9 In maintaining this line between (i) contributions to candidates or parties and (ii) expenditures, the Court has acknowledged that a citizen’s or group’s large expenditure – for example, in financing advertisements or get-out-the-vote activities – may confer some benefit on a candidate and thereby give influence to the spender. But the Court nonetheless has consistently dismissed the notion that expenditures implicate the anti-corruption interest. See Buckley, 424 U.S. at 47 (expenditures not “a quid pro quo for improper commitments from the candidate”); see also McConnell, 540 U.S. at 153 (“mere political favoritism or opportunity for influence alone is insufficient to justify regulation”); id. at 156-57 n.51 (Congress could not regulate talk show hosts or newspaper editors “on the sole basis that their activities conferred a benefit on the candidate”); NCPAC, 470 U.S. at 498 (“exchange of political favors for uncoordinated expenditures remains a hypothetical possibility and nothing more”). Fifth, the Court has been somewhat more tolerant of regulation of for-profit corporations and labor unions. The Court has permitted statutory limits on contributions that forprofit corporations and unions make from their general treasuries to candidates and parties.5 More controversially, the Court has carved out a significant exception to Buckley’s holding on expenditures: The Court has upheld laws that prohibit for-profit corporations and unions from making expenditures for activities expressly advocating the election campaign finance statutes, this Court has repeatedly adhered to Buckley’s constraints, including those on expenditure limits.”). 5 The Court also has ruled that the Government may bar certain non-profit as well as for-profit corporations from making direct contributions to candidates or parties. See FEC v. Beaumont, 539 U.S. 146, 159-60 (2003).