment review.”); Human Life of Wash. Inc. v. Brumsickle, 624 F.3d 990, 1012-13 (9th Cir.2010), cert. denied, - U.S. -, 131 S.Ct. 1477, 179 L.Ed.2d 302 (2011); SpeechNow.org v. Fed. Election Comm’n, 599 F.3d 686, 697 (D.C.Cir.2010) (en banc), cert. denied sub nom., Keating v. Fed. Election Comm’n, — U.S.-, 131 S.Ct. 553, 178 L.Ed.2d 371 (2010); NCRL III, 525 F.3d at 320 (Michael, J. dissenting); see also Yamada, 872 F.Supp.2d at 1048, 2012 WL 983559, at *20 (collecting further cases in support of this proposition and noting, “[t]his makes sense — the purpose of requiring registration as a noncandidate committee is transparency and to enable disclosure”). VRLC has not actually objected to the full suite of burdens it argues Vermont PACs face. While PACs are subject to a $2000 limit on contributions from an individual donor, VRLC did not join FIPE’s challenge to that portion of the law and has not alleged concerns about how contribution restrictions might impact it were it deemed a PAC. While it invokes the federal law banning congressionally chartered banks and corporations and foreign nationals from making contributions, 2 U.S.C. §§ 441b, 441e, it does not show how that law burdensomely applies to it or to any other Vermont PAC. Since VRLC has not raised issue with the contribution restriction, it strikes the Court as improbable that the challenge relates to any PAC burden other than the registration and reporting disclosure requirements. As such, the Court can do no more than apply exacting scrutiny, lest, in adopting VRLC’s approach, it blur the bright line distinction the Supreme Court has carefully maintained between the scrutiny to apply to spending restraints and to disclosure rules. If Vermont law poses too onerous a burden of compelled transparency for entities falling within the PAC definition, the law should fail exacting scrutiny. Otherwise, it is constitutional as it concerns disclosure. VRLC also argues the PAC definition fails, even under exacting scrutiny, because it does not incorporate “the major purpose” test to limit the groups that may be considered PACs. The Supreme Court first articulated the major purpose test in Buckley, where it reviewed federal PAC disclosure provisions triggered when an organization made campaign expenditures or received contributions of more than $1000. 424 U.S. at 77-79 & n. 105, 96 S.Ct. 612. The Court was concerned that the definition of “contribution” and “expenditure,” terms that in turn defined a political committee, were vague for using the phrase “ ‘for the purpose of ... influencing’ ” an election. Id. at 77, 96 S.Ct. 612. That language made it unclear whether political committees included “groups engaged purely in issue discussion.” Id. at 79, 96 S.Ct. 612. As the Court had already noted, there was no clear line between speech centering on political issues to which a candidate may be linked and speech advocating for or against that candidate’s election. Id. at 42, 96 S.Ct. 612. To narrow the statute, the Court limited the law to “organizations that are under the control of a candidate or the major purpose of which is the nomination or election of a candidate.” Id. at 79, 96 S.Ct. 612 (emphasis added). On that reading, Buckley found, the law would only reach groups that “are, by definition, campaign related,” thus placing them “within the core area sought to be addressed by Congress.” Id. After Buckley, it remained an open question whether “the major purpose” was merely a limiting construction applied to a vague federal law, or whether it was an irreducible First Amendment limit on PAC disclosure laws. VRLC argues it is the latter, contending that Vermont’s definition must include the major purpose component to prevent the law from sweeping in groups that do not engage in candidate advocacy as their major purpose. The State would have the Court hold the former. Vermont law does not by its plain terms include the major purpose test, as it covers entities that make greater than $500 in contributions and expenditures “for the purpose of supporting or opposing one or more candidates____” Vt. Stat. Ann. tit. 17, § 2801(4). The Fourth and Tenth Circuits, in recent cases, applied the major purpose test to state laws in the manner urged by VRLC. NCRL III, 525 F.3d at 288-89 (“[i]f organizations were regulable merely for having the support or opposition of a candidate as ‘a major purpose,’ political committee burdens could fall on organizations primarily engaged in speech on political issues unrelated to a particular candidate.”); N.M. Youth Organized v. Herrera, 611 F.3d 669, 677-78 (10th Cir.2010); Colo. Right to Life Comm. v. Coffman, 498 F.3d 1137, 1153 (10th Cir.2007). The NCRL III court noted that states had the less burdensome alternative of imposing one-time disclosure in the instances in which a non-major purpose organization engaged in campaign spending, rather than requiring regular PAC reporting. 