DISCUSSION
THE TRUMP CAMPAIGN FUNDRAISING TEAM
As detailed below, the Trump Campaign misled the American public and President Trump's donors on how they planned to use, and did use, the donated funds while bombarding supporters with hundreds of emails, as many as twenty-five emails per day, stating the election had been stolen. In those emails, they used inflammatory language accusing Democrats of trying to "steal the election," encouraged supporters to join the "Trump army"; "Defend" the election: and to "fight back" over, and over, and over again.[1] They sent these emails out because they knew they were effective at raising money.[2] This was made possible by the creation of a fundraising machine powered jointly by the Trump Campaign and the RNC.
A. The TMAGAC Fundraising Machine
During the 2020 election cycle, President Trump operated a structure under which the Trump reelection campaign and the RNC merged programs and raised money jointly through the Trump Make America Great Again Committee (internally referred to by its acronym TMAGAC, which RNC officials pronounced "T-Magic").[3] TMAGAC was focused on raising money online through small-dollar donations.[4] Tim Murtaugh, the Trump Campaign's communications director, described the TMAGAC fundraising operation as "an entity unto itself within the campaign."[5]
The individual charged with leading the digital operation in 2020 was Gary Coby.[6] Coby first started working with the RNC in 2016 even before President Trump became the nominee.[7] Coby explained that, as digital director, his role during the 2020 Presidential election cycle was to "oversee the digital operation."[8] Similarly, senior staffers at the Trump Campaign and the RNC all made clear that Coby was the individual in charge of the TMAGAC digital team.[9] Both high-level staffers at the Trump Campaign and at the RNC confirmed that Coby had the trust of Jared Kushner, the President's son-in-law.[10]
Coby explained that during the 2020 Presidential election cycle, the TMAGAC digital team was a "big team with multiple organizations and vendor teams all working together as one, that include[d] RNC staff, [Donald J. Trump for President] staff, [and] maybe a half dozen vendor teams."[11] The RNC digital team, a subset of the TMAGAC digital team, was led operationally by Kevin Zambrano, Chief Digital Officer at the RNC. In 2020, members of the digital staff of both the RNC and Trump Campaign merged in an office building in Arlington, Virginia, with some suites jointly hosting RNC and Trump Campaign staff on the digital team, and other suites hosting third-party companies, such as Opn Sesame and Direct Persuasion.[12] Thereafter, Zambrano assisted Coby in managing the TMAGAC
