Principles First FEC Complaint

4.
Campaign Legal Center (“CLC”) is a nonpartisan, nonprofit 501(c)(3) organization whose
mission is to protect and strengthen the U.S. democratic process through litigation and other
legal advocacy. CLC participates in judicial and administrative matters throughout the nation
regarding campaign finance, voting rights, redistricting, and government ethics issues.
FACTS
5. Principles First, Inc. (“Principles First”) also known as Principles First PAC, is an
independent expenditure-only political action committee (i.e., a “super PAC”) that was active
in Montana’s U.S. Senate primary election, which was held on June 5, 2018. 1
6. Matt Rosendale is a Republican candidate seeking election to the U.S. Senate from
Montana. 2
7. On May 22, 2018, Principles First began running $26,625 in broadcast ads on three Montana
stations—KPAX-TV/KAJ-TV, KECI, and KTMF—according to Federal Communications
Commission (“FCC”) records. 3 The political ad file accompanying one of the contracts
described the ad as relating to the “U.S. House race for Montana primary.” 4
8. A copy of the ad posted to the Advertising Analytics platform AdMo shows that the ad
expressly advocated against Rosendale’s election by urging viewers: “On June 5th Vote NO!
on Maryland Matt Rosendale.” 5 The ad concluded with the message: “Principles First is
1
See 2018 Congressional Pre-Election Reporting Dates, FEC.gov
https://transition.fec.gov/info/charts_primary_dates_2018.shtml#anchor5.
2
Matt Rosendale for Montana, Statement of Candidacy, FEC Form 2, at 1 (amended May 11, 2018),
http://docquery.fec.gov/pdf/618/201805110200366618/201805110200366618.pdf.
3
See Exhibits B-E. The contracts with KPAJ and KECI were executed on May 18, 2018. See Exhibit C at 1;
Exhibit D at 3-4.
4
Exhibit B at 2.
5
Principles First PAC, Maryland Matt, ADMO,
https://host2.advertisinganalyticsllc.com/admo/#/viewer/7b838c16-e08f-4676-9160-
75e0c9bb55ea/cGVkcm8uc3VhcmV6QGdtbWIuY29t (last visited June 20, 2018); see also @Robillard, Twitter
(Mar. 23, 2018), https://twitter.com/robillard/status/999336801318920192?lang=en (Politico reporter Kevin
Robillard tweeting on May 23 that “A new group, Principles First PAC, is on the air in #MTSen, attacking GOP
frontrunner @MattforMontana as “Maryland Matt,” with a link to the ad).
2
responsible for the content of this advertising. Paid for by Principles First and not authorized
by any candidate or candidate’s committee.” 6
9. On May 23, 2018, Principles First filed a statement of organization with the Commission. 7
The statement of organization designated Randall Lee Pullen as the committee’s treasurer,
listed a Scottsdale, Arizona address for the committee, and informed the Commission that it
intended to raise unlimited funds and make independent expenditures. 8
10. Also on May 23, 2018, an Arizona-based attorney for Principles First sent a letter to the
station manager of KTMF ABC/FOX News in Missoula, Montana, responding to a cease-
and-desist letter from Matt Rosendale for Montana. 9 The Principles First letter argued that its
ad describing Rosendale as “Maryland Matt” did not contain a factually inaccurate voiceover
message; rather, the letter insisted “[i]t is clear that the advertisement in question is not
misleading, it is not false, and it does not materially misrepresent any facts surrounding this
issue.” 10
11. On May 25, 2018, MTN News reported that Principles First, a “little-known group,” had
purchased $50,000 in airtime for a TV ad attacking U.S. Senate candidate Matt Rosendale. 11
As MTN News described:
The ad refers to Rosendale as “Maryland Matt” – a pejorative often used by Democrats to

