22 Profit Groups in Federal Elections, 31 N. KY. L. REV. 243, 280 (2004) (“Today’s electioneering non-profit groups . . . can make no such promises of access in exchange for a soft money contribution.”). More fundamentally, non-profit groups do not have the same inherent relationship with federal candidates and officeholders that political parties do. The McConnell Court identified numerous “real-world differences between political parties and interest groups.” 540 U.S. at 188. “Interest groups do not select slates of candidates for elections. Interest groups do not determine who will serve on legislative committees, elect congressional leadership, or organize legislative caucuses. Political parties have influence and power in the Legislature that vastly exceeds that of any interest group. As a result, it is hardly surprising that party affiliation is the primary way by which voters identify candidates, or that parties in turn have special access to and relationships with federal officeholders.” Id. As noted in McConnell, Congress recognized these differences and enacted a statutory scheme under which “[i]nterest groups . . . remain free to raise soft money to fund voter registration, GOTV activities, mailings,” and advertising. Id. at 187. In sum, it will not work to simply transport McConnell’s holding from the political party context to the non-profit setting. On this question as well, we agree with Judge Wilkinson: “It is . . . not an exaggeration to say that McConnell views political parties as different in kind than independent expenditure committees.” N.C. Right to Life, 525 F.3d at 293. For non-profit entities, the most pertinent Supreme Court precedents remain Buckley, Cal-Med, Citizens Against Rent Control, NCPAC, and MCFL. As discussed above, those

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