Full opinion text
LIPEZ, Circuit Judge. This appeal requires us to address the constitutionality of several Maine election laws governing, inter alia, the registration of political action committees (“PACs”) and the disclosure and reporting of information about expenditures made for election-related advocacy. Appellant National Organization for Marriage (“NOM”), a New Jersey-based nonprofit corporation organized for the purpose of providing “organized opposition to same-sex marriage in state legislatures,” contends that Maine’s laws are unconstitutionally vague and over-broad. Claiming a chill of its First Amendment-protected advocacy efforts in Maine, NOM brought a facial and as-applied challenge seeking an injunction against the laws’ enforcement and a declaration of their unconstitutionality. On summary judgment, the district court largely rejected NOM’s claims, agreeing only that the phrase “for the purpose of influencing,” which the court severed from the provisions in which it appeared, was unconstitutionally vague. NOM renews here its arguments challenging Maine’s laws on vagueness and overbreadth grounds. NOM asks as well that we reverse a ruling by the district court unsealing the trial record. In turn, the defendants (various Maine officials) contend that the district court erred in finding vague, and severing from Maine’s statutes, the phrase “for the purpose of influencing.” After careful consideration of the parties’ arguments and key precedents, we conclude that Maine’s laws pass constitutional muster. Central to our holding is the nature of the laws NOM challenges here. These provisions neither erect a barrier to political speech nor limit its quantity. Rather, they promote the dissemination of information about those who deliver and finance political speech, thereby encouraging efficient operation of the marketplace of ideas. As the Supreme Court recently observed, such compulsory “transparency enables the electorate to make informed decisions and give proper weight to different speakers and messages.” Citizens United v. FEC, — U.S. -, 130 S.Ct. 876, 916, 175 L.Ed.2d 753 (2010). While we acknowledge that disclosure can, in some cases, unduly burden or chill political speech, there is no evidence that the Maine laws at issue here have had such a deleterious effect on NOM or its constituents. We agree with the appellees that the use of “for the purpose of influencing” in the statutes at issue, given the appropriately limited reading offered by Maine’s Commission on Governmental Ethics and Election Practices, is not unconstitutionally vague, and therefore we vacate the district court’s holding as to that phrase and the consequent severance of portions of Maine’s statutes. We otherwise affirm the district court’s judgment in its entirety. I. Statutory and Procedural Background A. Maine’s Election Laws Maine has enacted a comprehensive set of election laws that embraces, among other things, contribution limits, a public financing system for state-office candidates, and various reporting and disclosure requirements for those engaged in election-related advocacy. We have previously described the contribution limit and public financing aspects of Maine’s regulation of elections — which are not at issue here — in some detail. See Daggett v. Comm’n on Governmental Ethics & Election Practices, 205 F.3d 445, 450-52 (1st Cir.2000). The provisions challenged here, all relating solely to reporting and disclosure, fall into three categories: rules governing PACs, rules governing “independent expenditures,” and general attribution and disclaimer requirements. 1. PAC Provisions Maine’s PAC provisions are, as the appellees aptly characterize them, “pure disclosure laws.” Maine imposes no limitation on the amount of money PACs may raise, nor does it cap the sum a PAC may-spend independently of a candidate or candidate committee. If they contribute money directly to a candidate, PACs are subject to the same per-candidate contribution limits — $750 per election for gubernatorial candidates and $350 per election for legislative candidates — as any other donor. See Me.Rev.Stat. tit. 21-A, § 1015(1), (2). The only PAC-specific requirements relate to registration, recordkeeping, and reporting. An organization may qualify as a PAC under Maine law in one of several ways, of which two are relevant here. The first pertains to so-called “major-purpose” PACs. An organization that “has as its major purpose initiating, promoting, defeating or influencing a candidate election, campaign or ballot question” must register as a PAC in Maine if it receives contributions or makes expenditures aggregating more than $1,500 in a given calendar year for that purpose. Id. §§ 1052(5)(A)(4), 1053. The second relates to “non-major-purpose PACs,” which are subject to a significantly higher contribution/expenditure threshold for registration. Specifically, Maine law requires that an organization register as a PAC if it “does not have as its major purpose promoting, defeating or influencing candidate elections but ... receives contributions or makes expenditures aggregating more than $5,000 in a calendar year for the purpose of promoting, defeating or influencing in any way the nomination or election of any candidate to political office.” Id. §§ 1052(5)(A)(5), 1053. Within seven days of exceeding the relevant contribution or expenditure threshold, a PAC must register with the Maine Commission on Governmental Ethics and Election Practices (the “Commission”). Id. § 1053. Registration requires that the organization supply a name and address for the PAC; identify its form of organization and date of origin; name its treasurer, principal officers, and primary fundraisers and decisionmakers; and indicate which candidates, committees, referenda, or campaigns it supports or opposes. Id. An organization need not make any formal changes, such as forming a separate legal entity or creating a segregated fund, to operate as a PAC in Maine. Once registered, a PAC is subject to two ongoing obligations under Maine law. First, the PAC treasurer must maintain records of certain election-related expenditures and contributions for four years following the election to which the records pertain. Id. § 1057. Second, the PAC must electronically file campaign finance reports on a quarterly basis, with additional reports due eleven days before any primary or general election and forty-two days after. Id. § 1059. The contents of the report vary by type of PAC. A major-purpose PAC must report any contribution to the PAC of more than $50 (including the name, address, occupation, and place of business of the contributor), while a non-major-purpose PAC reports only those contributions made “for the purpose of promoting, defeating or influencing a ballot question or the nomination or election of a candidate to political office.” Id. § 1060(6). The reporting of expenditures breaks down along similar lines: major-purpose PACs report all expenditures, including operational and administrative expenses, whereas non-major-purpose PACs report “only those expenditures made for the purpose of promoting, defeating or influencing a ballot question or the nomination or election of a candidate to political office.” Id. § 1060(4), (5), (7). Maine law also explicitly requires PACs that are organized in another state to comply with all applicable registration and reporting