label him as a recent arrival to the state – and says he signed legal documents “affirming
he’s a Maryland citizen.” Rosendale moved from Maryland to Montana in 2002.
6
Id.
7
Principles First, Inc., Statement of Organization, FEC Form 1, at 1 (filed May 23, 2018),
8
Id. at 1, 5.
9
Exhibit A at 1-2.
10
Id.
11
Mike Dennison, GOP Senate primary: obscure group dings Rosendale; Club for Growth ups the ante
against Fagg, MTN NEWS (May 25, 2018), http://www.krtv.com/story/38279181/in-gop-senate-primary-obscure-
group-dings-rosendale-club-for-growth-ups-ante-against-fagg.
3
Rosendale’s campaign denounced the ad as “blatantly false,” saying that a Maryland title
company has said, in writing, that the 2015 land-sale document indicating Rosendale is a
resident of Maryland is a mistake that it made.
Principles First PAC is not registered with the Federal Election Commission and a media
buyer for the group did not return a telephone message from MTN. 12
12. On May 30, 2018, Principles First spent an additional $22,725 on broadcast ads on the same
three Montana stations, KPAX-TV/KAJ-TV, KECI, and KTMF, according to FCC records. 13
13. The officer listed on Principles First’s FCC documents appears to be the treasurer listed on
Principles First’s reports filed with the Commission. 14
14. On June 19, 2018, Principles First filed two separate amendments to its Statement of
Organization. The first amendment reflected zero changes from the original. 15 The second
amendment changed the committee’s email and mailing addresses, and removed the text
appearing on the last page of the two previous versions saying that the committee intended to
raise unlimited funds for independent expenditures. 16
15. On July 7, 2018, Principles First filed a July Quarterly report disclosing $90,000 in receipts
from two contributors: $40,000 from Alliance for a Better Tomorrow, Inc. on May 15, 2018,
and $50,000 from Almon Blain on May 16, 2018. 17 Schedule E of the report disclosed
12
Id.
13
See Exhibits F-H.
14
The “Agreement Form[s] for Non-Candidate/Issue Advertisements” included in this set of filings indicate
that this is the same group that registered with the FEC on May 23, 2018, given that Randall, or “Randy,” Pullen is
listed in filings with both Commissions. Compare Principles First, Inc., Statement of Organization, supra n. 7, with
Exhibit B at 2.
15
Compare Principles First, Inc., Statement of Organization, Amendment 1, FEC-1239149, FEC Form 1
(amended June 19, 2018), http://docquery.fec.gov/pdf/345/201806199113758345/201806199113758345.pdf, with
Principles First, Inc., Statement of Organization, Original, FEC Form 1 (filed May 23, 2018), supra n. 7.
16
Compare Principles First, Inc., Statement of Organization, Amendment 2, Current Version FEC-1239170,
FEC Form 1, (amended June 19, 2018),
http://docquery.fec.gov/pdf/587/201806199113758587/201806199113758587.pdf, with Principles First, Inc.,
Statement of Organization, Amendment 1, FEC Form 1, (filed June 19, 2018), supra n. 15.
17
Principles First, Inc., July Quarterly Report, FEC Form 3X, at 7 (filed July 7, 2018),
http://docquery.fec.gov/pdf/451/201807079115247451/201807079115247451.pdf. The July Quarterly includes a
note stating “This fil (sic) was created with the help of Kaitlan at the FEC for the quarterly report. Did not need to
file monthly report (DCf2). Once the 7/15/18 report is filed, will file the 24 hour late reports.” Id. at 6.
4
$65,150 in independent expenditures supporting U.S. Senate candidate Russell Fagg:
$60,000 in TV ads and $5,150 in digital ads disseminated on May 18, 2018. 18 Also on July 7,
2018, Principles First filed a 24-hour independent expenditure report disclosing those same
independent expenditures. 19
SUMMARY OF THE LAW
16. A political committee must comply with the organizational and recordkeeping requirements
of 52 U.S.C. § 30102, and must file periodic disclosure reports, either on a monthly or
quarterly basis, of its receipts and disbursements, 52 U.S.C. § 30104(a)(4)(A)-(B).
17. Independent expenditures are expenditures that expressly advocate the election or defeat of a
clearly identified federal candidate and are not coordinated with such candidate or political
party. 52 U.S.C. § 30101(17); 11 C.F.R. § 100.16(a).
18. Every person that makes independent expenditures aggregating $1,000 or more less than 20
days, but more than 24 hours, before the date of an election must report the expenditures
within 24 hours. 52 U.S.C. § 30104(g)(1)(A); 11 C.F.R. §§ 104.4(c), 104.5(g)(2), 109.10(d).
The person must file an additional 24-hour report each time the person makes subsequent
independent expenditures in that election aggregating $1,000 or more. Id.
19. Such reports must disclose information regarding the committee’s independent expenditures,
including the date, amount, and purpose of the independent expenditure and a statement
indicates whether it is in support of, or in opposition to, a candidate, as well as the name and
office sought by that candidate, and the identity of any person to whom over $200 was
18
Id. at 9.
19
Principles First, Inc., 24/48 Hour Report of Independent Expenditures, Schedule E (filed July 7, 2018),
5
disbursed in connection with the independent expenditure. 52 U.S.C. § 30104(b)(6)(B)(iii);
11 C.F.R. §§ 104.4(c), 104.3(b)(3)(vii), 109.10(d)-(e).
20. A political committee that makes independent expenditures must itemize them on its periodic
reports. 52 U.S.C. §§ 30104(b)(4)(H)(iii), (6)(B)(iii); 11 C.F.R. § 104.4(a).
21. The Supreme Court has repeatedly recognized the importance of campaign finance disclosure
to informing the electorate. See, e.g., Citizens United v. FEC, 558 U.S. 310, 369 (2010)
(discussing the public interest in “knowing who is speaking about a candidate shortly before
an election.”).
CAUSES OF ACTION
I. PRINCIPLES FIRST, INC. FAILED TO REPORT INDEPENDENT EXPENDITURES
22. Published reports and FCC records indicate that Principles First spent at least $49,350 to air
at least 127 broadcast advertisements in Montana that expressly advocated against the
election of Montana Congressional candidate Matt Rosendale (“Vote NO! on Maryland Matt
Rosendale”) and did so within 20 days before the June 5th election. 20 These advertisements
constituted independent expenditures as that phrase is defined in FECA. 52 U.S.C. §
30101(17); 11 C.F.R. § 100.16(a).
23. According to FCC records, Principles First spent:
a. $16,100 on 30 ad spots that ran May 22, 2018 through May 29, 2018 on the KPAX-
TV/KAJ-TV station in Missoula, Montana; 21
20
See Political Files, Principles First, Federal Communications Commission,
https://publicfiles.fcc.gov/find/%22principles%20first%22/page-offset-0/order-oldest/filter-[]/#files (last visited
June 21, 2018); see also Principles First PAC, Maryland Matt, supra note 5.
21
Exhibit C at 3.
6
b. $9,650 on 25 ad spots that ran May 22, 2018 through May 29, 2018 on the KECI
station in Missoula, Montana; 22
c. $875 on 12 ad spots that ran May 22, 2018 through May 29, 2018 on the KTMF
station in Missoula, Montana; 23
d. $13,400 on 26 ad spots that ran May 30, 2018 through June 5, 2018 on the KPAX-
TV/KAJ-TV station in Missoula, Montana; 24
e. $8,700 on 24 ad spots that ran May 30, 2018 through June 5, 2018 on the KTMF
station in Missoula, Montana; 25 and
f. $625 on 10 spots that ran May 30, 2018 through June 5, 2018 on the KTMF station in
Missoula, Montana. 26
24. A political committee that makes independent expenditures aggregating $1,000 or more less
than 20 days before the date of an election must report the expenditures within 24 hours, and
file additional 24-hour reports each time subsequent independent expenditures aggregate an
22
Exhibit D at 1-4. On the attached “Agreement Form for Non-Candidate/Issue Advertisements,” the “No”
box is selected in response to the question, “Does the programming (in whole or in part) communicate ‘a message
relating to any political matter of national importance?’” Id. at 6. However, the preceding contract displays the
“Political Issue” designation in the “Product” field, id. at 1, 2, and complainants are not aware of any evidence to
suggest Principles First was running ads during that period that were not tied to the Montana U.S. Senate race.
23
Exhibit E at 1-3. A previous version of this filing, dated three days earlier, included an attached agreement
form answering “No” to the question, “Does the programming (in whole or in part) communicate ‘a message
relating to any political matter of national importance?” However, the most recent version available in the FCC files
omitted that attachment. The exhibits cited in this complaint reflect the most recent versions of the records on file
with the FCC.
24
Exhibit F at 3.
25
Exhibit G at 1-4. On the attached “Agreement Form for Non-Candidate/Issue Advertisements,” the “No”
relating to any political matter of national importance?’” Id. at 6. However, the preceding contract displays the
“Political Issue” designation in the “Product” field, id. at 1, 2, and there is no reporting nor other evidence to suggest
Principles First was running ads during that period that were not tied to the Montana U.S. Senate race.
26
Exhibit H at 1-4. On the attached “Agreement Form for Non-Candidate/Issue Advertisements,” the “No”
relating to any political matter of national importance?’” Id. at 6. However, the preceding order displays the
“Political/Vote” designation in the “Con Type” field, id. at 3, and there is no reporting nor other evidence to suggest
Principles First was running ads during that period that were not tied to the Montana U.S. Senate race.
7
EXHIBIT A
EXHIBIT B
NAB Form PB-18 Issues
AGREEMENT FORM FOR

NON-CANDIDATE/ISSUE ADVERTISEMENTS
Station and Location: Date:
5/18/19
KPAX
I, TJ Osborne
do hereby request station time concerning the following issue:
Principles First PAC
Time of
Broadcast Day, Times per Number of
Days Class
Length Rotation or Week Weeks
Package

This broadcast time will be used by: _________________________________________
Copyright © 2013 by the National Association of Broadcasters. May not be copied, reproduced or further distributed
1
THIS PAGE MUST BE COMPLETED FOR PROGRAMMING THAT

“COMMUNICATES A POLITICAL MATTER OF NATIONAL IMPORTANCE.”
FOR ALL OTHER ISSUE ADS, PLEASE GO TO PAGE 3.
Programming that “communicates a political matter of national importance”

includes (1) references to legally qualified candidates (presidential, vice
presidential or congressional); (2) any election to Federal office (e.g., any
references to “our next senator”, “our person in Washington” or “the President”);
and (3) a national legislative issue of public importance (e.g., Affordable Care Act,
revising the IRS tax code, federal gun control or any federal legislation).
Does the programming (in whole or in part) communicate “a message

relating to any political matter of national importance?”
■ Yes
  No
For programming that “communicates a message relating to any political matter of

national importance,” list the name of the legally qualified candidate(s) the programming
refers to, the offices being sought, the date(s) of the election(s) and/or the issue to
which the communication refers (if applicable):
US House race for Montana primary
I represent that the payment for the above described broadcast time has been furnished
by (name and address):
and you are authorized to announce the time as paid for by such person or entity
(hereinafter referred to as the “sponsor”).
List the chief executive officers or members of the executive committee or the board of
directors below (or attach separately):
Randy Pullen
For programming that “communicates a message relating to any political matter of

national importance,” attach Agreed Upon Schedule (Page 5)
2

DOES NOT “COMMUNICATE A POLITICAL MATTER OF NATIONAL
IMPORTANCE”
(hereinafter referred to as the “sponsor”).
3
TO BE COMPLETED FOR ALL ISSUE ADVERTISEMENTS
THIS STATION DOES NOT DISCRIMINATE OR PERMIT DISCRIMINATION ON THE

BASIS OF RACE OR ETHNICITY IN THE PLACEMENT OF ADVERTISING.
The Sponsor agrees to indemnify and hold harmless the station for any damages or
liability, including reasonable attorney’s fees, that may ensue from the broadcast of the
above-requested advertisement(s). For the above-stated broadcast(s), the sponsor
also agrees to prepare a script, transcript, or tape, which will be delivered to the
station at least _________ before the time of the scheduled broadcasts.
TO BE SIGNED BY ISSUE ADVERTISER (SPONSOR)

