August 9, 2024
Federal Election Commission
Attn: Office of Complaints, Examination, and Legal Administration
1050 First Street, NE
Washington, DC 20463
Re: Complaint against Kamala Harris, et al.; Supplemental Information
Dear Sir or Madam:
I write to follow up on the robust complaint filed by Citizens United and 17 state and territorial
party committees on July 25, 2024, against Kamala Harris, Harris for President, and Keana Spencer, in
her official capacity as Treasurer. I wish to bring to the attention of the Federal Election Commission
(“FEC” or “Commission”) additional issues with Ms. Harris’s FEC filings, which I have identified since
filing Citizens United’s original complaint.
Specifically, when Ms. Harris filed her Statement of Candidacy (FEC Form 2) on July 21, 2024,
declaring that she was now running for President, she used the FEC Candidate ID Number of Joe Biden
instead of her own Candidate ID Number. This extraordinarily irregular and improper act suggests that
Ms. Harris or her attorneys recognized there was a fundamental problem with one candidate simply
assuming the campaign funds and assets of another candidate. Instead, they invented a preposterous
fiction in which Kamala Harris has become one and the same person as Joe Biden. Of course, this
pathetic ploy is ludicrous on its face and cannot in any way justify Ms. Harris’s illegal seizure of the Biden
for President campaign for her own separate candidacy.
First, P80000722 is the FEC Candidate ID that Joseph R. Biden has used continuously as a
Presidential candidate ever since his first failed candidacy for President in 1988, his second failed
candidacy for President in 2008, and his subsequent candidacies in 2020 and 2024:1
1
See https://www.fec.gov/data/candidate/P80000722/?cycle=2024&election_full=true&tab=about-
candidate (last visited Aug. 9, 2024).
1
Second, P00009423 is the FEC Candidate ID that Kamala Harris used for her failed candidacy for
President in 2020:2
2
See https://www.fec.gov/data/candidate/P00009423/?tab=about-candidate (last visited Aug. 9,
2024).
2
The FEC’s Form 2 instructions3 make it clear that, for Line 2, “candidates who have terminated a
previous candidacy but are now running again for the same seat [i.e., office], should use their original
identification number.” And, as the FEC records highlighted above reflect, that is precisely what Joe
Biden did for his 1988, 2008, 2020, and 2024 bids for the White House.
However, when Kamala Harris brazenly and illegally seized control of the Biden for President
campaign funds and assets on July 21, 2024, and declared that she was now running for President, she
entered in not her own FEC Candidate ID, but the FEC Candidate ID of Joe Biden—P80000722—on her
FEC Statement of Candidacy:4
Of course, two separate individuals or candidates for President may not share the same FEC
Candidate ID, just as they may not share the same campaign committee. Kamala Harris is not Joe Biden.
Yet, Biden is exactly whom Harris purported to be on the FEC Form 2 that she filed on July 21, 2024.
Why use Biden’s FEC Candidate ID instead of her own FEC Candidate ID, as the FEC’s instructions
direct her to do? The most likely reason is that even Harris or her attorneys recognized that she did not
have any rightful claim to Biden for President as her own campaign committee prior to her and Joe
Biden having been nominated by their party to be the candidates for Vice President and President,
respectively (as explained in our initial complaint). Therefore, they created this fiction in which Harris
and Biden are one and the same person and candidate, having the same FEC Candidate ID, so that the
3
https://www.fec.gov/resources/cms-content/documents/policy-guidance/fecfrm2i.pdf (last visited
Aug. 9, 2024).
4
https://docquery.fec.gov/pdf/303/202407219665705303/202407219665705303.pdf (last visited
Aug. 9, 2024).
3
same “candidate” could continue using the campaign funds and assets of Biden for President when
Biden announced he was going to “stand down” on July 21, 2024.
The Commission should reject this preposterous fiction, which has no basis in reality or the law.
Rather than support Harris’s legal position that she is entitled to assume the campaign funds and assets
of Biden for President, this sleight of hand with the FEC Candidate ID simply further underscores how
the entire maneuver was blatantly illegal.
The Commission should immediately find “reason to believe” in this matter forthwith, take all
appropriate actions to stop Kamala Harris from using her ill-gotten gains, and hold accountable all
parties involved in this troubling and gross violation of our nation’s campaign finance laws.
Sincerely,
David N. Bossie
Chairman and President
Citizens United