requirements. See id. § 1053-B. There is, however, a narrow exemption: out-of-state PACs may contribute to candidates, party committees, and PACs in Maine without registering with the Commission, provided that (1) such contributions are the out-of-state PAC’s only financial activity within Maine and (2) the out-of-state PAC “has not raised and accepted any contributions during the calendar year to influence an election or campaign” in Maine. Id. 2. “Independent Expenditure” Provision In addition to its PAC-specific requirements, Maine’s election laws also require across-the-board reporting of certain “independent expenditures.” At a general level, an “independent expenditure” is any payment or obligation made “for the purpose of influencing the nomination or election of any person to political office” other than a direct contribution to candidates and their campaign committees. Id. §§ 1012(3), 1019-B(1). Maine law provides that any individual or entity making independent expenditures aggregating more than $100 over the course of a particular candidacy must file a report with the Commission. Id. § 1019-B(3). That report must simply identify the expenditures by date, payee, and purpose, state whether the expenditures were made in support of or opposition to the relevant candidate, and state under oath or affirmation whether the expenditures were coordinated with a candidate or candidate committee. Id. An expenditure may qualify as an “independent expenditure” in one of two ways. First, an expenditure will fall within the independent expenditure reporting requirement where it is made to finance a communication that “expressly advocates the election or defeat of a clearly identified candidate” and it is not a direct contribution to a candidate or candidate’s committee. Id. § 1019-B(1)(A). Second, certain expenditures for communications made close to an election — twenty-one days before a primary and thirty-five days before the general election — are presumed to be “independent expenditures.” Id. The presumption applies only to an expenditure “made to design, produce or disseminate a communication that names or depicts a clearly identified candidate” in a race where at least one candidate has accepted public financing. Id. § 1019-B(1)(B). The person making the expenditure is afforded a chance to rebut the presumption by filing a written statement with the Commission within forty-eight hours of the expenditure “stating that the cost was not incurred with the intent to influence the nomination, election or defeat of a candidate.” Id. § 1019-B(2). Once a rebuttal statement is filed, the Commission will determine by a preponderance of the evidence, after gathering relevant material, whether the expenditure was incurred with such an intent. Id. 3. Attribution and Disclaimer Requirements Finally, Maine law also requires that political advertisements and certain other political messages contain statements of attribution and disclaimer. The governing statute provides that any “communication expressly advocating the election or defeat of a clearly identified candidate ... clearly and conspicuously state” whether it has been authorized by the candidate (the disclaimer) and state the name and address of the person who financed the communication (the statement of attribution). Id. § 1014(l)-(2). These disclaimer and attribution statements must also be included in any communication shortly before an election that “names or depicts a clearly identified candidate,” unless the communication “was not made for the purpose of influencing the candidate’s nomination for election or election.” Id. § 1014(2-A). 4. Sanctions The Commission may level a variety of sanctions — primarily in the form of fines— for violations of the provisions discussed above. An entity that falls within the definition of a PAC but fails to register may be subject to a civil fine of $250, id. § 1062-A(1), and a PAC’s failure to file reports within thirty days of a reporting deadline can result in a fine of up to $10,000 or a criminal misdemeanor charge. Id. § 1062-A(8). Likewise, violations of the independent expenditure reporting requirement are punishable by a civil fine of up to $5,000. Id. § 1020-A(5-A)(A). Finally, violations of the attribution and disclosure requirements are subject to lesser fines (up to $200 if made within 20 days before an election, and no more than $100 at other times), but may be punished by a special fine of up to $5,000 if the violation was committed with the intent to misrepresent the source or candidate authorization of the advertisement. Id. § 1014(4). B. Procedural History NOM filed the initial complaint in this case in October 2009, shortly before a referendum election in Maine on a raft of issues that included same-sex marriage. The complaint challenged the constitutionality of a provision relating to ballot question committees, Me.Rev.Stat. tit. 21-A, § 1056-B, and was accompanied by motions for a temporary restraining order and a preliminary injunction. Following an expedited hearing, the district court denied NOM’s motion for a temporary restraining order. NOM subsequently amended its complaint to add the claims at issue here: those targeting the constitutionality of Maine’s PAC registration, independent expenditure, and attribution and disclaimer laws. The district court held a hearing on NOM’s motion for a preliminary injunction, consolidated with a bench trial on the merits, on August 12, 2010. The parties stipulated to a joint trial record, which was submitted under seal. At the hearing, the district court expressed doubt about the basis for sealing the record, and subsequently issued an order to show cause why the trial record should be maintained under seal. In a decision issued on August 19, 2010, the district court largely denied NOM’s claims and upheld the constitutionality of the challenged statutes. See Nat’l Org. for Marriage v. McKee, 723 F.Supp.2d 245 (D.Me.2010). Finding that NOM had adequately demonstrated an interest in engaging in expressive activity that was deterred by the prospect of regulation under Maine’s laws, the court held that NOM had standing to challenge the statutes at issue. Id. at 256-58. On the merits, the court found for NOM on only two points. First, the court held the phrase “for the purpose of influencing” to be unconstitutionally vague, citing the treatment of similar language in the Supreme Court’s opinion in Buckley v. Valeo, 424 U.S. 1, 96 S.Ct. 612, 46 L.Ed.2d 659 (1976). Nat’l Org. for Marriage, 723 F.Supp.2d at 261. The phrase (and variants thereof) appears in several places throughout the challenged statutes, including in the definition of a non-major-purpose PAC, the rebuttal provision for presumed independent expenditures (i.e., those made shortly prior to an election), and in the provisions defining which communications are subject to disclaimer and attribution requirements. The court determined that the appropriate remedy was to sever the phrase from the statutes. Id. The most significant impact of this holding was on the independent expenditure statute. Because the rebuttal procedure for presumed independent expenditures was dependent on the term “influencing,” the court’s ruling severed the entire rebuttal procedure. Thus, the independent expenditure presumption became conclusive for expenditures for communications clearly identifying a candidate made shortly before