5/18/2018 2023375700
Date Signature Contact Phone Number
TO BE SIGNED BY STATION REPRESENTATIVE

 Accepted  Accepted in Part  Rejected
Signature Printed Name Title
4
AGREED UPON SCHEDULE

For All Issue Advertisements That Communicate a Message Relating to Any
Political Matter of National Importance
Time of
Days Class
Package
Attach proposed schedule with charges (if available):
AFTER AIRING OF BROADCASTS:

Attach invoices or Schedule Run Summary to this Form showing:
(1) actual air time and charges for each spot;

(2) the date(s), exact time(s) and reason(s) for Make-Good(s), if any; and
(3) the amount of rebates given (identify exact date, time, class of broadcast and
dollar amount for each rebate), if any.
Note: Because the FCC requires that the political file contain the actual time the rate for
spots “communicating a political matter of national importance” air, that information
should be included in the file as soon as possible. If that information is only generated
monthly, the file should include the name of a contact person who can provide the times
that and rates for specific spots aired. The FCC’s online political files include a folder for
“Terms and Disclosures.” NAB suggests that, for stations subject to the online public file
rule, the names of contact person(s) be placed in that folder.
5
EXHIBIT C
Contract Agreement Between: Print Date 05/18/18 Page 1 of 3
CONTRACT
KPAX-TV/KAJ-TV Contract / Revision Alt Order #
PO Box 4827 127039 / 09086819
Missoula, MT 59806 Product
(406) 542-4400 PRINCIPLES FIRST PAC
Contract Dates Estimate #
05/22/18 - 05/29/18 4080
Advertiser Original Date / Revision
Principles First PAC 05/18/18 / 05/18/18
And: Billing Cycle Billing Calendar Cash/Trade
EOM/EOC Broadcast Cash
Nebo Media Inc
1911 N Ft Myer Dr Property Account Executive Sales Office
Ste 400 KPAX Alex Hong (HRP) National Washington
Arlington, VA 22209 Special Handling
Demographic
Adults 35+
Agy Code Advertiser Code Product 1/2

358 446
Agency Ref Advertiser Ref
Start/End Spots/
* Line Ch Start Date End Date Description Time Days Length Week Rate Rtn Type Spots Amount
N 1 All 05/28/18 05/28/18 Montana This Morning 5:30 AM-7:00 AM :30 NM 1 $400.00
Start Date End Date Weekdays Spots/Week Rate
Week: 05/28/18 06/03/18 1------ 1 $400.00
N 2 All 05/24/18 05/24/18 Noon News 12:00 PM-12:30 PM :30 NM 1 $300.00
Week: 05/21/18 05/27/18 ---1--- 1 $300.00
Week: 05/21/18 05/27/18 ----1-- 1 $300.00
Week: 05/28/18 06/03/18 -1----- 1 $300.00
N 5 All 05/28/18 05/28/18 M-F 4:00 PM-5:00 PM :30 NM 1 $200.00
Week: 05/28/18 06/03/18 1------ 1 $200.00
N 6 All 05/22/18 05/22/18 M-F 4:00 PM-5:00 PM :30 NM 1 $200.00
Week: 05/21/18 05/27/18 -1----- 1 $200.00
N 7 All 05/23/18 05/23/18 M-F 4:00 PM-5:00 PM :30 NM 1 $200.00
Week: 05/21/18 05/27/18 --1---- 1 $200.00
N 8 All 05/24/18 05/24/18 M-F 4:00 PM-5:00 PM :30 NM 1 $200.00
Week: 05/21/18 05/27/18 ---1--- 1 $200.00
N 9 All 05/25/18 05/25/18 M-F 4:00 PM-5:00 PM :30 NM 1 $200.00
Week: 05/21/18 05/27/18 ----1-- 1 $200.00
N 10 All 05/29/18 05/29/18 M-F 4:00 PM-5:00 PM :30 NM 1 $200.00
Week: 05/28/18 06/03/18 -1----- 1 $200.00
N 11 All 05/23/18 05/23/18 M-F 530p News 5:30 PM-6:00 PM :30 NM 1 $1,500.00
Week: 05/21/18 05/27/18 --1---- 1 $1,500.00
(* Line Transactions: N = New, E = Edited, D = Deleted)

Notwithstanding to whom bills are rendered, advertiser, agency and service, jointly and severally, shall remain obligated to pay to station the amount of any bills rendered by station within the time specified and until
payment in full is received by station. Payment by advertiser to agency or to service or payment by agency to service, shall not constitute payment to station. Station will not be bound by conditions. printed or
otherwise contracts, insertion orders, copy instructions or any correspondence when such conflict with the above terms and conditions. Two week advance cancellation notice is required unless otherwise specified.
powered by WideOrbit
Contract / Revision Alt Order #

KPAX-TV/KAJ-TV
127039 / 09086819
PO Box 4827
Missoula, MT 59806 Contract Dates Product Estimate #
(406) 542-4400 05/22/18 - 05/29/18 PRINCIPLES FIRST PAC4080

Start/End Spots/
Week: 05/21/18 05/27/18 -1----- 1 $400.00
Week: 05/21/18 05/27/18 ----1-- 1 $1,500.00
N 14 All 05/28/18 05/28/18 M-F 6:30 PM-7:00 PM :30 NM 1 $1,000.00
Week: 05/28/18 06/03/18 1------ 1 $1,000.00
N 15 All 05/22/18 05/22/18 M-F 6:30 PM-7:00 PM :30 NM 1 $1,000.00
Week: 05/21/18 05/27/18 -1----- 1 $1,000.00
Week: 05/21/18 05/27/18 -1----- 1 $1,500.00
Week: 05/21/18 05/27/18 ---1--- 1 $1,500.00
Week: 05/28/18 06/03/18 -1----- 1 $1,500.00
N 19 All 05/28/18 05/28/18 The Late Show 10:35 PM-11:35 PM :30 NM 1 $200.00
Week: 05/28/18 06/03/18 1------ 1 $200.00
Week: 05/21/18 05/27/18 -1----- 1 $200.00
Week: 05/21/18 05/27/18 ---1--- 1 $200.00
Week: 05/21/18 05/27/18 ----1-- 1 $200.00
Week: 05/21/18 05/27/18 ----1-- 1 $400.00
Week: 05/28/18 06/03/18 -1----- 1 $200.00
N 25 All 05/28/18 05/28/18 CBS This Morning 7:00 AM-9:00 AM :30 NM 1 $400.00
Week: 05/28/18 06/03/18 1------ 1 $400.00
Week: 05/21/18 05/27/18 -1----- 1 $400.00
Week: 05/21/18 05/27/18 ---1--- 1 $400.00


KPAX-TV/KAJ-TV
127039 / 09086819
PO Box 4827

Start/End Spots/
Week: 05/21/18 05/27/18 ----1-- 1 $400.00
Week: 05/28/18 06/03/18 -1----- 1 $400.00
Week: 05/21/18 05/27/18 --1---- 1 $300.00
Totals 0.00 30 $16,100.00
Time Period # of Spots Gross Amount Agency Comm. Net Amount

04/30/18 - 05/27/18 20 $11,300.00 ($1,695.00) $9,605.00
05/28/18 - 05/29/18 10 $4,800.00 ($720.00) $4,080.00
Totals 30 $16,100.00 ($2,415.00) $13,685.00
Signature: Date:
This station does not discriminate in the sale of advertising time, and will accept no advertising which is placed with an intent to
discriminate on the basis of race, national origin or ancestry. Advertiser hereby certifies that it is not buying broadcasting air time
under this advertising sales contract for a discriminatory purpose, including but not limited to decisions not to place advertising on
particular stations on the basis or race, national origin or ancestry. We reserve the right not to accept all copy.

