This is the second part of this story which originally ran on February 10, 2018.

The Clark Fork Group, LLC was incorporated in Ohio in June, 2015, at a private residence in Dublin, so Ayers must have consulted after that date and before becoming Pence’s COS in July 2017. Curiously, on the disclosure form Ayers lists Clark Fork Group’s address as being in Thompson Falls, MT. Clark Fork is a river in Montana, but Plunderbund could find no record of a similarly named LLC ever being incorporated there. In its most recent Kentucky filings, American Policy Coalition also lists its address as being in Thompson Falls, MT (which is on the Clark Fork river). Tom Norris, Columbus-based lobbyist and Ohio Dark Money king pin appears to be connected to APC and the Clark Fork Group. A Grove City address linked to yet another dark money organization is listed as being owned by Tom Norris, but the tax bill is being sent to Thompson Falls, MT.

Tom Norris hired Joel Riter away from Josh Mandel’s office in 2010 and they have been working together ever since. Riter appears to be an influential person at Clark Fork Group, if he is not, in fact a partner. A “who is” lookup reveals that the domain was registered in Riter’s name on May 21, 2016, with his personal gmail address as the contact email.

Plunderbund obtained this business card from Ron Osburn, the Associate Editor of hometown newspaper, The Bryan Times. He shadowed State Representative Rob McColley (at the time, he’s a State Senator now) for an article, and over the course of the day, he was allowed to observe meetings between different lobbyists and McColley. One of the lobbyists that day was Riter.

Riter may lobby Ohio State Representatives but his longtime business partner, Tom Norris, aims higher: he served on the Trump transition team at the Department of Energy. Fellow Dark Money player, Nick Ayers, volunteered for the Trump Campaign. If anyone associated with the Trump campaign directed the design or purchase of these billboards, that would meet the FEC’s definition of “coordination” and it would be illegal.

The FEC has successfully pursued fines for illegal instances of coordination; Plunderbund has recently written about another case involving Ohio Dark Money. In that case, the pass through entity, American Conservative Union, took a cut of the funds they transferred – 5% of the total.  On November 30, AUV paid Langdon Law $4,020, which, in a strange coincidence, drew the Super PAC’s balance to exactly zero. This payment would come to about 4.5% of the total $90k donation, if it were in a fact a “cut” or “service fee”.

The National Context

Throughout the 2016 election, the Trump campaign was dogged by allegations of questionable accounting practices, even – as unbelievable as this sounds – unusual transactions surrounding direct mail campaigns in Indiana. The Washington Post reports that Left Hand Enterprises LLC was a “pop up” corporation that received $730,637 over five days, becoming the 10th biggest vendor to the Trump campaign for the entire election cycle. Corey Lewandowski claimed that company was created to handle direct mail campaigns ahead of the Indiana and Nebraska Republican primaries.

However, the Post could find no record of mailings by that firm and the timing of the payment cast doubt on the timeframe presented by the Trump Campaign. The Left Hand Enterprises payments were handled by Paul Manafort, who was indicted by Special Counsel Robert Mueller on charges of money laundering, among other crimes.

There are reasonably tight regulations around how money is transferred into campaigns and committees, but as the Left Hand Enterprises example illustrates, regulations around how campaigns select and pay their vendors are lax. Ayers joined the Trump campaign in July 2016 when Mike Pence came on board, which was long after the Left Hand Enterprises disbursements. However, a Politico report has raised questions about Ayers’s unusual funding set up during 2016, in which he volunteered for the Trump campaign, while doing paid work for other candidates. The article points out that “any payments from different campaigns for Ayers’ work on the Trump-Pence campaign would qualify as an illegal in-kind contribution, but there is no indication that this took place.”

Another eyebrow-raising piece of the puzzle is the fact that Corry Bliss, Rob Portman’s 2016 campaign manager, became the executive director of the Congressional Leadership Fund in December 2016, just two months after the lion’s share of CLF’s $85,000 donation was likely routed to the Portman aligned Super PAC Fighting for Ohio. The same day (October 13) Americans United for Values transferred $80,000 to Fighting for Ohio PAC, it made a $190,000 anti-Strickland ad buy.

