DEMOCRATIC SOCIALISTS OF AMERICA

75 Maiden Lane / Suite 505 / MW^.l 10038

(212) 727-8610 / fax: (212) 60^-6955" / ww.dsausa.org
2001 MAY 2b A 10 59

May 21,2009
To: Daniel Buckley
Honorary Chairs FEC
Bogdan Den itch
Barbara Ehrenreich From: Frank Llewellyn
Dolores Huerta Treasurer DSA PAC
Eliseo Medina
Eugene "Gus " Newport Re: Response to Your Letter Dated April 24,2009, Concerning Democratic
Frances Fox Piven Socialists of America PAC's October Quarterly Report (7/1/08-9/30/08)
Gloria Steinem
Cornel West
The $1,704.37 expenditure paid for a portion of the postage, printing and mailing expenses
of Democratic Left, the newsletter of Democratic Socialists of America (DSA), DSA
Vice Chairs
PAC's connected organization. The 16-page Fall 2008 issue of Democratic Left included
Elaine Bernard
two articles that arguably expressly advocated for the election of then-presidential
Edward Clark
O candidate Barack Obama and against the election of John McCain (primarily the latter).
© Jose LaLuz The newsletter was first distributed in September of 2008, and the vast majority of the
Nl Steve Max copies (approximately 90% of the 7000 copies printed), were sent to bona fide members of
Q Harold Meyerson DSA or were not used. The newsletter did not solicit any contributions, as defined
p>
Maxine Phillips by Commission regulations. Nevertheless, the Democratic Socialists of America PAC paid
fM
Christine Riddiough the portion of the expenses allocable to express advocacy in advance of the
Rosemary Ruether newsletter's publication and distribution. The portion of the expenses allocable to express
Joseph Schwartz advocacy was determined on the basis of the number of pages the articles containing
Ruth Spitz express advocacy occupied relative to the newsletter's total number of pages.
Moll Zelmanowicz
The $1,000 expenditure was an advance payment made to DSA to cover a portion of the
compensation of a DSA employee who was organizing students on college campuses. At
Founding Chair
the time of the payment, it was believed that the employee would at times expressly
Michael Harrington
advocate for the election of Barack Obama. After DSA PAC made the expenditure, and
(1928-1989)
the October quarterly report was filed, it was determined that the employee engaged in
hardly any express advocacy and that the fair market value of the time involved was $250.
National Director Moreover the employee never solicited contributions, as defined by Commission
Frank Llewellyn regulations. We did not amend the report to remove the over-expenditure from Schedule E
and report it as an "other disbursement" on line 29 of Schedule B simply because it was a
Youth Organizer relatively small amount and we did not think the public interest was harmed by this type of
Erik Rosenberg "over-reporting."

Financial Manager Finally, I understand that you spoke with our attorney, Paul J. Murphy, who verified with
Fatou Camara you the adequacy of this response. If you should require any additional information,
however, please do not hesitate to contact me.
 Federal Election Commission
ENVELOPE REPLACEMENT PAGE FOR INCOMING DOCUMENTS
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(3/2005)