EXHIBIT D
Contract # 3346016 Date Entered 05/21/18 KECI+KCFW Combo (KECI+KCFW)
^^^^^^^^^^^^^^^^^^^ Schedule Dates Last Modified Bv Broadcast Month Scots Ratp
05/22/18-05/29/18 05/21/18
May. 2018 16 $5,990.00
Principles First (124745) Entered By Leslie Stoll-Onelll
Jun. 2018 9 $3,660.00
Nebo Media (10105) CO-OP No
Grand Total: 25 $9,650.00
Headline # ECR26016641
•RUtAe! i\'!il SJ Missoula' MT 59802 product POLITICAL ISSUE (ns) (1187)
Demo
ISSUE ADVERTISING (218560)
^^^^^^^^^^^^^^^^^^^^^^ Salesperson Order Type Normal
Katz/DC, Washington DC (4022)
Package Deal
Katz Washington DC
Commission % 15.00
Nebo Media Buyer Name TJ,Osborne,
PO BOX 9825 Phone/Fax Commission $1,447.50
/
Arlington, VA 22219 CPE
358/446/4080 Net Total $8,202.50
Account Types Sales Tax
National/Political Issue Agency BRD
Billing Type Standard
Issue
Separation: 30
Une One Type / Break Type (Ref #) Dates Sec Length Run Times SPW Mo Tu We Tn Fr Sa Su Spots Rate Total Station Comments Entered
1.0 Normal Una /Mews 05/22/18-05/22/18 1 :30 6A- 6:3QA (MST) i1 i1 x* !1 i i i 1 J290.00 $290.00 KECI+KCFW Combo (KECI-f KCFW MONTANA TODAY2 S/21/18
2.0 Normal Une /News 05/2S/1S-05/25/18 1 :30 6A- 6:30A (MST) i x! 1 1 $290.00 $290.00 KEd+KCFW Combo (KECI+KCFW MONTANA TODAY2 S/21/1S
3.0 Normal Line /News OS/28/18-05/28/18 1 :30 6A- 6:30A (MST) i X i l l ! 1 $290.00 $290.00 KECHKCFW Combo (KEd+KCFW MONTANA TODAY2 5/21/18
4.0 Normal Line /News OS/22/18-05/22/18 1 :30 6:30A- 7A (MST) i i

V
A
i i1 !i 1 $290.00 $290.00 KECI+KCFW Combo [KECI+KCFW MONTANA TODAY3 S/21/18
5.0 Jormal Une / News OS/23/18-05/23/18 1 :30 6:30A-7A(MST) i X i i 1 $290.00 $290.00 KECI+KCFW Combo (KECI+KCFW MONTANA TODAY3 S/21/18
6.0 formal Line / News OS/24/18-05/24/18 1 :30 6:30A- 7A (MST) 1 i x 1 1 1 $290.00 $290.00 KECI+KCFW Combo (KECI+KCFW MONTANA TODAY3 S/21/18
7.0 formal Une / News OS/28/18-05/28/18 1 :30 6:30A- 7A (MST) 1 X ii ! i 1 5290.00 $290.00 KECI+KCFW Combo (KECI+KCFW MONTANA TODAYS 5/21/18
8.0 formal Une / News OS/29/18-05/29/18 1 :30 6:30A- 7A (MST) 1 V

X
F
1 i ! 1 $290.00 $290.00 KECI+KCFW Combo (KECI+KCFW MONTANA TODAYS 5/21/1S
9.0 formal Une/ News OS/25/ 18-05/25/1S 1 :30 5P- S:30P (M5T) i i
1 >
t 1i A
x 1i 1i 1 $460.00 $460.00 KECI+KCFW Combo (KEd+KCFW NEWS AT 5 5/21/18
ID.O formal Une /News OS/28/18-05/28/18 1 :30 5P- 5:30P (MST) i X i 1 i 1 5460.00 $460.00 KECI+KCFW Combo (KECI+KCFW NEWS ATS 5/21/18
11.0 "Jormal Une / News 05/22/18-05/22/18 1 :30 6P- 6:30P (MST) i i x i I 1 i 1 S540.00 $540.00 KECI-fKCFW Combo (KECI+KCFW News at 6pm 5/21/18
12.0 formal Une/ News 05/23/18-OS/B/18 1 :BO 6P- 6:30P (MST) 1 f1 x* !i i ! 1 $540.0C $540.00 KECI+KCFW Combo (KECI+KCFW News at 6pm S/21/18
13.0 formal Une / News 05/25/18-05/25/18 1 :30 6P- 6:30P (MST) 1 i !x| I 1 $540.00 $540.00 KECI+KCFW Combo (KECI+KCFW News at 6pm 5/21/18
CONFIRMATION CONTRACT
Accepted-Agency/Advertiser: Date: Accepted-Station: Date: Comments:
The patties intend for the Standard Advertiser Terms and Conditions ("Terms") located at... ^ 1224 ... to be part of their agreement, and Ihe sale of advertising is expressly subject to said Terms.
B/E Bookend P/B Piggy Back

Contract # 3346016 Date Entered 05/21/18 KECI+KCFW Combo (KECI-i-KCFW}
By Broadcast Month Spots Rat_g
Schedule Dates 05/22/18-05/29/18 Last Modified 05/21/18
BEST
May. 2018 16 $5,990.00
+KCFWvertiser Principles First (124745) Entered By Leslie Stoll-Oneill
Jun. 2018 9 $3,660.00
Agency Nebo Media (10105) C°-°P No
Product POLITICAL ISSUE (ns) (1187) Headlines ECR26016641
Brand ISSUE ADVERTISING (218560) Demo
Salesperson KatZ/DC, Washington DC (4022) Order Type Normal
sales office Katz Washington DC Packaae Deal
•^, ~ , Commission % IS 00
Nebo Media Buyer Name TJ,Osborne, '
PO Box 9825 Phone/Fax / Commission $1,447.50
Arlington, VA 22219 CPE 358/446/4080 NetTotal $8,202.50
Account Types National/Political Issue Agency BRD sales Tax
Comments Issue
Separation: 30
Line Line Type / BreakType (Ref #} Dates Sec Length Run Times SPW Mo Tu We Th Fr Sa Su Spots Rate Total Station Comments Entered
14.0 Normal Line /News 05/24/18-05/24/18 1 :30 10P-1Q:3SP(MST) l I X ! 1 $660.00 $660.00 KECI+KCFW Combo (KECI+KCFW News at 10 5/21/18
15.0 Normal Line / News 05/28/13-05/28/18 1 :30 10P-10:35P(MST) l X 1 1 1 $660.00 $660.00 KEd+KCFW Combo (KECI+KCFW News at 10 5/21/18
16.0 Normal Une / SPOT OS/22/ 18-05/22/18 1 :BO 4P-5P(MST) 1 1 x ! 1 $220.00 $220.00 KECI+KCFW Combo (KECI+KCFW ELLEN 5/21/18
17.0 Normal Une/ SPOT 05/28/1S-GS/28/1S 1 :30 4P-5P(MST) 1 x

i
1
i 1 $220.00 $220.00 KEQ+KCFW Combo (KECI+KCFW ELLEN 5/21/18
l
i
1S.O Normal Line /SPOT 05/23/18-05/23/18 1 :30 6:30P-7P(MST) ! * 1 $300.00 $300.00 KECI+KCFW Combo (KECI+KCFW Entertainment Tonight 5/21/18
1 i
19.0 Normal Line /SPOT 05/25/18-05/25/18 1 :30 6:30P- 7P (MST) 1 x ' 1 $300.00 $300.00 KECI+KCFW Combo (KECI+KCFW Entertainment Tonight 5/21/18
20.0 Normal Line /SPOT 05/29/18-05/29/18 1 :30 6:30P- 7P (MST) l ix! 1 $300.00 $300.00 KECI+KCFW Combo (KECI+KCFW Entertainment Tonight 5/21/18
21.0 Normal Line /SPOT 05/22/18-05/22/18 1 :30 10l35P-ll:35P(MST) 1 x| 1

i 1 $290.00 $290.00 KECI+KCFW Combo (KECI+KCFW Tonight Show 5/21/18
05/24/18-05/24/18 1 :30 10:35P- 11:35P (HST) l

i ii x
i 1 $290.00 $290.00 KECI+KCFW Combo (KECI+KCFW Tonight Show 5/21/18
22.0 Normal Une / SPOT
i | ii
23,0 formal Une / SPOT 05/28/18-05/2S/1B 1 :30 10:35P- 11:35P (MST) l X i 1 $290,00 $290.00 KECI+KCFW Combo (KECI+KCFW Tonight Show 5/21/18
24.0 formal Une / SPOT 05/26/18-05/26/13 1 :30 10:30P- 12A (MST) l ! xi 1 $400.00 $400.00 KEd+KCFW Combo (KECI+KCFW SNL 5/21/18
25.Q formal Une / SPOT 05/29/18-05/29/18 1 :30 7P- 9P (MST) l *i 1 1 $860.00 $860.00 KEd+KCFW Combo (KECI+KCFW America's Got Talent 5/21/18
CONFIRMATION CONTRAC
Accepted-Agency/AdvettJser: Date: Accepted-Station: Date: Comments:
The parties intend for the Standard Advertiser Tcims and Conditions ("Tenns") located at... http://sbgi.net/7p=1224 ... to be part of their agreement, and the sale of advertising is expressly subject to said Terms.