Around the same time that Bliss took the helm of the CLF, he also became the Executive Director of American Action Network, which has cultivated more of a reputation for being a dark money power player.  This comes as no surprise because millions of dollars in dark money were spent in the Ohio Senate race to benefit Rob Portman. Fighting for Ohio PAC accepted $2.275 million dollars in Dark Money, or 23.4% of total contributions. James Nathanson’s Freedom Vote, Inc. lead the pack, giving $525,000. Historically, Freedom Vote has accepted large donations from American Action Network.

ODMP Donations to Fighting for Ohio PAC 2015-2016
Entity Donation Date Donation Amount
FREEDOMVOTE, INC 12/29/2015 $200,000
FREEDOMVOTE, INC 3/31/2016 $300,000
FREEDOMVOTE, INC 7/5/2016 $500,000
FREEDOMVOTE, INC 8/25/2016 $250,000
FREEDOMVOTE, INC 9/14/2016 $200,000
FREEDOMVOTE, INC 9/21/2016 $250,000
FREEDOMVOTE, INC 10/5/2016 $275,000
ODMP Total   $2,275,000
Total Donations   $9,569,000
ODMP to Total Donations   23.8%

In addition to the Ohio 2016 Senate election, dark money insinuated itself into the 2016 Missouri Gubernatorial election, throwing its support behind Republican Eric Greitens. Greitens is currently under fire for allegedly blackmailing his mistress with nude photos and physically assaulting her in his home, but he is no stranger to controversy. A Super PAC called SEALS for Truth stunned Missourians by breaking the record for the largest, single campaign contribution in a State Election. On July 18, 2016, American Policy Coalition (which is now located in Thompson Falls, MT) donated $2 million dollars to SEALS for Truth; that same day SEALS for Truth donated $1.975 to the Greitens campaign.

Another Super PAC, called LG PAC, financed attack ads against Greitens’s opponents in the primary and was partially funded by, you guessed it, Ohio Dark Money. This time the funder was a 501 (c) 4 called Freedom Frontier, which has been linked to Nathanson (of Freedom Vote), Langdon and Riter. Nick Ayers also consulted for Greitens’s campaign and received more than $30,000 in payments in 2016. It is possible that Americans United for Values filed the amended Pre-General report, in which they reattributed the $90,000 donation from American Policy Coalition to A Public Voice, Inc. because APC was embroiled in controversy and drawing scrutiny.

Dark Money Players at the Ohio Statehouse

Though the big bucks in dark money are spent on big ticket elections, like Presidential and Gubernatorial races, it leaves its traces everywhere, even the Ohio Statehouse. There could be a dark money power player sitting in your State Representative’s office right now, trying to sell him on road cement, for example, or trying to convince him to outsource the lion’s share of ODOT’s PR work to their firm.

A Public Voice, Inc. was initially incorporated at 88 East Broad Street, Suite 1770 Columbus, OH. That address matches the current address of Strategic Public Partners (SPP) and FEC filings show that SPP occupied that same address both before and after APV was incorporated in May 2012.

Strategic Public Partners is a Public Affairs shop that has championed many conservative causes over the years. In 2012, they spearheaded the defeat of State Issue 2 in 2012, the ballot initiative which would have a “created a 12-person citizen commission to draw legislative and congressional district maps.” Around that time, they incorporated a nonprofit called “Protect Your Vote Ohio” to fund that effort. Then, in April 2013, they changed the name to “A Public Voice, Inc.” Its current registered agent is listed as Langdon Law.

In 2013, they were nearly awarded a $1.88 million dollar contract to handle all the PR for ODOT’s highway construction projects, but a Democrat Senator questioned the lucrative deal before the contract could be approved. Kasich promptly withdrew the request, prompting some Democrats to wonder if he had done so to dampen further public scrutiny.

The ODOT connection is interesting because Joel Riter, the former Josh Mandel aide, dark money player and apparent member of the mysterious Clark Fork Group, is a registered lobbyist for the concrete and cement industry. He is also listed as the treasurer of the  Concrete and Portland Cement Action Network, a Super PAC that receives astonishingly little money from the concrete industry and has been connected to Tom Norris as well.

