16 the sole basis for regulating campaign contributions and expenditures. See Davis, 128 S. Ct. at 2773. As the Court has explained the anti-corruption principle, mere donations to non-profit groups cannot corrupt candidates and officeholders. In the words of the Fourth Circuit, it is “implausible that contributions to independent expenditure political committees are corrupting.” N.C. Right to Life, 525 F.3d at 293 (internal quotation marks omitted). And to the extent a non-profit then spends its donations on activities such as advertisements, get-out-the-vote efforts, and voter registration drives, those expenditures are not considered corrupting, even though they may generate gratitude from and influence with officeholders and candidates. Rather, under Buckley, those expenditures are constitutionally protected. Therefore, limiting donations to and spending by non-profits in order to prevent corruption of candidates and officeholders represents a kind of “prophylaxis-upon-prophylaxis” regulation to which the Supreme Court has emphatically stated, “Enough is enough.” FEC v. Wis. Right to Life, Inc. (WRTL), 551 U.S. 449, 478-79 (2007) (controlling opinion of Roberts, C.J.). Writing for the Fourth Circuit, Judge Wilkinson recently summarized the relevant Supreme Court precedents, concluding that “the Court has never held that it is constitutional to apply contribution limits to political committees that make solely independent expenditures.” N.C. Right to Life, 525 F.3d at 292. Those non-profit groups receive full First Amendment protection and are entitled to receive donations and make expenditures because they “offer an opportunity for ordinary citizens to band together to speak on the issue or issues most important to them.” Id. at 295. We agree with Judge Wilkinson’s assessment of the state of the law.