3 Otherwise, the word “purpose” becomes superfluous, a result that this court cannot accept, e.g., Reiter v. Sonotone Corp., 442 U.S. 330, 339 (1979), especially for a jurisdictional provision like this one, see, e.g., N. Am. Van Lines, Inc. v. NLRB, 869 F.2d 596, 598 (D.C. Cir. 1989). Under FECA, federal effects are simply not enough.2 Nor does labeling spending that may affect both state and federal elections as “mixed-purpose” somehow solve the FEC’s problem. Regulating on the basis of such a label still assumes there must be a federal purpose behind any spending that might influence, even tangentially, a federal campaign. Because that necessary assumption is false, these regulations remain invalid. Only after a federal purpose—mixed or otherwise—is identified does the FEC’s power come into play. If a federal purpose can be shown, then allocation ratios like those promulgated here may well be appropriate under FECA, but just asserting that there must be a federal purpose skips the threshold jurisdictional question.3 2 Cf. 42 U.S.C. § 1973c (under the Voting Rights Act, certain jurisdictions cannot alter their voting procedures without showing the change “neither has the purpose nor will have the effect of denying or abridging the right to vote on account of race or color” (emphasis added)). 3 It is also no defense to say that under Buckley v. Valeo, 424 U.S. 1 (1976), everything political committees do reflects federal purposes. See EMILY’s List v. FEC, 569 F. Supp. 2d 18, 44 (D.D.C. 2008) (“EMILY’s List is undoubtedly correct that its status as a political committee does not automatically give the FEC authority to regulate its legitimately nonfederal election activities.”). In Buckley, the Court explained “[e]xpenditures of . . . ‘political committees’ . . . can be assumed to fall within the core area sought to be addressed by Congress.” 424 U.S. at 79. This “assum[ption],” however, is rebutted when it is unreasonable to posit a federal purpose. See Akins v. FEC, 101 F.3d 731, 742 (D.C.

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