Contract # 26016641 Changes as of: 5/18/2018 at 1:44 PM Version: Original Order
CPE: 358/446/4080 Flight: 5/22/18-5/29/18 Station: KECI Con Type: POLITICAL/VOTE
Agency: NEBO MEDIA Advertiser: Principles First PAC Market: Missoula Total $: $9,650.00
1911 N.FORTMYER Product: Issue Office: WASHINGTON Total Spots: 25
DRIVE
KATZ TELEVISION
GROUP
ARLINGTON, VA
22209
Agency Order#: 7363565 Service: Nielsen Total CPP: $0.00
Buyer: Osborne, TJ Primary Demo: Total GRP:

Salesperson: MATTHEW MULZOFF Assistant: MATTHEW MULZOFF Traffic #: 3346016
125 West 55th St 202-955-5342 202-955-5342
New York, NY 10Q19
Separation:
Comments: Separation: 30
5/22 - 5/29 Total Total

# Day/Time DP Program Rate Len 5/22 5/23 5/24 5/25 5/26 5/27 5/28 5/29 Spots $ CPP* GRP*
Tu-F,M
1 6a-6:30a MONTANA TODAY2 $290.00 30 1 0 0 1 0 0 1 0 3 $870.00 $0.00 0.0
Tu-F,M
2 6:30a-7a MONTANA TODAYS $290.00 30 1 1 1 0 0 0 1 1 5 $1,450.00 $0.00 0.0
Tu-F,M
3 5p-5:30p NEWS AT 5 $460.00 30 0 0 0 1 0 0 1 0 2 $920.00 $0.00 0.0
Tu-F,M
4 6p-6:30p News at 6pm $540.00 30 1 1 0 1 0 0 0 0 3 $1,620.00 $0.00 0.0
Tu-F.M
5 10p-10:35p News at 10 $660.00 30 0 0 1 0 0 0 1 0 2 $1,320.00 $0.00 0.0
Tu-F,M
6 4p-5p ELLEN $220.00 30 1 0 0 0 0 0 1 0 2 $440.00 $0.00 0.0
Tu-F,M
7 6:30p-7p Entertainment Tonight $300.00 30 0 1 0 1 0 0 0 1 3 $900.00 $0.00 0.0
Tu-F,M
8 10:35p-11:35p Tonight Show $290.00 30 1 0 1 0 0 0 1 0 3 $870.00 $0.00 0.0
Sa
9 10:30p-12m SNL $400.00 30 0 0 0 0 1 0 0 0 1 $400.00 $0.00 0.0
Tu
10 7p-9o America's Got Talent $860.00 30 0 0 0 0 0 0 0 1 1 $860.00 $0.00 0.0
TOTALS: 5 3 3 4 1 0 6 3 25 $9,650.00 $0.00 0.0
Printed on 05/21/2018 at 01:44 PM | * Stats based on Primary Demo Pagel of 2

Contracts 26016641 _C_hanges as of: 5/18/2018 at 1:44 PM Version: Original Order
DRIVE
KATZ TELEVISION
GROUP
ARLINGTON, VA
22209
Agency Order #: 7363565 Service: Nielsen Total CPP: $0.00
125WBSt55thSt 202-955-5342 202-955-5342

New York, NY 10019
Separation:
Special
Instructions
Order Level Comments

Date/Time Added by Comment
05/18/18 1;45 PM MATTHEW MULZOFF Separation: 30
Competitive Information Daypart Summary Monthly Summary

Market Btldqet:$26,081 Day/Time % Distrib Spots Dollars CPP GRP Month Spots Dollars
KEC] Share: 37% 100% 25 $9,650.00 N/A 0.0 2018-Mav 16 $5,990.00
Comment: Total 100% 25 $9,650.00 N/A 0.0 2018-Jun 9 $3,660.00
KPAX: 60% Total 25 $9,650.00
KTMF: 3%
Transaction History
Trans Created/Received Created by Status Spot* Spot- $Chg •Contract $ Comment
Queued for
Electronic
Contracting 5/18/18 3:59 PM $0 $0
New 5/1 8/18 1:44 PM MATTHEW MULZOFF New 25 $9,650.00 $9,650.00
PARAGRAPHS 49 AND 50 OF THE UNITED STATES FEDERAL COMMUNICATIONS COMMISSION'S REPORT AND ORDER NO. 07-217 PROVIDES THAT BROADCAST STATIONS'
Non-Discrimination ADVERTISING CONTRACTS WILL NOT DISCRIMINATE ON THE BASIS OF RACE OR ETHNICITY, AND MUST CONTAIN NONDISCRIMINATION CLAUSES. CONSISTENT WITH THIS ORDER,
Policy KATZ MEDIA GROUP (INCLUDING ANY SUBSIDIARY OR DIVISION OF KATZ) DOES NOT DISCRIMINATE IN ANY BROADCAST ADVERTISING CONTRACT ON THE BASIS OF RACE OR
ETHNICITY AND EVALUATES, NEGOTIATES AND COMPLETES ITS BROADCAST ADVERTISING CONTRACTS WITHOUT REGARD TO RACE OR ETHNICITY.
Printed on 05/21/2018 at 01:44 PM | * Stats based on Primary Demo Page 2 of 2

AGREEMENT FORM FOR

Station and Location: Date
S
TJ Osborne
Time of
Days Class
Package
This broadcast time will be used by:. Principles First PAC
Copyright ©2013 by the National Association of Broadcasters. May not be copied, reproduced or further distributed
1

"COMMUNICATES A POLITICAL MATTER OF NATIONAL IMPORTANCE."
Programming that "communicates a political matter of national importance"

references to "our next senator", "our person in Washington" or "the President"};
Does the programming (in whole or in part) communicate "a message

relating to any political matter of national importance?"
D Yes R No
For programming that "communicates a message relating to any political matter of

national importance," list the name of the legally qualified candidate(s) the programming
(hereinafter referred to as the "sponsor").

national importance," attach Agreed Upon Schedule (Page 5)
2

DOES NOT "COMMUNICATE A POLITICAL MATTER OF NATIONAL
IMPORTANCE"
by (name and address): _____^_^_
directors below (or attach separately): __________^^_^_
3

liability, including reasonable attorney's fees, that may ensue from the broadcast of the
above-requested advertisement(s). For the above-stated broadcast(s), the sponsor
station at least before the time of the scheduled broadcasts.
5/18/2018 TJ Osborne ±M£SiS£tw 2023375700

