Correct the Record was a super PAC created to support the 2016 presidential candidacy of former U.S. Secretary of State Hillary Clinton by providing opposition research on her opponents in the election. The PAC was run by Clinton ally David Brock as part of a network designed to boost Clinton’s chances. The PAC was an offshoot of another Brock organization, American Bridge 21^st Century.

Correct the Record ceased operations after the 2016 presidential election.

Formation

Correct the Record originated in 2013 as a project of American Bridge PAC. The entity was designed to provide a rapid response to attacks by Republicans on Democratic candidates in future elections.

The project initially hired four Democratic political operatives. The team was to be led by Burns Strider, a political consultant who handled outreach to faith and religious groups for Hillary Clinton’s 2008 presidential campaign. Strider was joined by Democratic strategist Isaac Wright, former chief of staff to Rep. Loretta Sanchez (D-California) Adrienne Elrod, and former research director for U.S. Sen. Bill Nelson (D-Florida) Sam Ritzman.

The project had already secured funding from Susie Tompkins Buell, a national co-chair of the Ready for Hillary PAC, and Clinton donor Steve Bing. ¹

The PAC operated until the conclusion of the 2016 Presidential election, at which time it ceased operations.

Coordination Controversy

In May 2015, Correct the Record separated from American Bridge and became its own entity. Clinton campaign attorney Marc Elias wrote a memo (released publicly after it was allegedly hacked by hackers with ties to Russian intelligence²) that expressed confidence that Correct the Record and the Clinton campaign would be allowed to legally coordinate. Normally, FEC rules prohibit super PACs and campaigns from coordinating.

The committee based its argument on a provision in Federal Election Commission rules by which Correct the Record’s communications could be considered not “public communications,” allowing coordination.³ The FEC eventually did allow the campaign and the super PAC to coordinate.

The left-leaning Campaign Legal Center filed a complaint in October 2016 alleging that Correct the Record had violated campaign finance law. Brendan Fischer, an attorney with the organization, called Correct the Record’s actions a “brazen attempt to undermine the campaign finance laws.” It also alleged that Correct the Record employees have conducted opposition research, trained surrogates, pitched stories to reporters, and led “rapid response” efforts on behalf of the Clinton campaign. Correct the Record denied the allegations.⁴

This wasn’t the first time Correct the Record skirted campaign finance laws. In May 2016, Correct the Record got cable news channels to air a video opposing then-Republican candidate Donald Trump for free. It made videos and only posted them online and its own social media accounts. Paul S. Ryan of the Campaign Legal Center called the committee’s actions “illegal” and a “charade” and said it was absurd for the super PAC to take advantage of the internet exemption that was intended solely for campaign volunteers and bloggers.⁵

On August 13, 2020, conservative nonprofit Patriots Foundation issued a lawsuit against the Federal Electoral Commission (FEC) for failing to act on a previous complaint it had issued in April against political operative David Brock and four of his organizations. ^{6 7} The complaint claimed that David Brock had used Correct the Record as well as Media Maters, American Bridge 21^st Century, and American Bridge 21^st Century Foundation to illegally coordinate with Hillary Clinton’s 2016 presidential campaign. ⁸

Internal communications leaked by WikiLeaks reveal an email written by Clinton press Secretary Nick Merrill, in which he discusses using Correct the Record (CtR) and Media Matters for America (MMFA) to push against a Vanity Fair article criticizing Clinton vice chair Huma Abedin. ⁹ The email read, “We have MMFA, CtR, and core surrogates lined up, which we can expand on tomorrow…” and Media Matters published its own article criticizing Vanity Fair’s piece shortly afterward. ^{10 11}

Out of the $8.5 million Correct the Record received in donations during the 2016 election cycle, around $275,615 came from pro-Clinton organization Hillary for America. ¹² A 2015 Washington Post report stated, “Correct the Record believes it can avoid the coordination ban by relying on a 2006 Federal Election Commission regulation that declared that content posted online for free, such as blogs, is off limits from regulation.” ¹³

It continued, “The ‘Internet exemption’ said that such free postings do not constitute campaign expenditures, allowing independent groups to consult with candidates about the content they post on their sites.” ¹⁴ However, the original April complaint issued by Patriots Foundation disputes this interpretation, as “the PAC spent money on polling and other activities that don’t constitute communications.” ¹⁵

Criticism

Internet Trolling

Correct the Record engaged in badgering and harassment of online critics of Hillary Clinton’s candidacy. The organization committed to spend $1 million on Facebook, Twitter, Reddit, and Instagram, putting at least some of the funds towards trolling Clinton critics on social media. As Dan Gillmor, a professor of media literacy at Arizona State University put it, it was hard for paid political operatives to win a trolling war against people who didn’t need to be paid to troll. ¹⁶

“Money for Dirt”