an election. The court held that the provision, as altered, nonetheless passed constitutional muster, as recent Supreme Court decisions “have made the rebuttal exercise pointless.” Id. at 265. Second, the court held one of the implementing regulations for the independent expenditure statute unconstitutional, finding that it impermissibly burdened First Amendment speech. Id. at 266. The regulation was one of a pair governing the timing of reporting independent expenditures. The first, which the court upheld, required that independent expenditures of over $100 made within two weeks of an election be reported to the Commission within twenty-four hours. See 94-270-001 Me.Code R. § 10(3)(A). The second required the reporting within twenty-four hours of any independent expenditures aggregating over $250, regardless of when made. Id. § 10(3)(B). Finding the short reporting time frame mandated by both regulations to be burdensome, the court held that the second regulation, unlike the first, could not be justified by a close relationship to “the state’s interest in providing information to voters at precisely the time that such information can be of greatest use.” Nat’l Org. for Marriage, 723 F.Supp.2d at 266. The defendants do not challenge this holding on appeal. In addition to its merits holdings, the district court also ruled that the trial evidence must be unsealed. Explaining that it was “not willing to make a First Amendment decision based upon a sealed record,” the court ordered the parties to refile the record in publicly available form. Id. at 249 n. 4. This timely appeal followed. II. Standing We begin, as we must, with the defendants’ argument that NOM lacks standing to prosecute some of its constitutional claims. We review a district court’s ruling on the question of standing de novo. Sullivan v. City of Augusta, 511 F.3d 16, 24 (1st Cir.2007). The standing requirement — or, more accurately, requirements, as standing “comprises a mix of constitutional and prudential criteria,” Osediacz v. City of Cranston, 414 F.3d 136, 139 (1st Cir. 2005) — flows from the limited nature of federal court jurisdiction, and specifically from the grounding of the federal judicial power in “Cases” and “Controversies.” U.S. Const, art. Ill, § 2; Ariz. Christian Sch. Tuition Org. v. Winn, — U.S. -, 131 S.Ct. 1436, 1441-42, 179 L.Ed.2d 523 (2011). The constitutional aspect of standing embraces three core requirements: “First, the plaintiff must have suffered an ‘injury in fact’ — an invasion of a legally protected interest which is (a) concrete and particularized, and (b) ‘actual or imminent, not “conjectural” or “hypothetical.” ’ Second, there must be a causal connection between the injury and the conduct complained of — the injury has to be ‘fairly trace[able] to the challenged action of the defendant, and not ... th[e] result [of] the independent action of some third party not before the court.’ Third, it must be ‘likely,’ as opposed to merely ‘speculative,’ that the injury will be ‘redressed by a favorable decision.’ ” Ariz. Christian Sch., 131 S.Ct. at 1442 (quoting Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61, 112 S.Ct. 2130, 119 L.Ed.2d 351 (1992)). The Supreme Court has overlaid these constitutional dictates with several prudential limitations on standing, including “ ‘the general prohibition on a litigant’s raising another person’s legal rights, the rule barring adjudication of generalized grievances more appropriately addressed in the representative branches, and the requirement that a plaintiffs complaint fall within the zone of interests protected by the law invoked.’ ” Osediacz, 414 F.3d at 139 (quoting Allen v. Wright, 468 U.S. 737, 751, 104 S.Ct. 3315, 82 L.Ed.2d 556 (1984)). In certain facial First Amendment challenges to a statute, we may relax these prudential limitations, Osediacz, 414 F.3d at 141, but the constitutional requirements apply with equal force in every case, Sutliffe v. Epping Sch. Dist., 584 F.3d 314, 326 n. 6 (1st Cir.2009). Defendants do not seek to dispose of the entire suit on standing grounds, but instead surgically target NOM’s standing to challenge Maine’s PAC-related election laws. They assert that NOM lacks standing to bring the PAC claims because it failed to prove that it came within the reach of Maine’s PAC laws, i.e., that NOM’s activities would have qualified it as a PAC. In light of the fact that prudential limitations on standing may be relaxed in the context of First Amendment challenges — and because defendants cite the constitutional standards for standing in making their argument — we construe this argument as a challenge to the adequacy of NOM’s Article III injury-in-fact showing. Preenforcement First Amendment challenges like this one occupy a somewhat unique place in Article III standing jurisprudence. By definition, such cases present us with situations where the government has not yet applied the allegedly unconstitutional law to the plaintiff, and thus there is no tangible injury. However, in these circumstances the Supreme Court has recognized “self-censorship” as “a harm that can be realized even without an actual prosecution.” Virginia v. Am. Booksellers Ass’n, 484 U.S. 383, 393, 108 S.Ct. 636, 98 L.Ed.2d 782 (1988); see also N.H. Right to Life Political Action Comm. v. Gardner, 99 F.3d 8, 13 (1st Cir.1996) (“[I]t is not necessary that a person expose herself to arrest or prosecution under a statute in order to challenge that statute in a federal court.”). The chilling of protected speech may thus alone qualify as a cognizable, Article III injury. The mere allegation of a “chill,” however, will not suffice to open the doors to federal court. See Laird v. Tatum, 408 U.S. 1, 13-14, 92 S.Ct. 2318, 33 L.Ed.2d 154 (1972) (“Allegations of a subjective ‘chill’ are not an adequate substitute for a claim of specific present objective harm or a threat of specific future harm.... ”). Where, as here, the plaintiff claims injury based on such a chilling of speech, the plaintiff must establish with specificity that she is “within the class of persons potentially chilled.” Osediacz, 414 F.3d at 142. This burden will be satisfied by record evidence supporting “an objectively reasonable possibility that she would be subject to the allegedly unconstitutional [law].” Id. at 143; see also N.H. Right to Life, 99 F.3d at 14 (“A party’s subjective fear that she may be prosecuted for engaging in expressive activity will not be held to constitute an injury for standing purposes unless that fear is objectively reasonable.”). NOM challenges three separate provisions of Maine’s PAC laws: the major-purpose PAC definition, the non-major-purpose PAC definition, and the provision governing out-of-state PACs. We examine in turn whether the record supports an “objectively reasonable possibility” that each provision would be applied to NOM, Osediacz, 414 F.8d at 143, and then turn briefly to a related inquiry specific to NOM’s vagueness challenges to the PAC statutes. A. Standing to Challenge Major-Purpose PAC Provision It is plain that NOM has no objectively reasonable apprehension of being regulated as a major-purpose PAC. Among other things, a major-purpose PAC must have “as its major purpose initiating, promoting, defeating or influencing a candidate election, campaign or ballot question” in Maine. Me.Rev.Stat. tit. 21-A, § 1052(5)(A)(4). NOM identifies itself as a nonprofit