525 F.3d at 290. The Court is unpersuaded that the reasoning in those cases applies here. Principally, McConnell made clear that the line between express and issue advocacy was a tool of statutory construction and not of independent constitutional moment. It explained that “[i]n narrowly reading the FECA provisions in Buckley to avoid problems of vagueness and overbreadth, we nowhere suggested that a statute that was neither vague nor overbroad would be required to toe the same express advocacy line.” 540 U.S. at 192, 124 S.Ct. 619. It then concluded that the First Amendment does not “independent of our precedents ... erect[ ] a rigid barrier between express advocacy and so-called issue advocacy.” Id. at 193, 124 S.Ct. 619. Citizens United emphasized this point strongly in the area of disclosure, rejecting the effort to use the functional equivalent of express advocacy test, developed in the context of electioneering spending, to mark the First Amendment boundary of the electioneering transparency provisions at issue there. 130 S.Ct. at 915. Thus, “in light of Citizens United ... the distinction between issue discussion and express advocacy has no place in First Amendment review of these sorts of disclosure-oriented laws.” McKee, 649 F.3d at 54-55 (applying this analysis to Maine’s non-major-purpose PAC registration provisions, id. at 55 n. 29); see Brumsickle, 624 F.3d at 1016 (“[Ijmposing disclosure obligations on communicators engaged in issue advocacy is not per se unconstitutional; instead, the constitutionality of the obligations is determined by whether they are substantially related to a sufficiently important governmental interest.”). The major purpose limiting construction was the product of a vague statute, not of the First Amendment. It is also for this reason that the Court disagrees with VRLC that the Second Circuit’s decision in United States v. National Committee for Impeachment, 469 F.2d 1135 (2d Cir.1972) governs the analysis of Vermont law and requires the major purpose test. National Committee for Impeachment grappled with the same language in the federal statute prior to Buckley and was a source for the Supreme Court’s major purpose test. See Buckley, 424 U.S. at 79 n. 106, 96 S.Ct. 612. The case dealt with whether - a group that published a lengthy ad in the New York Times in support of President Nixon’s impeachment and in opposition to the Vietnam War was required to register as a PAC. 469 F.2d at 1135-38. The Court found the ad, which also praised pro-impeachment members of the U.S. House of Representatives and called for the potential creation of a pro-impeachment third party, id., “[qualitatively, as well as quantitatively,” in “support of an impeachment resolution, not the election of political candidates.” Id. at 1140. It found that to regulate the sponsoring group as a PAC solely on the basis of such an ad would create “serious constitutional issues on which we express no opinion.” Id. To avoid that result, it limited “ ‘for the purpose of influencing’ ” with the major purpose test and found that based on the ad’s focus on impeachment, the group did not meet that standard. Id. at 1141. The test put forward in National Committee for Impeachment was prophylactic in nature, imposed, as the Second Circuit clarified prior to McConnell, “[l]est any movement dealing with national policy be subjected to the onerous requirements devised to police political campaigns, a result we refused to believe Congress intended.” Fed. Election Comm’n v. Survival Educ. Fund, Inc., 65 F.3d 285, 294 (2d Cir.1995). As outlined in the tailoring analysis below, Vermont’s provision poses little threat of regulating beyond the election context. Moreover, McConnell and Citizens United made clear that a concern for separating issue advocacy and express