7O BE SIGNED BY STATION REPRESENTATIVE

cepted D Accepted in Part D Rejected
4

Time of
Days Class
Package

spots "communicating a political matter of national importance" air, that information
that and rates for specific spots aired. The FCC's online political files include a folder for
"Terms and Disclosures." NAB suggests that, for stations subject to the online public file
Copyright© 2013 by the National Association of Broadcasters. May not be copied, reproduced or further distributed
5
EXHIBIT E
EXHIBIT F
CONTRACT
KPAX-TV/KAJ-TV Contract / Revision Alt Order #
PO Box 4827 127038 / 09086820
Missoula, MT 59806 Product
(406) 542-4400 PRINCIPLES FIRST PAC
Contract Dates Estimate #
05/30/18 - 06/05/18 4081
And: Billing Cycle Billing Calendar Cash/Trade
EOM/EOC Broadcast Cash
Nebo Media Inc
1911 N Ft Myer Dr Property Account Executive Sales Office
Ste 400 KPAX Alex Hong (HRP) National Washington
Arlington, VA 22209 Special Handling
Demographic
Adults 35+
Agy Code Advertiser Code Product 1/2

358 446
Agency Ref Advertiser Ref
Start/End Spots/
Week: 06/04/18 06/10/18 1------ 1 $400.00
Week: 06/04/18 06/10/18 1------ 1 $300.00
Week: 05/28/18 06/03/18 --1---- 1 $300.00
Week: 05/28/18 06/03/18 ---1--- 1 $300.00
Week: 05/28/18 06/03/18 ----1-- 1 $300.00
N 6 All 06/04/18 06/04/18 M-F 4:00 PM-5:00 PM :30 NM 1 $200.00
Week: 06/04/18 06/10/18 1------ 1 $200.00
N 7 All 05/30/18 05/30/18 M-F 4:00 PM-5:00 PM :30 NM 1 $200.00
Week: 05/28/18 06/03/18 --1---- 1 $200.00
N 8 All 05/31/18 05/31/18 M-F 4:00 PM-5:00 PM :30 NM 1 $200.00
Week: 05/28/18 06/03/18 ---1--- 1 $200.00
N 9 All 06/01/18 06/01/18 M-F 4:00 PM-5:00 PM :30 NM 1 $200.00
Week: 05/28/18 06/03/18 ----1-- 1 $200.00
Week: 05/28/18 06/03/18 --1---- 1 $1,500.00
Week: 05/28/18 06/03/18 ----1-- 1 $1,500.00


KPAX-TV/KAJ-TV
127038 / 09086820
PO Box 4827

Start/End Spots/
Week: 05/28/18 06/03/18 --1---- 1 $400.00
N 13 All 05/31/18 05/31/18 M-F 6:30 PM-7:00 PM :30 NM 1 $1,000.00
Week: 05/28/18 06/03/18 ---1--- 1 $1,000.00
Week: 06/04/18 06/10/18 1------ 1 $1,500.00
Week: 05/28/18 06/03/18 ----1-- 1 $1,500.00
Week: 06/04/18 06/10/18 1------ 1 $200.00
Week: 05/28/18 06/03/18 --1---- 1 $200.00
Week: 05/28/18 06/03/18 ---1--- 1 $200.00
Week: 05/28/18 06/03/18 ----1-- 1 $200.00
Week: 05/28/18 06/03/18 ---1--- 1 $400.00
Week: 05/28/18 06/03/18 ----1-- 1 $400.00
Week: 06/04/18 06/10/18 1------ 1 $400.00
Week: 06/04/18 06/10/18 -1----- 1 $400.00
Week: 05/28/18 06/03/18 --1---- 1 $400.00
Week: 05/28/18 06/03/18 ---1--- 1 $400.00
Week: 05/28/18 06/03/18 ----1-- 1 $400.00
Totals 0.00 26 $13,400.00


KPAX-TV/KAJ-TV
127038 / 09086820
PO Box 4827

Time Period # of Spots Gross Amount Agency Comm. Net Amount

05/28/18 - 06/05/18 26 $13,400.00 ($2,010.00) $11,390.00
Totals 26 $13,400.00 ($2,010.00) $11,390.00
Signature: Date:
This station does not discriminate in the sale of advertising time, and will accept no advertising which is placed with an intent to
discriminate on the basis of race, national origin or ancestry. Advertiser hereby certifies that it is not buying broadcasting air time
under this advertising sales contract for a discriminatory purpose, including but not limited to decisions not to place advertising on
particular stations on the basis or race, national origin or ancestry. We reserve the right not to accept all copy.

EXHIBIT G
Contract # 3352683 DateEntered 05/25/18 KECI+KCFW Combo (KECI+KCFW)
Schedule Dates 0 5/3 0/1 8 -0 6/0 S/ 18 Last Modified 05/25/18 By Broadcast Month Spots Rate
BBssr
Jun. 2018 24 $8,700.00
+KCFWvertiser Principles First (124745) Entered By Leslie StolI-Onelll
Agency Nebo Media (10105) co*op No
Product POLITICAL ISSUE (ns) (1187) Headline # ECR26016644
lUMy Brand
salesperson
sales office
Katz/DC, Washington DC (4022)
Katz Washington DC
Demo
Order Type
Pacha9e Deal
Normal
. .. _ , Commission % 1 S flf)
Nebo Media Buyer Name TJ,Osbome, i3'

Arlington, VA 22219 CPE 358/446/4081 MetTotal $7,395.00
Account Types National/Political Issue Agency BRD SaiesTax
Comments Issue.
Separation: 30
Line Une Type / Break Type (Ref #) Dates Sec Length RunTimes SPW Mo Tu We Tri Fr Sa Su Spots Rate Total Station Comments Entered
1.0 Normal Une / News 05/31/18-05/31/18 1 :30 S:30A- 6A (MST) l ! X 1i 1 $210.00 $210.00 KEd+KCFW Combo (KECI+KCFW MONTANA TODAY! 5/25/18
2.0 Normal Line / News 05/30/18-05/30/18 1 :30 6A- 6:30A (MST) l y
1 $290.00 $290.00 KECH KCFW Combo (KECI-fKCFW MONTANA TODAY* 5/25/18
3.0 Normal Line /News 06/01/18-06/01/18 1 :30 6A- 6:30A (MST) 1 xt i 1 $290.00 $290.00 KECI+KCFW Combo (KECI*KCFW MONTANA TODAY2. 5/25/18
4.0 Normal Line/ News Q6/04/18-06/CW/18 1 :30 6A- 6:30A (MSI) l X

1
1 j 1 $290.00 $290.00 KECI+KCFW Combo (KEQ+KCFW MONTANA TODAYS. 5/25/18
5.0 Normal Line /News OS/30/ 18-05/30/18 1 :30 6:30A- 7A (MST) l X I 1 3290.00 $290.00 KECI+KCFW Combo (KECI+KCFW MONTANATODAY3 5/25/1S
1
6.0 Normal One / News 05/31/18-05/31/18 1 :30 6:30A-7A(MST) 1 X ! 1 $290.00 $290.00 KECI+KCFW Combo (KEd+KCFW MONTANA TODAYS 5/25/18
1
7.0 Normal Line / News 06/0 1/18-06/0 1/1 8 1 :30 6:30A-7A(MST) l 1 V !
A i 1 $290.00 $290.00 KECI+KCFW Combo (KEd-f KCFW MONTANA TODAY3 5/25/18
8.0 Normal Line / News 06/04/13-06/04/18 1 :30 6:30A-7A(MST) 1 X i 1 $290.00 $290.00 KECI+KCFW Combo (KEd+KCFW MONTANA TODAY3 5/25/18
9.0 Normal Line / News 06/05/18-06/05/18 1 :30 6:30A- 7A (MST) l X 1 I 1 $290.00 $290.00 KECI+KCFW Combo (KECI+KCFW MONTANA TODAY3 5/25/18
10.0 Normal Line /News 06/01/16-06/01/18 1 :30 5P- 5:30P (MST) l X 1 $460.00 3460.00 KECI+KCFW Combo (KEC1+KCFW NEWS AT 5 5/25/18
11.0 formal Une /News 06/04/18-06/04/18 1 :30 5P- S:30P (MST) 1 X i 1 3460.00 $450.00 KECI+KCFW Combo (KECI+KCFW NEWS AT 5 5/25/18
12.0 Normal Une / News 05/30/18-05/30/18 1 :30 6P- 6:30P (MST) 1 X ! 1 $540.00 $540,00 KEQ-f KCFW Combo (KECI+KCFW News at 6pm 5/25/18
13.D Normal Une / News 06/01/18-06/01/18 1 :30 6P- 6:30P (MST) 1 x| 1 $540.00 $540.00 KECI+ KCFW Combo (KECHKCFW Mews at 6pm 5/25/18
Accepted-Agency/Adverdser; Date: Accepted-Station: Date: Comments:
The parties intend for the Standard Advertiser Terms and Conditions ("Terms") located at... hrtp://sbgi.net/?p=1224 ... to be part of their agreement, and the sale of advertising is expressly subject to said Terms.
B/E Bookend P/B Piqqy Back