advocacy organization with a national scope, dedicated to providing “organized opposition to same-sex marriage in state legislatures.” NOM’s advocacy efforts and expenditures have spanned the country, with significant expenditures in California, Iowa, New York, and New Hampshire, among others. In 2009, the year of NOM’s largest expenditures in Maine (made to support repeal of Maine’s same-sex marriage law), NOM spent $1.8 million in Maine out of $8 million in total expenditures for the year. In light of this record, NOM does not have as its “major purpose” election advocacy in Maine, and it is accordingly not subject to regulation as a major-purpose PAC. NOM therefore lacks standing to challenge § 1052(5)(a)(4). B. Standing to Challenge Non-Major-Purpose PAC Provision It is a closer question whether the record reveals an objectively reasonable possibility that NOM would be regulated as a non-major-purpose PAC under Maine law. To so qualify, NOM would have to anticipate receiving contributions or making expenditures of more than $5,000 in a year “for the purpose of promoting, defeating or influencing in any way the nomination or election of any candidate to political office.” Me.Rev.Stat. tit. 21-A, § 1052(5)(A)(5). The evidence is inconclusive as to whether NOM actually crossed the $5,000 threshold during the 2010 election cycle. However, we need not determine whether NOM in fact became subject to the provision during the relevant period, because NOM claims injury based upon self-censorship in anticipation of the law’s application to it, and not upon the actual burdens of the law. NOM’s executive director, Brian Brown, testified — consistently with the allegations in NOM’s complaint — that NOM’s fear of enforcement of Maine’s election laws was curtailing NOM’s speech, and that “[u]ntil Maine’s law is changed,” NOM was “not going to expend precious resources” becoming involved in campaigns in the state. The appropriate inquiry, then, is whether it was objectively reasonable for NOM to believe that the non-major-purpose PAC provision might apply to it and that it would have to curtail its activities in Maine to avoid such a result. The record evidence confirms that NOM’s fears were objectively reasonable and led NOM to engage in self-censorship. The complaint, which was verified by Brown, explained that NOM sought to engage in a variety of forms of election-related speech, including “radio ads, direct mail, and publicly accessible Internet postings of its radio ads and direct mail.” NOM alleged that some portion of these advertisements would relate to “clearly identified candidates for state or local offices.” To this end, NOM discussed potential advertisements with a marketing vendor, and went so far as to have the vendor create three template advertisements (specifically, copy for two broadcast advertisements and one mailer) to be used in not-yet-identified candidate races. One such template, titled “Consequences,” raised fears that legalizing same-sex marriage would lead to schools teaching children about same-sex relationships, and concluded: Legislator Z and some politicians in Maine can’t fix the real problems in these troubled times, but they’ve got time to push gay marriage on Maine families? Call Legislator Z and tell him/ her: “Don’t mess with marriage.” While the record does not indicate how much the contemplated advertisements would cost, NOM alleged generally that each of its communications costs more than $250. The advertisements were never used, in line with NOM’s claim to have curtailed its planned speech. The record also contained evidence that NOM had made political expenditures in Maine in the past, including contributions of $1.8 million in 2009 to a committee opposed to Maine’s same-sex marriage law. We agree with the district court that, although NOM’s “showing certainly could have been stronger,” Nat’l Org. for Marriage, 723 F.Supp.2d at 258, NOM has met its standing burden with respect to its challenge to § 1052(5)(A)(5). The burden of proving that one’s speech was chilled is a modest one. See Osediacz, 414 F.3d at 143. The record evidence adequately establishes both “an objectively reasonable possibility” that NOM would be subject to Maine’s requirements for non-major-purpose PACs if it engaged in its intended speech, and that NOM forwent political speech to avoid the alleged burdens (and possible penalties for non-compliance) attending the non-major-purpose PAC provision. Id. Such self-censorship in the face of possible legal repercussions suffices to show Article III injury. See N.H. Right to Life, 99 F.3d at 13 (“[A]n actual injury can exist when the plaintiff is chilled from exercising her right to free expression or forgoes expression in order to avoid enforcement consequences.”). C. Standing to Challenge Out-of-State PAC Provision We next examine NOM’s standing to challenge § 1053-B, which provides generally that a “political action committee organized outside of [Maine] shall register and file reports with the [C]ommission” in accordance with Maine’s PAC laws. Me. Rev.Stat. tit. 21-A, § 1053-B. The question of whether NOM might be considered a “political action committee” retreads ground we have just covered. Maine law defines “political action committee” to include, among other things, a non-major-purpose PAC. Moreover, the record shows that NOM, which operates from New Jersey, is organized as a Virginia nonprofit. Thus, there is no question that NOM is “organized outside of [Maine],” and there is a reasonable possibility that it would be considered a “political action committee” within the meaning of the statute. NOM therefore has standing to challenge the out-of-state PAC provision. D. Standing to Bring Vagueness Challenge We last address a standing-related argument specific to NOM’s vagueness claims. Defendants argue that NOM cannot bring a vagueness challenge to the non-major-purpose PAC definition, as well as to its corresponding definition of the term “expenditure,” because NOM’s advocacy efforts were clearly covered by the provisions’ terms. In so arguing, defendants rely on the well-established proposition that 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 Hoffman Estates v. Flipside, Hoffman Estates, Inc., 455 U.S. 489, 495, 102 S.Ct. 1186, 71 L.Ed.2d 362 (1982)). Defendants contend that certain postcards NOM sent in September 2010 targeting state legislative candidates were unambiguously covered by the non-major-purpose PAC statute and expenditure definition, i.e., that they were “for the purpose of promoting, defeating or influencing in any way” a candidate election, Me.Rev. Stat. tit. 21-A, § 1052(5)(A)(5), and “for the purpose of influencing the ... election of any person to political office; or for the initiation, support or defeat of a campaign,” id § 1052(4)(A)(1). The defendants’ argument is off-target for at least two reasons. First, the question of whether the non-major-purpose PAC provisions clearly applied to NOM’s September mailings is irrelevant to NOM’s standing to bring its vagueness claims. Because this is a preenforeement challenge based on conduct forgone due to an alleged chill, the appropriate focus for the defendants’ arguments would be on whether “the statutory terms are clear in their application to [NOM’s] proposed, conduct.” Humanitarian Law Project, 130 S.Ct. at 2720 (emphasis added). Moreover, the judgment in this case was