21 and political committees to raise funds from a greater number of persons.’” Id. at 136 (quoting Buckley, 424 U.S. at 21–22). Unlike strict scrutiny, which requires narrow tailoring to serve compelling governmental interests, a contribution limit is “valid [if] it satisfies the lesser demand of being closely drawn to match a sufficiently important interest.” Id. After McConnell, allocation and solicitation rules are subject only to this lesser scrutiny. Facing BCRA § 323(a), which forbids national parties from soliciting and spending soft money, and § 323(b), which forbids state parties from spending soft money on “federal election activities,” the Court declined to apply strict scrutiny. 540 U.S. at 138–39. The Court held “neither provision in any way limits the total amount of money parties can spend. Rather, they simply limit the source and individual amount of donations. That they do so by prohibiting the spending of soft money does not render them expenditure limitations.” Id. at 139. We instead ask “whether the mechanism adopted to implement the contribution limit, or to prevent circumvention of that limit, burdens speech in a way that a direct restriction on the contribution itself would not.” Id. at 138–39. Using the Court’s standard, I agree with the district court that while the FEC’s regulations “may affect the manner in which EMILY’s List must fund the speech in which it chooses to engage, they do not in any way limit the political speech that EMILY’s List may undertake.” EMILY’s List, 569 F. Supp. 2d at 39. The issue we confront then is whether these regulations, facially, are closely drawn to match an important interest. To answer, we again ought to look to McConnell. In upholding BCRA § 323, the Court noted the “interests that underlie contribution limits—interests in preventing both the actual corruption threatened by large financial contributions and the eroding of public confidence in the electoral process through

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