In September 2016, Brock and Correct the Record offered money for dirt on Donald Trump. Brock told NBC News “we’re chasing everything” including his tax returns, internal documents from Trump’s businesses, or evidence of personal misconduct. There was no cap on money that the organization was willing to pay. Paying for dirt on political opponents is an unusual practice in American politics, but is more common overseas. The American media also generally does not pay sources for information.¹⁷

1. Sink, Justin. 2013. “Super-PAC With Hillary Ties Announces ‘Correct The Record’ Effort”. Thehill. http://thehill.com/blogs/ballot-box/campaign-ads/188979-super-pac-with-hillary-ties-announces-correct-the-record-effort.
2. Perez, Andrew. 2016. “Hacked Clinton Campaign Memo Lays Out Legal Basis For Coordinating With Super PAC”. Maplight.Org. https://maplight.org/story/hacked-clinton-campaign-memo-lays-out-legal-basis-for-coordinating-with-super-pac/.
3. Perez, Andrew. 2016. “Hacked Clinton Campaign Memo Lays Out Legal Basis For Coordinating With Super PAC”. Maplight.Org. https://maplight.org/story/hacked-clinton-campaign-memo-lays-out-legal-basis-for-coordinating-with-super-pac/.
4. Perez, Andrew. 2016. “Hacked Clinton Campaign Memo Lays Out Legal Basis For Coordinating With Super PAC”. Maplight.Org. https://maplight.org/story/hacked-clinton-campaign-memo-lays-out-legal-basis-for-coordinating-with-super-pac/.
5. Zuvich, Cady. 2016. “How A Pro-Hillary Clinton Super PAC Got An Ad On TV For Free”. Time. http://time.com/4328093/correct-record-clinton-super-pac-ad-web-video-broadcast/.
6. Kerr, Andrew. “Conservative Group Sues FEC For Failing To Act On Allegations Against Media Matters.” The Daily Caller. August 14, 2020. https://dailycaller.com/2020/08/14/conservative-group-fec-lawsuit-media-matters-patriots-foundation-david-brock/
7. Wulfsohn, Joseph A. “FEC sued over inaction on claim against Clinton ally David Brock’s organizations.” Fox News. August 15, 2020. https://www.foxnews.com/media/fec-sued-david-brock-media-matters-complaint
8. Hemingway, Mark. “Did Media Matters shill so hard for Hillary that it broke the law.” The Federalist. August 17, 2020. https://thefederalist.com/2020/08/17/did-media-matters-shill-so-hard-for-hillary-that-it-broke-the-law/
9. Hemingway, Mark. “Did Media Matters shill so hard for Hillary that it broke the law.” The Federalist. August 17, 2020. https://thefederalist.com/2020/08/17/did-media-matters-shill-so-hard-for-hillary-that-it-broke-the-law/
10. Hemingway, Mark. “Did Media Matters shill so hard for Hillary that it broke the law.” The Federalist. August 17, 2020. https://thefederalist.com/2020/08/17/did-media-matters-shill-so-hard-for-hillary-that-it-broke-the-law/
11. Suenn, Brennan. “Vanity Fair’s Huma Abedin Hit Piece By The Numbers.” Media Matters for America. January 6, 2020. https://www.mediamatters.org/hillary-clinton/vanity-fairs-huma-abedin-hit-piece-numbers
12. Hemingway, Mark. “Did Media Matters shill so hard for Hillary that it broke the law.” The Federalist. August 17, 2020. https://thefederalist.com/2020/08/17/did-media-matters-shill-so-hard-for-hillary-that-it-broke-the-law/
13. Gold, Matea. “How a super PAC plans to coordinate directly with Hillary Clinton’s campaign.” The Washington Post. May 12, 2015. https://www.washingtonpost.com/news/post-politics/wp/2015/05/12/how-a-super-pac-plans-to-coordinate-directly-with-hillary-clintons-campaign/
14. Gold, Matea. “How a super PAC plans to coordinate directly with Hillary Clinton’s campaign.” The Washington Post. May 12, 2015. https://www.washingtonpost.com/news/post-politics/wp/2015/05/12/how-a-super-pac-plans-to-coordinate-directly-with-hillary-clintons-campaign/
15. Hemingway, Mark. “Did Media Matters shill so hard for Hillary that it broke the law.” The Federalist. August 17, 2020. https://thefederalist.com/2020/08/17/did-media-matters-shill-so-hard-for-hillary-that-it-broke-the-law/
16. Halper, Evan. 2016. “Be Nice To Hillary Clinton Online — Or Risk A Confrontation With Her Super PAC”. Latimes.Com. http://www.latimes.com/politics/la-na-clinton-digital-trolling-20160506-snap-htmlstory.html.
17. Seitz-Wald, Alex. 2016. “Democratic Super PAC To Pay For Dirt On Trump”. NBC News. https://www.nbcnews.com/politics/2016-election/democratic-super-pac-pay-trump-dirt-n648591.