entered and NOM’s appeal was filed in August 2010, and thus evidence of NOM’s September 2010 advocacy efforts is not properly part of the record on appeal. At the time of the hearing below, NOM had not yet engaged in any advocacy efforts in Maine in 2010. Second, NOM’s claim is not simply a challenge to the vagueness of the provisions as they would be applied to its actual or intended advocacy efforts; NOM also brings a facial challenge to the provisions under the First Amendment over-breadth doctrine. The bar against vagueness challenges by those whose conduct the law clearly proscribes is “relaxed ... in the First Amendment context, permitting plaintiffs to argue that a statute is overbroad because it is unclear whether it regulates a substantial amount of protected speech.” United States v. Williams, 553 U.S. 285, 304, 128 S.Ct. 1830, 170 L.Ed.2d 650 (2008). We thus see no bar to reaching the merits of NOM’s vagueness challenge to the non-major-purpose PAC provisions. III. First Amendment Overbreadth Challenges Turning to the merits of NOM’s constitutional challenges, we first address its First Amendment arguments that Maine’s election laws are unconstitutionally overbroad, reviewing those claims de novo. United States v. Morales-de Jesús, 372 F.3d 6, 8 (1st Cir.2004) (constitutional challenges are reviewed de novo). The First Amendment’s guarantee of free speech applies with special vigor to discussion of public policy and the qualifications of political candidates. Buckley v. Valeo, 424 U.S. 1, 14, 96 S.Ct. 612, 46 L.Ed.2d 659 (1976). Indeed, “there is practically universal agreement that a major purpose of [the First] Amendment was to protect the free discussion of governmental affairs.” Mills v. Alabama, 384 U.S. 214, 218, 86 S.Ct. 1434, 16 L.Ed.2d 484 (1966). Accordingly, “[t]he First Amendment affords the broadest protection to such political expression in order ‘to ensure [the] unfettered interchange of ideas for the bringing about of political and social changes desired by the people.’ ” Buckley, 424 U.S. at 14, 96 S.Ct. 612 (alteration in original) (quoting Roth v. United States, 354 U.S. 476, 484, 77 S.Ct. 1304, 1 L.Ed.2d 1498 (1957)). NOM has framed its First Amendment challenges to Maine’s election laws as overbreadth claims, arguing that each law is unconstitutional on its face. Under the overbreadth doctrine, “a statute is facially invalid if it prohibits a substantial amount of protected speech.” Williams, 553 U.S. at 292, 128 S.Ct. 1830. The overbreadth doctrine is “ ‘strong medicine’ ” that should be “employed ... with hesitation, and then ‘only as a last resort.’ ” New York v. Ferber, 458 U.S. 747, 769, 102 S.Ct. 3348, 73 L.Ed.2d 1113 (1982) (quoting Broadrick v. Oklahoma, 413 U.S. 601, 613, 93 S.Ct. 2908, 37 L.Ed.2d 830 (1973)). For that reason, courts “vigorously enforce[] the requirement that a statute’s overbreadth be substantial, not only in an absolute sense, but also relative to the statute’s plainly legitimate sweep.” Williams, 553 U.S. at 292, 128 S.Ct. 1830. A. Distinction Between Issue Discussion and Express Advocacy We first address NOM’s arguments that the statutes challenged here are overbroad because they may reach discussion of issues as well as express advocacy of a candidate’s election or defeat. The division between pure “issue discussion” and “express advocacy” of a candidate’s election or defeat is a conceptual distinction that has played an important, and at times confounding, role in a certain set of modern Supreme Court election law precedents. Though the contours (and significance) of the distinction have never been firmly fixed, the core premise is that regulation of speech expressly advocating a candidate’s election or defeat may more easily survive constitutional scrutiny than regulation of speech discussing political issues more generally. Because a number of NOM’s arguments here raise, both directly and indirectly, this distinction between issue discussion and express advocacy, we pause briefly to describe how the distinction arose and developed. We ultimately conclude, however, that the distinction is not important for the issues addressed in this appeal. 1. Issue/Express Advocacy Distinction Generally The issue discussion/express advocacy distinction has its roots in the Supreme Court’s decision in Buckley v. Valeo. Perhaps the Court’s seminal decision in the area of campaign finance regulation, Buckley resolved a wide-ranging series of challenges to provisions of the Federal Election Campaign Act of 1971 (“FECA”). One of those challenged provisions, of relevance to our discussion here, imposed an absolute cap on independent expenditures, stating that “ ‘[n]o person may make any expenditure ... relative to a clearly identified candidate during a calendar year which, when added to all other expenditures made by such person during the year advocating the election or defeat of such candidate, exceeds $1,000.’ ” Buckley, 424 U.S. at 39, 96 S.Ct. 612 (alterations in original) (quoting 18 U.S.C. § 608(e)). Reviewing this language, the Court first noted that the “use of so indefinite a phrase as ‘relative to’ a candidate” raised serious vagueness concerns. Id. at 41, 96 S.Ct. 612. The Court construed the phrase (by reference to its surrounding terms) as limited to expenditures “advocating the election or defeat of’ a candidate. However, this construction, in the Court’s estimation, merely “refocus[ed] the vagueness question.” Id. at 42, 96 S.Ct. 612. The Court’s evident concern was that the statute, even as limited, failed to draw a sharp enough line between advocacy of a candidate’s election and discussion of issues, and that the resulting uncertainty over what the statute covered would “ ‘compel[ ] the speaker to hedge and trim,’ ” id. at 43, 96 S.Ct. 612 (quoting Thomas v. Collins, 323 U.S. 516, 535, 65 S.Ct. 315, 89 L.Ed. 430 (1945)): [T]he distinction between discussion of issues and candidates and advocacy of election or defeat of candidates may often dissolve in practical application. Candidates, especially incumbents, are intimately tied to public issues involving legislative proposals and governmental actions. Not only do candidates campaign on the basis of their positions on various public issues, but campaigns themselves generate issues of public interest. Id. at 42, 96 S.Ct. 612. To avoid this uncertainty, the Court limited the scope of the statute to “expenditures for communications that in express terms advocate the election or defeat of a clearly identified candidate for federal office.” Id. at 44, 96 S.Ct. 612. The constitutional basis for this concern with distinguishing between laws that regulate advocacy of a candidate’s election and those that regulate pure issue discussion has never been entirely clear. Buckley explicitly framed its discussion in terms of unconstitutional vagueness under the Due Process Clause, and there is, to be sure, a vagueness dimension to the analysis. See, e.g., FEC v. Wis. Right to Life, Inc., 551 U.S. 449, 497, 127 S.Ct. 2652, 168 L.Ed.2d 329 (2007) (Sealia, J., concurring in part) (referring to the express advocacy portion of Buckley as the decision’s “vagueness holding”). However, this interpretation has its limits; the mere fact that a statute may cover issue discussion as well as candidate advocacy does not alone render it vague under due process standards, provided that the statute is reasonably clear in