advocacy is not rooted in overbreadth but rather in vagueness. As described supra, Vermont’s PAC definition, as narrowed, is not unconstitutionally vague. Indeed, the troubling “ ‘for the purpose of ... influencing’ ” language that spurred the Court in Buckley to impose the major purpose requirement has been functionally excised from the Vermont statute. Green Mountain Future, slip op. at 12. In the present setting, the justification for applying the major purpose test evaporates. That conclusion is reinforced by the peculiar results that may arise in applying the major purpose test as a constitutional floor for PAC disclosure. For instance, a group that spends $1.5 MM of a total of $6 MM on promoting candidates probably would not qualify, but one that spends $1500 of a total budget of $2000 probably would. See Nat’l Org. for Marriage v. McKee, 723 F.Supp.2d 245, 264 (D.Me.2010), vacated in part on other grounds, 649 F.3d 34 (1st Cir.2011). A national organization might have the major purpose of advancing candidates for state office in every state, but could avoid registering as a PAC in any particular state. Nat’l Org. for Marriage v. McKee, 666 F.Supp.2d 193, 210 n. 96 (D.Me.2009). The test also allows a group that might fit the major purpose definition on its own simply to fold itself into another, larger group that does not, evading the law’s requirements. Brumsickle, 624 F.3d at 1012. Those outcomes emphasize that the test was merely “an artifact of the Court’s construction of a federal statute.” McKee, 649 F.3d at 59. VRLC responds that failure by Vermont and other states to incorporate the major purpose test would create the greater perversion. Specifically, it contends that national political advocacy organizations that do not have the major purpose of participating in any single state’s candidate elections would be forced to reveal sensitive information about their activities in accordance with the requirements of the state with the broadest PAC definition and most exacting PAC disclosure laws. Even though Vermont law does not currently incorporate the major purpose test, VRLC has provided no evidence to substantiate its concern. More to the point, because the law defines “election” and “candidate” to include only Vermont elections and Vermont candidates, Vt. Stat. Ann. tit. 17, §§ 2801(1), (7), the Court is not troubled by the prospect that a national organization would be forced to disclose to the Secretary its non-Vermont contributions and expenditures or to abide by Vermont’s contribution limit for non-Vermont-related contributions. See id. §§ 2801(2), (3) (defining contribution and expenditure in relation to support or opposition for “candidates” in an “election”). In relation to a disclosure statute that is not vague, the major purpose test has no relevance, and Vermont was not required to incorporate it. Having established that the frame of analysis for reviewing the PAC provisions is the disclosure regulation they trigger and having found the major purpose test is unnecessary, the Court turns to its exacting scrutiny analysis. The disclosure required of PACs bears a substantial relation to Vermont’s sufficiently important interest in permitting Vermonters to learn of the sources of significant influence in their state’s elections. See Citizens United, 130 S.Ct. at 914. Vermont imposes reasonable requirements: (1) registering with the Secretary within ten days of satisfying the dollar thresholds for PAC status, which involves designating a treasurer and bank account and then disclosing that information, Vt. Stat. Ann. tit. 17, §§ 2802, 2831(a); (2) filing campaign finance reports, at most six in an election year and one in a non-election year, Id. § 2811(d); Crossman Decl. ¶ 9; (3) listing contributors of over $100, along with their full names, addresses and dates of contribution, id. § 2803(a); and (4) totaling to-date contributions and expenditures, id. §§ 2803(a)(2), (b). See McKee, 649 F.3d at 58; Brumsickle, 624 F.3d at 997-98, 1013. By admission of Sharon Toborg, treasurer for VRLC, PC and FIPE, FIPE’s campaign finance reports took no more than ten to fifteen minutes to complete. Sharon Toborg Rule 30(b)(6) Dep. for FIPE, Defs.’ Mot. for Summ. J. Ex. A (“FIPE Dep.”), at 43-44, ECF No. 168-3. Moreover, to the extent constitutional concerns in requiring disclosure of issue advocacy remain after Citizens United, Vermont’s PAC disclosure law does not cover a “substantial amount of non-electoral speech.”