When Ron Osburn shadowed then-State Representative Rob McColley, Riter told him that he was advocating for the concrete road construction industry. McColley, at the time, chaired the House Transportation Subcommittee. SPP runs a PAC called Strategic Public Partners PAC and McColley’s campaign ranked 5th in highest amount of donations received from it, even beating out the Secretary of State, Jon Husted. On the McColley side, Strategic Public Partners ranked 22nd out of 134 non-individual donors for most donated from August 2013 to July 2017 (there is a reporting lag). Over that period, Strategic Public Partners PAC gave Rob McColley $2,850, almost triple the median non-individual donation of $975.

Rank Committee  Total
2 KASICH FOR OHIO  $  12,156
6 HUSTED FOR OHIO  $    2,000
10 CITIZENS FOR MINGO  $    1,000
* Two combined committees and totals    **Excluded from Analysis


And finally because all politics is local – even national campaigns in the midst of unprecedented foreign influence – there is even an Ohio connection to a Trump aligned Super PAC. Throughout the 2016 election, dark money watchdogs were carefully scrutinizing a Super PAC called Great America PAC, whose founders had a history of shady campaign finance dealings. During the Iowa caucus, the Great America PAC placed pro-Trump ads using a company called GRP Buying LLC.

GRP Buying has been described as “mysterious” by Mother Jones. It’s incorporated in the state of Delaware,  but lists its mailing address as 3136 Kingsdale Center #136, Upper Arlington – that’s a post office box at an e-shipping store. In 2017, Americans United for Values bought ads in the primaries of the Georgia 6th Special Election and the South Carolina 5th Special Elections. They used GRP Buying to place the TV ads in South Carolina. They also ran a direct mail campaign in that primary, selecting the Jacksonville, FL firm Majority Strategies for the job.

After Nick Everhart fell out with the powerhouse far right, Evangelical-aligned Strategy Group for Media, he was something of a pariah in GOP circles. He accept a less glamorous position than a Republican rising star should have been able to land – he went to work for Majority Strategies.

After a few years in exile, he returned to Upper Arlington to start his new firm, which is currently located in downtown Columbus. But it wasn’t always. It used to be located at 3380 Tremont Rd, in Upper Arlington. Google estimates that Everhart’s old office was a twelve minute walk / four minute drive to the post office box where GRP buying receives its mail. GRP most likely stands for “Gross Rating Point” which is a standard measure of an advertisement’s impact – its a fairly common phrase. Coincidentally, Clark Fork Group filled for, but ultimately abandoned a trademark application for the words “MOBILE GROSS RATING POINT/MOBILE GRP”.

The organizer of the Great America PAC, which bought those Pro-Trump ads in Iowa from GRP buying, is a lawyer named Dan Backer. Russian-born Backer was the lawyer who won the Supreme Court case, McCutcheon vs. Federal Election Commission which eliminated the cap on how much wealthy individuals can donate to federal candidates, parties and PACs in a single, two-year election cycle. In the Dallas News, an Op-Ed credits Backer’s legal crusading as paving the way for “U.S. citizens with close ties to Russia” to donate millions to Federal GOP candidates. Great America PAC has run ads attempting to discredit the Mueller investigation.

It’s all a strange, confusing mass of threads that knot and unweave and reunite again. Eventually you cast a net so wide, you’re bound to ensnare pure coincidences. That’s the point: as with laundering money, you mix the clean money with dirty money, until neither one can be distinguished. It’s the same objective when “fake news” mixes lies with truth. The alliances and networks of the Ohio Dark Money Plexus occupy a kind of permanent Schrodinger’s cat status and its dead useful for obscuring their true intentions.

So let’s focus on what matters and can be proven: in fall of 2016, somebody paid for 25 billboards to go up around Cincinnati, that had a clear political message and intent – to discourage Clinton voters. The Super PAC that took credit for the ad buy did not have enough money to pay for them, which means they did not fully disclose their donors. That is a violation of campaign finance law. The people associated with the Super PAC that took credit for the billboards have clear ties to the Trump campaign and transition. Any proven coordination between the billboard purchasers and the Trump Campaign would be a violation of campaign finance law.

The Citizens United ruling, for all its faults, acknowledges that voters have the right to know who paid for political advertisements, because it should inform our decision making process when we go to the polls. The public, especially the voters in Ohio who were targeted, deserves to know who paid for the billboards and whether any laws were broken.