40 Relatedly, the concurrence disputes our reading of CalMed. See Concurring Op. at 24. But our analysis of that case, including our reliance on Justice Blackmun’s opinion, tracks the persuasive reasoning of the Fourth Circuit in North Carolina Right to Life, of several other courts, and of numerous commentators. See, e.g., N.C. Right to Life, 525 F.3d at 292; see also, e.g., Comm. on Jobs Candidate Advocacy Fund v. Herrera, No. C 07-03199, 2007 WL 2790351, *4 (N.D. Cal. Sept. 20, 2007); Wash. State Republican Party v. Wash. State Pub. Disclosure Comm’n, 4 P.3d 808, 825 (Wash. 2000); Richard Briffault, The 527 Problem and the Buckley Problem, 73 GEO. WASH. L. REV. 949, 982-85 (2005); John C. Eastman, Strictly Scrutinizing Campaign Finance Restrictions (and the Courts that Judge Them), 50 CATH. U. L. REV. 13, 37 (2000); Gregg D. Polsky & Guy-Uriel E. Charles, Regulating Section 527 Organizations, 73 GEO. WASH. L. REV. 1000, 1031 (2005). Moreover, the concurrence does not substantively address the several post-Cal-Med cases that similarly recognize the right of non-profits to raise and spend money to support their agendas and preferred candidates. See, e.g., FEC v. Mass. Citizens for Life, Inc. (MCFL), 479 U.S. 238, 259-65 (1986); FEC v. Nat’l Conservative PAC (NCPAC), 470 U.S. 480, 501 (1985); Citizens Against Rent Control v. City of Berkeley, 454 U.S. 290, 296-99 (1981). The concurrence further contends that we have not received on-point briefing on the constitutional issue. We again respectfully disagree. The briefs and oral argument focused first and most extensively on the First Amendment and McConnell – and debated the key question in this case: For First Amendment purposes, are non-profits more like individual citizens (who under Buckley have the right to spend unlimited money to support their preferred candidates) or more like political parties (which under McConnell do not)?