its coverage. Perhaps for this reason, there are hints in Buckley that the constitutional basis for the Court’s concern lay more in over-breadth — i.e., that statutes that reached issue discussion might be deemed to regulate impermissibly a substantial amount of speech protected by the First Amendment — than in vagueness. See, e.g., 424 U.S. at 80, 96 S.Ct. 612 (limiting a second, disclosure-related provision of FECA to communications that “expressly advocate” a candidate’s election to “insure that the reach of [the provision] is not impermissibly broad”). This reading finds considerable support in subsequent authority. See Osborne v. Ohio, 495 U.S. 103, 120 n. 14, 110 S.Ct. 1691, 109 L.Ed.2d 98 (1990) (describing Buckley as a “case where a law was construed to avoid potential overbreadth problems”); FEC v. Mass. Citizens for Life, Inc., 479 U.S. 238, 248, 107 S.Ct. 616, 93 L.Ed.2d 539 (1986) (stating that Buckley's “express advocacy” limitation was imposed to “avoid problems of overbreadth”); cf. McConnell v. FEC, 540 U.S. 93, 192, 124 S.Ct. 619, 157 L.Ed.2d 491 (2003) (noting that Buckley “narrowly read[ ] the FECA provisions ... to avoid problems of vagueness and overbreadth”), overruled on other grounds by Citizens United, 130 S.Ct. 876. Regardless of its origins, the dividing line between issue discussion and express advocacy, as it evolved, came to be associated more strongly with First Amendment overbreadth analysis than with due process vagueness concerns. See, e.g., Wis. Right to Life, 551 U.S. at 457, 127 S.Ct. 2652 (noting that the “law in this area requires us ... to draw such a line, because we have recognized that the interests held to justify the regulation of campaign speech [under the First Amendment] ... ‘might not apply’ to the regulation of issue advocacy” (quoting McConnell, 540 U.S. at 206 n. 88, 124 S.Ct. 619)). 2. Application to Maine’s Election Statutes Drawing on these cases, NOM argues that the statutes before us are unconstitutionally overbroad because they reach issue advocacy as well as express advocacy of a candidate’s election or defeat. NOM’s argument presumes that the distinction between issue discussion and express advocacy is relevant to the review of the statutes here. That is not the case for a couple of reasons. First, the issue/express advocacy dichotomy has only arisen in a narrow set of circumstances not present here. From the beginning, the distinction’s primary purview has been cases scrutinizing limits on independent expenditures. The statute that prompted the Buckley Court to introduce the “express advocacy” construction was a blanket $1,000 limit on independent expenditures. 424 U.S. at 41-44, 96 S.Ct. 612. The more recent Supreme Court precedents to make use of the express/issue advocacy distinction addressed a narrower federal law prohibiting corporations and labor unions from employing general treasury funds to pay for “electioneering” communications targeting candidates for election. See McConnell, 540 U.S. at 189-209, 124 S.Ct. 619; Wis. Right to Life, 551 U.S. at 464-82, 127 S.Ct. 2652. This line of cases came to a definitive end with Citizens United, which held limitations on such expenditures by corporations and unions to be unconstitutional, and thus effectively prohibited any law limiting independent expenditures regardless of the identity of the regulated entity. 130 S.Ct. at 896-913. As the present case does not involve a limit on independent expenditures, the relevance of these cases is limited at best. Second, and more fundamentally, the Supreme Court has explicitly rejected an attempt to “import [the] distinction” between issue and express advocacy into the consideration of disclosure requirements. Id. at 915; see also id. (“[W]e reject Citizens United’s contention that the disclosure requirements must be limited to speech that is the functional equivalent of express advocacy.”). The provisions before us are all effectively disclosure laws, in that they require the divulgenee of information to the public or the Commission, but do not directly limit speech. We find it reasonably clear, in light of Citizens United, that the distinction between issue discussion and express advocacy has no place in First Amendment review of these sorts of disclosure-oriented laws. Accord Human Life of Wash. Inc. v. Brumsickle, 624 F.3d 990, 1016 (9th Cir.2010) (“Given the Court’s analysis in Citizens United, and its holding that the government may impose disclosure requirements on speech, the position that disclosure requirements cannot constitutionally reach issue advocacy is unsupportable.”). Thus, to the extent that NOM’s over-breadth arguments turn on the distinction between issue discussion and express advocacy, we reject them. B. Standard of Scrutiny Since Buckley, the Supreme Court has distinguished in its First Amendment jurisprudence between laws that restrict “the amount of money a person or group can spend on political communication” and laws that simply require disclosure of information by those engaging in political speech. 424 U.S. at 19, 64, 96 S.Ct. 612. The Court has recognized that disclosure laws, unlike contribution and expenditure limits, “impose no ceiling on campaign-related activities,” id. at 64, 96 S.Ct. 612, and thus are a “less restricfive alternative to more comprehensive regulations of speech.” Citizens United, 130 S.Ct. at 915; see also Buckley, 424 U.S. at 68, 96 S.Ct. 612 (“[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.”). For that reason, disclosure requirements have not been subjected to strict scrutiny, but rather to “ ‘exacting scrutiny,’ which requires a ‘substantial relation’ between the disclosure requirement and a ‘sufficiently important’ governmental interest.” Citizens United, 130 S.Ct. at 914 (quoting Buckley, 424 U.S. at 64, 66, 96 S.Ct. 612); see also Doe v. Reed, — U.S. -, 130 S.Ct. 2811, 2818, 177 L.Ed.2d 493 (2010). While NOM concedes that exacting scrutiny applies to review of Maine’s independent expenditure and disclaimer and attribution laws, it contends that Maine’s PAC definitions are subject to strict scrutiny. In fact, NOM suggests that any law defining an organization as a PAC is subject to strict scrutiny, because, “[a]s a matter of law, not fact,” PAC status is burdensome and subjects an entity to “extensive regulations.” NOM’s argument here reflects two contradictory points. On the one hand, NOM seeks to justify the application of strict scrutiny by reference to some undefined set of “full-fledged political committee burdens.” On the other, NOM disclaims any challenge to the disclosure requirements attendant to PAC status under Maine law — i.e., the actual burdens of registration and reporting imposed by the state’s PAC provisions— but purports to challenge only the “PAC definition, through which Maine unconstitutionally imposes full-fledged political committee burdens.” NOM’s point appears to be that “by giving government the power to license speech” by defining an entity as a PAC, whatever obligations are imposed on PACs “in effect are prior restraints.” 