BEFORE THE FEDERAL ELECTION COMMISSION
IN THE MATTER OF:
Michael Moore, :
Lions Gate Entertainment Corp., :
Cablevision Systems Corporation, :
Rainbow Media Holdings LLC, :
The Independent Film Channel LLC, :
Fellowship Adventure Group, : MUR NO. ______________
Harvey Weinstein, :
Bob Weinstein, :
Showtime Network, Inc., and :
Viacom International Inc., :
:
RESPONDENTS. :
____________________________________:
COMPLAINT
Pursuant to 11 CFR § 111.4, the undersigned hereby files this Complaint with the Federal Election Commission (“Commission”), alleging as follows:
SUMMARY OF ALLEGATIONS
On information and belief, the undersigned alleges that planned advertising for the film FAHRENHEIT 9/11 violates the Federal Election Campaign Act (“FECA”). More specifically, the Complaint alleges that broadcast advertisements for the film, which include visual images and sound clips of President George W. Bush and other candidates for Federal elective office, qualify as “electioneering communications” under FECA if they are broadcast within 30 days prior to the Republican National Convention or 60 days prior to the general election. The undersigned contends that Respondents are about to violate the Act because the Ads will be funded by corporate and foreign money; expenditures for the ads will not be reported to the Federal Election Commission; and the ads will not include the required disclosure statements.
The named Respondents in the Complaint include: Michael Moore, Lions Gate Entertainment Corp., Cablevision Systems Corporation, Rainbow Media Holdings LLC, The Independent Film Channel LLC, Fellowship Adventure Group, Harvey Weinstein, Bob Weinstein, Showtime Network, Inc. and Viacom International Inc
RELEVANT STATUTES & REGULATIONS
FECA defines an “electioneering communication” to include “any broadcast, cable or satellite communication which-
(I) refers to a clearly identified candidate for Federal office;
(II) is made within-
(aa) 60 days before a general, special, or runoff election for the office sought by the candidate; or
(bb) 30 days before a primary or preference election, or a convention or caucus of a political party that has authority to nominate a candidate, for the office sought by the candidate; and
(III) in the case of a communication which refers to a candidate for an office other than President or Vice President, is targeted to the relevant electorate.
SNIP.....
Complaint Against Michael Moore..........