- NCRL III, 525 F.3d at 327 (Michael, J. dissenting); see Wash. State Grange, 552 U.S. at 450 n. 6, 128 S.Ct. 1184. As narrowed by state court decision, PAC status is triggered only when an organization’s contributions and expenditures to support or oppose candidates each pass the $500 threshold in a single calendar year. Green Mountain Future, slip op. at 12; Vt. Stat. Ann. tit. 17, § 2801(4). In addition, as limited, the contribution and expenditure definitions are tightly construed to apply only to funding “supporting or opposing one or more candidates” or “advocating a position on a public question.” See id. §§ 2801(2), (3). The only forms of speech a PAC must report to the Secretary are contributions and expenditures. See id. § 2803. That means PACs need only report speech that is meant to advance or defeat the cause of a candidate or a ballot measure, not speech that broadcasts a stance on an issue. The statute also excludes an organization’s charitable work. If VRLC were at some point to become a PAC, it would not need to report, to take an example, donations received and funds spent to support crisis pregnancy centers. That activity would not meet the definition of a contribution or expenditure under Vermont law. Since the PAC provisions neither place unconstitutionally onerous burdens on PACs nor sweep overbroadly to require disclosure of a substantial amount of immune speech, the Court finds them constitutional. 2. MMA and Electioneering Communications VRLC also argues the MMA and electioneering communications disclosure provisions are overbroad. VRLC relies on the assumption that, as a matter of constitutional law, when states seek to compel disclosure not connected to PAC status they may only do so concerning two narrow types of speech: (1) express advocacy; and (2) federally-defined electioneering communications, as approved in Citizens United, 130 S.Ct. at 914-16. Pis.’ Summ. J. Br. 44. VRLC’s position amounts to a belief that lower courts examining state law may only approve of mandated disclosure provisions defined in precisely the same manner as past Supreme Court interpretations of federal statutes. See Pis.’ Summ. J. Br. 45-47. To do otherwise, VRLC argues, would spring the traps of vagueness or over-breadth. See Pis.’ Summ. J. Br. 46. Based on its reading of the case law, the Court disagrees. The Supreme Court has not implied that its reasoning on disclosure laws was limited to finely detailed copies of the cases before it. Even so, the provisions upheld in Citizens United were electioneering-related disclosure and identification regulations broadly similar to Vermont’s MMA and electioneering laws, respectively. Compare 130 S.Ct. at 913-14, with Vt. Stat. Ann. tit. 17, §§ 2891-93. Vermont’s MMA and electioneering provisions do go beyond the federal law’s requirements in some way's, but are narrower than the federal equivalent in others. Examining those differences individually, the Court concludes they do not render Vermont law over-broad. Generally, federal law defines electioneering communications as “any broadcast, cable, or satellite communication” referring to a “clearly identified candidate for Federal Office” that is run within 60 days before a general or 30 days before a primary election, and that is “targeted to the relevant electorate” in congressional elections. 2 U.S.C. § 434(f)(3)(A). Disclosure is required when the communications’ sponsor spends more than $10,000 in a calendar year on them. Id. § 434(f)(1). Once past the $10,000 mark, the sponsoring entity must file a report with the Federal Elections Commission within twenty-four hours to identify itself, its “custodian of the books and accounts,” its principal place of business (if not an individual), the amount and source of any single disbursement over $200, the elections and names of candidates to which the communications pertain, and the names and addresses of all contributors of more than $1000 to the sponsor or a segregated bank account used by it since the start of the last calendar year. Id. §§ 434(f)(l)-(2). Vermont’s MMA provisions reach more media than the federal equivalent above, including also “mass mailings, literature drops, newspaper and periodical advertisements, robotic phone calls,