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. Those obligations-as well as the basic definition of a “PAC” — vary across the jurisdictions that regulate PACs. Maine’s requirements are substantially different from those at issue in the cases NOM cites in support of its contention that PAC status is inherently burdensome. For example, in Citizens United, where, as NOM points out, the Supreme Court characterized federal-law PACs as “expensive to administer and subject to extensive regulations,” 130 S.Ct. at 897, the Court was considering a regime that required corporations to set up a separate legal entity and create a segregated fund prior to engaging in any direct political speech. In addition, these federal-law PACs were subject to numerous obligations and restrictions, among them a prohibition on an organization soliciting contributions for its segregated fund from anyone except its “members,” which excluded “those persons who have merely contributed to or indicated support for the organization in the past.” Mass. Citizens for Life, 479 U.S. at 253-54, 107 S.Ct. 616 (citing 2 U.S.C. § 441b(b)(4)(A), (Q). In contrast, Maine’s non-major-purpose PAC provision does not condition political speech on the creation of a separate organization or fund, establishes no funding or independent expenditure restrictions, and imposes three simple obligations on an entity qualifying as a PAC: filing of a registration form disclosing basic information, quarterly reporting of election-related contributions and expenditures, and simple recordkeeping. Because Maine’s PAC laws do not prohibit, limit, or impose any onerous burdens on speech, but merely require the maintenance and disclosure of certain financial information, we reject NOM’s argument that strict scrutiny should apply. Accordingly, we review each of the laws at issue under the “exacting scrutiny” standard applicable to disclosure requirements. C. Application of Exacting Scrutiny to Maine’s Laws As we have stated, we will consider a law constitutional under exacting scrutiny standards where there is a “substantial relation” between the law and a “ ‘sufficiently important’ governmental interest.” Citizens United, 130 S.Ct. at 914 (quoting Buckley, 424 U.S. at 64, 66, 96 S.Ct. 612). In Buckley, the Court recognized the goal of “providing] the electorate with information as to where political campaign money comes from and how it is spent” to be such a “sufficiently important” governmental interest capable of supporting a disclosure law. 424 U.S. at 66, 96 S.Ct. 612 (internal quotation marks omitted). The Court’s more recent decisions have continued to recognize the importance of this informational interest. See, e.g., Citizens United, 130 S.Ct. at 914-15; McConnell, 540 U.S. at 196, 124 S.Ct. 619. Buckley tied the government’s interest in the dissemination of information to the functioning of the electoral process, noting that “[i]n a republic where the people are sovereign, the ability of the citizenry to make informed choices among candidates for office is essential.” 424 U.S. at 14-15, 96 S.Ct. 612. The Court observed that disclosure has several benefits in this regard: It allows voters to place each candidate in the political spectrum more precisely than is often possible solely on the basis of party labels and campaign speeches. The sources of a candidate’s financial support also alert the voter to the interests to which a candidate is most likely to be responsive and thus facilitate predictions of future performance in office. Id. at 67, 96 S.Ct. 612. However, the informational interest is not limited to informing the choice between candidates for political office. As Citizens United recognized, there is an equally compelling interest in identifying the speakers behind politically oriented messages. In an age characterized by the rapid multiplication of media outlets and the rise of internet reporting, the “marketplace of ideas” has become flooded with a profusion of information and political messages. Citizens rely ever more on a message’s source as a proxy for reliability and a barometer of political spin. Disclosing the identity and constituency of a speaker engaged in political speech thus “enables the electorate to make informed decisions and give proper weight to different speakers and messages.” Citizens United, 130 S.Ct. at 916; see also Cal. Pro-Life Council, Inc. v. Getman, 328 F.3d 1088, 1105 (9th Cir.2003) (recognizing that, in the “cacophony of political communications through which ... voters must pick out meaningful and accurate messages!,] • • • being able to evaluate who is doing the talking is of great importance”). Additionally, in the case of corporate or organizational speakers, disclosure allows shareholders and members to “hold [them] accountable for their positions.” Citizens United, 130 S.Ct. at 916. In short, “[t]he First Amendment protects political speech; and disclosure permits citizens and shareholders to react to [that] speech ... in a proper way.” Id. In line with these precedents, defendants offer Maine’s interest in disseminating information about political funding to the electorate in support of the laws challenged here. As the district court found, the interest is plainly a motivating factor behind Maine’s laws, and “Maine, through its Commission website and otherwise, makes [the financial disclosure] information easily available to the public.” Nat'l Org. for Marriage, 723 F.Supp.2d at 263. We thus proceed under the exacting scrutiny framework to examine whether there is a “substantial relation” between Maine’s informational interest and each of the laws at issue. 1. Non-Major-Purpose PAC Provisions As we have described, Maine considers an entity to be a non-major-purpose PAC when it receives contributions or makes expenditures of more than $5,000 annually “for the purpose of promoting, defeating or influencing in any way” a candidate’s election. Me.Rev.Stat. tit. 21-A, § 1052(5)(A)(5). Upon crossing that threshold, the newly-deemed non-major-purpose PAC must register with the Commission, maintain records of certain expenditures as well as donor contributions aggregating more than $50, and file reports both on a quarterly basis and shortly before and after each election. Id. §§ 1053, 1057, 1059-60. The reporting requirements are well tailored to Maine’s informational interest, requiring disclosure only of the candidates or campaigns the non-major-purpose PAC supports or opposes, its expenditures made to support or oppose the same, and identifying information for any contributors who have given more than $50 to the PAC to support or oppose a candidate or campaign. Id. § 1060. NOM does not challenge the substantive obligations attendant to non-major-purpose PAC status, nor contest that the registration, recordkeeping, and reporting requirements bear a substantial relation to Maine’s informational interest. Instead, NOM contends that Maine’s definition of a non-major-purpose PAC, standing alone, is unconstitutionally overbroad. In rejecting NOM’s argument for strict scrutiny, we have already addressed the claim that PAC status is somehow inherently burdensome apart from the specific requirements it entails. However, there is a second aspect to NOM’s argument. NOM contends that Supreme Court precedent sharply limits regulation of PACs to those that are under the control of a candidate or have as their “major purpose” the election of a candidate. By its very definition, Maine’s non-major-purpose PAC provision covers entities that fall outside of that allegedly limited zone of permissible regulation, and thus, NOM contends, the provision is fatally overbroad. We disagree. NOM extracts support for its argument from a dictum in Buckley, albeit a dictum that has had some reach. In Buckley, the Court concluded that the definition of expenditure used in connection with FECA’s disclosure provision — and particularly the phrase “for the purpose of influencing”' — • raised significant line-drawing problems because it had the “potential for encompassing both issue discussion and advocacy of a political result.” 