Paae 1 ol
Contract # 3352683 D^^t^a 05/25/18 KECI+KCFW Combo (KECI+KCFW)
By Broadcast Month Spots Rate
Schedule Dates 05/30/18-06/05/18 tart Modified 05/25/18
Jun. 2018 24 $8,700.00
+KCFWvertiser Principles First (124745) Entered By Leslie StolI-Qnelll
HH=3T Agency
Product
Brand
Nebo Media (10105)
POLITICAL ISSUE (ns) (1187)

c°-°p
Headlines
Dem°
No
ECR26016644
Salesperson KatZ/DC, Washington DC (4022) OrderType Norrnal
sales office Katz Washington DC Package Deal
-^, „ . Commission % i K (in

Nebo Media Buyer Name TJ,Osborne, LD' u
Arlington, VA 22219 CPE 358/446/4081 Net Total $7,395.00
Account Types National/Political Issue Agency BRD sales Tax

Comments T<;CMP
Separation: 30
Une Une Type/ BreakType (Ref #) Dates Sec Length RunTimes SPW Mo Tu We Th Fr Sa Su Spots Rate Total Station Comments Entered
14.0 Normal Line /News 06/04/18-06/04/18 1 :30 6P- 6:30P (MST) l X ic 1 ^540.00 $540.00 KEd-f KCFW Combo (KECI+KCFW News at 6pm 5/2S/1E
1
15.0 Normal Line /News 05/31/18-05/31/18 1 :30 10P- 10:35P (MST) 1 x 1 $660.00 $660.00 KEd-t-KCFW Combo (KECI+KCFW News at 10 S/25/1S
16.0 Normal Une/ News 06/M/18-06/M/18 1 :30 10P- 10:35P (MST) 1 X 1 $660.00 $650.00 KECI+KCFW Combo (KECT+KCFW News at 10 5/25/18
17.0 Normal Une / News 05/31/1S-OS/31/1S 1 :30 4P- SP (MST) 1 ! I *

1 $220.00 $220.00 KEd+KCFW Combo [KEd+KCFW ELLEN 5/25/18
18.0 Normal Line / News 06/04/1E-06/04/18 1 :3o 4P- 5P (MST) 1 X 1 $220.00 5220.00 KEQ+KCFW Combo (KECI+KCFW ELLEN 5/25/1S
19.0 Normal Line /SPOT 05/31/18-05/31/18 1 :30 6i30P-7P(MST) 1 i X 1 ?300.00 $300.00 KECI+KCFW Combo (KECI+KCFW Entertainment Tonight 5/25/18
20,0 Normal Une /SPOT 06/04/18-06/04/18 1 :30 6:30P-7P(MST) 1 * ! 1 ^300.00 $300.00 KECI+KCFW Combo [KECI+KCFW Entertainment Tonight 5/25/18
21.0 Normal Line / SPOT 05/31/18-05/31/18 1 :30 10:35P-11:35P(MST) 1 j j x 1 1290.00 $290.00 KECI+KCFW Combo (KEd+KCFW Tonight Show 5/25/18
22.0 temal Une / SPOT 06/01/18-06/01/15 1 :30 10:35P- ll:3SP (MST) 1 X 1 ?290.00 $290.00 KEQ+KCFW Combo (KECI+KCFW Tonight Show 5/25/18
23.0 formal Une /SPOT 06/04/18-06/04/18 1 :30 10:35P- 11:35P (MST) 117"! i 1 4290,00 $290.00 KEQ+KCFW Combo (KEQ+KCFW Tonight Show 5/25/18
24.0 Normal Une / SPOT 06/02/18-06/02/18 1 :30 10:30P-12A(MST) 1 1 y_ 1 $400.00 $400.00 KEQ+KCFW Combo (KEQ+KCFW SNL 5/25/18
Accepted-Agency/Advertiser: Date: Accepted-Station: Date: Comments:
The parties intend for the Standard AdvcrtiserTcmls and Conditions ("Terms") localed at... http://sbgi.net/7p=l224 ... to be part of iheir agreement, and the sale of advertising is expressly subj eel to said Terms.

Pace 2 ol
Contracts 26016644 Changes as of: 5/18/2018 at 1:46 PM Version: Original Order
1911N.FORTMYER Product: Issue Office: WASHINGTON Total Spots: 24
DRIVE
KATZ TELEVISION
GROUP
ARLINGTON, VA
22209
Agency Order #: 7363586 Service: Nielsen Total GPP; $0.00

Salesperson: MATTHEW MULZOFF Assistant: MATTHEW MUL2OFF Traffic #: 3352683
125 West 55th St 202-955-5342 202-955-5342
New York, NY 10019
Separation:
Comments: Separation: 30
5/30 - 6/5 Total Total

# Day/Time DP Program Rate Len 5/30 5/31 6/1 6/2 6/3 6/4 6/5 Spots $ CPP* GRP"
W-F.M-TU
1 5:30a-6a MONTANA TODAY1 $210.00 30 0 1 0 0 0 0 0 1 $210.00 $0.00 0.0
W-F,M-Tu
2 6a-6:30a MONTANA TODAY2 $290.00 30 1 0 1 0 0 1 0 3 $870.00 $0.00 0.0
W-F,M-Tu
3 6:30a-7a MONTANA TODAYS $290.00 30 1 1 1 0 0 1 1 5 $1,450.00 $0.00 0.0
W-F,M-Tu
4 5p-5:30p NEWS AT 5 $460.00 30 0 0 1 0 0 1 0 2 $920.00 $0.00 0.0
W-F.M-Tu
5 6p-6:30p News at 6pm $540.00 30 1 0 1 0 0 1 0 3 $1,620.00 $0.00 0.0
W-F,M-Tu
6 10p-10;35p News at 1 0 $660.00 30 0 1 0 0 0 1 0 2 $1,320.00 $0.00 0.0
W-F,M-Tu
7 4p-5p ELLEN $220.00 30 0 1 0 0 0 1 0 2 $440.00 $0.00 0.0
W-F.M-Tu
8 6:30p-7p Entertainment Tonight $300.00 30 0 1 0 0 0 1 0 2 $600.00 $0.00 0.0
W-F,M-Tu
9 10:35p-11:35p Tonight Show $290.00 30 0 1 1 0 0 1 0 3 $870.00 $0.00 0.0
Sa
10 10:30p-12m SNL $400.00 30 0 0 0 1 0 0 0 1 $400.00 $0.00 0.0
TOTALS: 3 6 5 1 0 8 1 24 $8,700.00 $0.00 0.0
Printed on 05/25/2018 at 12:29 PM I * Stats based on Primary Demo Page 1 of 2

Contract* 26016644 Changes as of: 5/18/2018 at 1:46 PM Version: Original Order
DRIVE
KATZ TELEVISION
GROUP
ARLINGTON, VA
22209
Agency Order #: 7363586 Service: Nielsen Total CPP: $0.00

Salesperson: MATTHEW MULZOFF Assistant: MATTHEW MULZOFF Traffic #: 3352683
125 West 55th St 202-955-5342 202-955-5342
New York, NY 10019
Separation:
InstructionsSKSl&S i
Order Level Comments

Date/Time Added by Comment
05/18/18 1:47 PM MATTHEW MULZOFF Separation: 30
Competitive Information Daypart Summary Monthly Summary

Market Budget: $23,514 Day/Time % Distrib Spots Dollars CPP GRP Month Spots Dollars
KECI Share: 37% 100% 24 $8,700.00 N/A 0.0 2018-Jun 24 $8,700.00
Comment: Total 100% 24 $8,700.00 N/A 0.0 Total 24 $8,700.00
KPAX: 60%
KTMF: 3%
Transaction History
Trans Created/Received Created by Status Spot* Spot- $Chg Contract $ Comment
Queued for
Electronic
Contracting 5/25/18 10:12 AM $0 $0
New 5/l8/181:46PM MATTHEW MULZOFF New 24 $8,700.00 $8,700.00
PARAGRAPHS 49 AND 50 OF THE UNITED STATES FEDERAL COMMUNICATIONS COMMISSION'S REPORT AND ORDER NO. 07-217 PROVIDES THAT BROADCAST STATIONS'
Non-Discrimination ADVERTISING CONTRACTS WILL NOT DISCRIMINATE ON THE BASIS OF RACE OR ETHNICITY, AND MUST CONTAIN NONDISCRIMINATION CLAUSES. CONSISTENT WITH THIS ORDER,
Policy KATZ MEDIA GROUP (INCLUDING ANY SUBSIDIARY OR DIVISION OF KATZ) DOES NOT DISCRIMINATE IN ANY BROADCAST ADVERTISING CONTRACT ON THE BASIS OF RACE OR
ETHNICITY AND EVALUATES, NEGOTIATES AND COMPLETES ITS BROADCAST ADVERTISING CONTRACTS WITHOUT REGARD TO RACE OR ETHNICITY.
Printed on 05/25/2018 at 12:29 PM | * Stats based on Primary Demo Page 2 of 2

AGREEMENT FORM FOR

Station and Location:
TJ Osborne
This broadcast time will be used by:

Copyright © 2013 by the National Association of Broadcasters, May not be copied, reproduced or further distributed
1

"COMMUNICATES A POLITICAL MATTER OF NATIONAL IMPORTANCE."
Programming that "communicates a political matter of national importance"

references to "our next senator", "our person in Washington" or "the President");
Does the programming (in whole or in part) communicate "a message

relating to any political matter of national importance?"
D Yes m No

national importance," list the name of the legally qualified candidate(s) the programming
by (name and address): ______

national importance," attach Agreed Upon Schedule (Page 5)
2

DOES NOT "COMMUNICATE A POLITICAL MATTER OF NATIONAL
IMPORTANCE"
Randy Pullen
3

liability, including reasonable attorney's fees, that may ensue from the broadcast of the
above-requested advertisement(s). For the above-stated broadcasts), the sponsor
station at least before the time of the scheduled broadcasts.
5/18/2018 ; TJ Osborne S^S£?£^W- 2023375700

7O BE SIGNED BY STATION REPRESENTATIVE

D Accepted in Part D Rejected
4

Time of
Days Class
Package

spots "communicating a political matter of national importance" air, that information
that and rates for specific spots aired. The FCC's online political files include a folder for
"Terms and Disclosures." NAB suggests that, for stations subject to the online public file
5
EXHIBIT H

Principles First FEC Complaint

Uploaded by

Principles First FEC Complaint

Uploaded by

4.

Campaign Legal Center (“CLC”) is a nonpartisan, nonprofit 501(c)(3) organization whose

stations—KPAX-TV/KAJ-TV, KECI, and KTMF—according to Federal Communications

by any candidate or candidate’s committee.” 6

intended to raise unlimited funds and make independent expenditures. 8

station manager of KTMF ABC/FOX News in Missoula, Montana, responding to a cease-

As MTN News described:

The ad refers to Rosendale as “Maryland Matt” – a pejorative often used by Democrats to

Principles First’s reports filed with the Commission. 14

raise unlimited funds for independent expenditures. 16

SUMMARY OF THE LAW

quarterly basis, of its receipts and disbursements, 52 U.S.C. § 30104(a)(4)(A)-(B).

party. 52 U.S.C. § 30101(17); 11 C.F.R. § 100.16(a).

within 24 hours. 52 U.S.C. § 30104(g)(1)(A); 11 C.F.R. §§ 104.4(c), 104.5(g)(2), 109.10(d).

independent expenditures in that election aggregating $1,000 or more. Id.

11 C.F.R. §§ 104.4(c), 104.3(b)(3)(vii), 109.10(d)-(e).

reports. 52 U.S.C. §§ 30104(b)(4)(H)(iii), (6)(B)(iii); 11 C.F.R. § 104.4(a).

I. PRINCIPLES FIRST, INC. FAILED TO REPORT INDEPENDENT EXPENDITURES

constituted independent expenditures as that phrase is defined in FECA. 52 U.S.C. §

30101(17); 11 C.F.R. § 100.16(a).

23. According to FCC records, Principles First spent:

TV/KAJ-TV station in Missoula, Montana; 21

station in Missoula, Montana; 22

station in Missoula, Montana; 23

TV/KAJ-TV station in Missoula, Montana; 24

station in Missoula, Montana; 25 and

AGREEMENT FORM FOR

Principles First PAC

Principles First PAC

THIS PAGE MUST BE COMPLETED FOR PROGRAMMING THAT

Programming that “communicates a political matter of national importance”

Does the programming (in whole or in part) communicate “a message

For programming that “communicates a message relating to any political matter of

US House race for Montana primary

For programming that “communicates a message relating to any political matter of

THIS PAGE MUST BE COMPLETED FOR PROGRAMMING THAT

TO BE COMPLETED FOR ALL ISSUE ADVERTISEMENTS

THIS STATION DOES NOT DISCRIMINATE OR PERMIT DISCRIMINATION ON THE

TO BE SIGNED BY ISSUE ADVERTISER (SPONSOR)

TO BE SIGNED BY STATION REPRESENTATIVE

Signature Printed Name Title

AGREED UPON SCHEDULE

Attach proposed schedule with charges (if available):

AFTER AIRING OF BROADCASTS:

(1) actual air time and charges for each spot;

Agy Code Advertiser Code Product 1/2

(* Line Transactions: N = New, E = Edited, D = Deleted)

Contract / Revision Alt Order #

Advertiser Original Date / Revision

(* Line Transactions: N = New, E = Edited, D = Deleted)

Contract / Revision Alt Order #

Advertiser Original Date / Revision

Totals 0.00 30 $16,100.00

Time Period # of Spots Gross Amount Agency Comm. Net Amount

(* Line Transactions: N = New, E = Edited, D = Deleted)

4.0 Normal Line /News OS/22/18-05/22/18 1 :30 6:30A- 7A (MST) i i

8.0 formal Une / News OS/29/18-05/29/18 1 :30 6:30A- 7A (MST) 1 V

B/E Bookend P/B Piggy Back

Brand ISSUE ADVERTISING (218560) Demo

Salesperson KatZ/DC, Washington DC (4022) Order Type Normal

sales office Katz Washington DC Packaae Deal

Account Types National/Political Issue Agency BRD sales Tax

Billing Type Standard

17.0 Normal Une/ SPOT 05/28/1S-GS/28/1S 1 :30 4P-5P(MST) 1 x

21.0 Normal Line /SPOT 05/22/18-05/22/18 1 :30 10l35P-ll:35P(MST) 1 x| 1

05/24/18-05/24/18 1 :30 10:35P- 11:35P (HST) l

B/E Bookend P/B Piggy Back

Buyer: Osborne, TJ Primary Demo: Total GRP:

5/22 - 5/29 Total Total

Printed on 05/21/2018 at 01:44 PM | * Stats based on Primary Demo Pagel of 2

Buyer: Osborne, TJ Primary Demo: Total GRP:

125WBSt55thSt 202-955-5342 202-955-5342

Order Level Comments

Competitive Information Daypart Summary Monthly Summary

Printed on 05/21/2018 at 01:44 PM | * Stats based on Primary Demo Page 2 of 2

AGREEMENT FORM FOR