424 U.S. at 79, 96 S.Ct. 612. In the course of its discussion, the Court noted that FECA’s definition of “political committees,” which, like the disclosure provision, was defined in terms of contributions and expenditures, “could raise similar vagueness problems.” Id. The provision escaped these concerns, the Court explained, because it could be construed more narrowly: To fulfill the purposes of [FECA, political committees] need only encompass organizations that are under the control of a candidate or the major purpose of which is the nomination or election of a candidate. Expenditures of candidates and of “political committees” so construed can be assumed to fall within the core area sought to be addressed by Congress. They are, by definition, campaign related. Id. Buckley’s narrow reading of FECA’s political committee definition, though dictum, appears to have been accepted by later opinions. See McConnell, 540 U.S. at 170 n. 64, 124 S.Ct. 619; Mass. Citizens for Life, 479 U.S. at 252 n. 6, 107 S.Ct. 616; cf. FEC v. Akins, 524 U.S. 11, 26-27, 118 S.Ct. 1777, 141 L.Ed.2d 10 (1998) (noting dispute over extent of narrowing construction). NOM draws from this the conclusion that the First Amendment permits an entity to be designated a “PAC” only where it (1) “is under the control of a candidate” or (2) has as its major purpose “the nomination or election of a candidate.” We find no reason to believe that this so-called “major purpose” test, like the other narrowing constructions adopted in Buckley, is anything more than an artifact of the Court’s construction of a federal statute. See McConnell, 540 U.S. at 191—92, 124 S.Ct. 619. The Court has never applied a “major purpose” test to a state’s regulation of PACs, nor have we. And, as we have discussed, the line-drawing concerns that led the Court to read FECA’s definition of “political committee” narrowly are not relevant to our First Amendment review of Maine’s statutes. Moreover, as the district court aptly observed, application of NOM’s “major-purpose” test would “yield perverse results” here: Under NOM’s interpretation, a small group with the major purpose of reelecting a Maine state representative that spends $1,500 for ads could be required to register as a PAC. But a mega-group that spends $1,500,000 to defeat the same candidate would not have to register because the defeat of that candidate could not be considered the corporation’s major purpose. Nat'l Org. for Marriage, 723 F.Supp.2d at 264. We, like the district court, see no basis to conclude “that the First Amendment’s protections should apply so unequally.” Id. We therefore reject NOM’s argument that the non-major-purpose PAC definition is unconstitutionally overbroad. Because we find a substantial relation between Maine’s disclosure-oriented regulation of non-major-purpose PACs and its interest in the dissemination of information regarding the financing of political speech, we conclude that the law does not, on its face, offend the First Amendment. 2. Independent Expenditure Provision We similarly find that Maine’s independent expenditure reporting provision poses no First Amendment concerns. The law primarily obligates anyone spending more than an aggregate of $100 for communications expressly advocating the election or defeat of a candidate to report the expenditure to the Commission. Me.Rev. Stat. tit. 21-A, § 1019-B(1)(A), (3). Reviewing a prior, substantially similar version of this provision in Daggett v. Commission on Governmental Ethics and Election Practices, 205 F.3d 445, 466 (1st Cir.2000), we held that “the modest amount of information requested is not unduly burdensome and ties directly and closely to the relevant government interests.” We see no reason to depart from that conclusion here. The independent expenditure law also presumptively requires a report of any expenditure over $100 for communications naming or depicting a clearly identified candidate within a set period prior to any election. Me.Rev.Stat. tit. 21-A, § 1019-B(1)(B), (3). Though we did not review this aspect of the law in Daggett, the Supreme Court upheld in Citizens United a similar provision of federal election law that required disclosure in connection with expenditures for electioneering communications (communications made shortly before an election that refer to a clearly identified candidate for federal office). 130 S.Ct. at 913-16. In so doing, the Court noted that “the public has an interest in knowing who is speaking about a candidate shortly before an election.” 130 S.Ct. at 915-16. The law here is perhaps more tailored than that at issue in Citizens United, as it offers an opportunity to rebut the presumption that a communication made shortly before an election and identifying a candidate had the “intent to influence the nomination, election or defeat of a candidate.” Me.Rev.Stat. tit. 21-A, § 1019-B(2). Regardless, the information that must be reported under this subsection is, as Daggett found, “modest,” 205 F.3d at 466, and it bears a substantial relation to the public’s “interest in knowing who is speaking about a candidate shortly before an election.” Citizens United, 130 S.Ct. at 915-16. NOM argues that Maine lacks a “sufficiently important” interest in the $100 threshold at which the reporting requirement adheres, and, alternatively, that the threshold lacks a “substantial relation” to a sufficiently important governmental interest. NOM’s argument operates from a mistaken premise; we do not review reporting thresholds under the “exacting scrutiny” framework. In Buckley, facing a similar challenge to a $10 threshold for a recordkeeping provision and a $100 reporting threshold, the Supreme Court noted that the choice of where to set such monetary thresholds “is necessarily a judgmental decision, best left in the context of this complex legislation to congressional discretion.” 424 U.S. at 83, 96 S.Ct. 612. The Court concluded that, although there was no evidence in the record that Congress had “focused carefully on the appropriate level at which to require recording and disclosure,” and despite the fact that the low thresholds might “discourage participation by some citizens in the political process,” it could not say that “the limits designated are wholly without rationality.” Id.; see also id. n. Ill (“[Wjhen it is seen that a line or point there must be, and that there is no mathematical or logical way of fixing it precisely, the decision of the legislature must be accepted unless we can say that it is very wide of any reasonable mark.” (quoting Louisville Gas & Electric Co. v. Coleman, 277 U.S. 32, 41, 48 S.Ct. 423, 72 L.Ed. 770 (1928) (Holmes, J., dissenting))). The Court thus upheld FECA’s recordkeeping and reporting thresholds. Following Buckley, we have granted “judicial deference to plausible legislative judgments” as to the appropriate location of a reporting threshold, and have upheld such legislative determinations unless they are “ ‘wholly without rationality.’ ” Vote Choice, Inc. v. DiStefano, 4 F.3d 26, 32-33 (1st Cir.1993)