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Despite Pledge, Americans Elect takes Special Interest Money from Chair of Promotion Marketing Association

“None of our funding comes from special interests or lobbyists.” — Americans Elect, July 2011

Special Interest. Noun. an individual, group, or corporation having a special interest in usually a particular part of the economy and receiving or seeking through political pressure special advantages from the government often to the detriment of the general welfare — usually used in plural — Merriam Webster Third New International Dictionary

Americans Elect is a corporation that has already obtained a 2012 presidential ballot line in states across the country. Like it or not, the Americans Elect corporate candidate for president will play a role in the presidential election next year.

Americans Elect has gained its ballot access thanks to an army of paid signature gatherers. Americans Elect owes a debt of gratitude to its funders for making its presidential ballot access possible.

Who are those funders? We largely don’t know, because after funneling $1.55 million of his own fortune into Americans Elect, Chair Peter Ackerman reclassified the enterprise as a 501c4 corporation, making its contributions and expenditures a secret. Thanks to the Citizens United supreme court ruling, Americans Elect has no legal obligation to disclose its source of funds. Despite requests, Americans Elect has refused to publish a list of the names of all the people who are propping up the presidential bid.

However, this week information about the sources of Americans Elect’s cash opened up a bit. The corporation’s campaign contribution collector, Piryx, quietly posted an incomplete list of those people who have given money to Americans Elect and have agreed to share their identity on Piryx’s “giving stream.” It’s an incomplete list, missing the names of people who wish to remain anonymous, but it’s good enough to test Americans Elect’s “no special interest money” pledge. If we can find any special interests in the Piryx “giving stream,” then Americans Elect’s claim will be debunked.

We’ve already found two special interest sources of money to Americans Elect:

1. $1.55 million contribution by Peter Ackerman, who is not only Chairman of Americans Elect but also a private wealth investor, a corporate takeover player, part owner of grocery corporation Fresh Direct, and owner in control of the marketing firm Emak Worldwide.

2. An undisclosed amount contributed by hedge fund operator Kirk Rostron.

This morning, we add a third special interest contributor to Americans Elect.

3. Jim Holbrook, who as CEO of the marketing firms Emak Worldwide, Neighbor and Upshot has special interests in the advancement of the marketing industry. More than this, though, Jim Holbrook is Chairman of the Promotion Marketing Association, a trade organization for the $750 Billion industry. The website of the Promotion Marketing Association makes it clear that it has special interests and is dedicated to pursuing those special interests in the spheres of American law and government. It has an entire section devoted to “Legal and Governmental Affairs”, with a publication entitled “PMA Legal Watch,” a “PMA International Law Book,” and an annual Marketing Law Conference. The PMA Bylaws stipulate explicitly that it is an organization dedicating to pursuing the interests of the promotion marketing industry:

The corporation is organized and shall be operated exclusively as the premier trade association for the principal purpose of advancing the interests, addressing the needs, and serving as the preeminent knowledge source for those companies and individuals that have a professional interest in and/or utilize integrated and promotion marketing, and assisting them in better serving the interests of their customers and/or consumers, including by achieving specific, measurable, brand-building goals.

The key elements of this mission are… d. To promote and protect the interests of those who use integrated and promotion marketing techniques; e. To monitor, communicate and encourage an understanding of the laws and regulations that apply to the use of integrated and promotional marketing techniques; … g. To cooperate with federal, state and local government authorities for the good of the consumer, the community and the integrated marketing industry;

… Section 7 – No member shall engage in any conduct that is prejudicial to the best interest of this Association…

Jim Holbrook may be a very nice person, but his multiple positions as a corporate leader and advocate in the marketing industry mark him as a representative of a special interest. If his contribution doesn’t qualify as a special interest source, it’s hard to imagine what would.

Americans Elect says it welcomes citizens’ questions. I am sending a question regarding this contribution to Americans Elect through its online form and through the e-mail address The question reads:

“Jim Holbrook is the CEO of three marketing corporations: Emak Worldwide, Upshot and Neighbor. He is also the Chairman of the Promotion Marketing Association, which describes itself explicitly as an interest advocacy trade group. Americans Elect has pledged that ‘None of our funding comes from special interests.’ If Americans Elect agrees that Jim Holbrook’s contribution is a special interest source, when will it return the contribution? If Americans Elect disagrees that Jim Holbrook’s contribution is a special interest source, then what is Americans Elect’s definition of ‘special interest’?”

If I receive a reply, I will post it here in the comments section. If you do not see notice of a reply from Americans Elect, it means that Americans Elect has not replied to my question.

10 thoughts on “Despite Pledge, Americans Elect takes Special Interest Money from Chair of Promotion Marketing Association”

  1. Tom says:

    i couldn’t care less about these shits. You wanna see something interesting? Check this out:

  2. Jay says:

    You forgot to mention that Mr. Rostron also founded a non-profit whose sole mission is to provide educational funding for children of fallen servicemen/women. Or that he also sits on the Board of Trustees of Florida State University. It looks like he gives both time and money to many causes, and not necessarily with a special interest agenda.

    I don’t personally agree with Kirk’s politics though I like him on a personal level. If there is a biased special interest bend to Americans Elect, it’s likely from the founding contributor. I hardly think it’s likely to come from someone who is willing to disclose his support.

    1. Jim Cook says:

      I also didn’t disclose Kirk Rostron’s address or favorite sports, although I ran across those too. They’re not part of the information relevant to the question at hand, which is whether in his profession Kirk Rostron represents a special interest, and it’s pretty clear by the standard definition of the term that he does (as does Jim Holbrook, the subject of this particular article). A person can be nice in many ways and also represent a special interest.

  3. Gordon says:

    Regarding this definition of Special Interest:

    1. Is there any US citizen who does NOT have a special interest in at least one particular part of the US economy?

    2. Does donating money to Americans Elect = “receiving or seeking through political pressure special advantages from the government”?

    3. If the answers to 1. and 2. are “No” and “Yes” respectively, what donor to Americans Elect would NOT occur for you as a violation?

    1. Jim Cook says:


      Those are really interesting questions.

      I would keep in mind that Americans Elect, not me, raised the issue of “special interests” by declaring itself to be free of them. So first of all, those are questions to pose to Americans Elect.

      1. I’m not sure at the philosophical level; I’d have to think about that question more. But I think it is fair to say that there are citizens who have smaller interests versus larger interests, and that there are citizens who have more widely diffused interests versus more concentrated interests. The gentleman in question in this article has both larger and more concentrated interests than is typical. It’s like how everybody has height and weight, but Andre the Giant has a lot of both of them.

      2. If Americans Elect is attempting to run a candidate to obtain desired policy outcomes, then possibly, yes. To the extent that Americans Elect has designed the process to allow its corporate board to steer the nomination, and to the extent that Americans Elect is not being forthcoming about sharing information about itself, this is an area of concern.

      3. n/a.

      1. Gordon says:

        Thanks. I like the Andre the Giant example (I’m going to steal it).

        Then, is it fair to say that any individual who has an atypically large and concentrated interest in the US economy, and who donates to Americans Elect, would occur for you as a violation of AE’s “No Special Interest Money” pledge?

        If so, what is the lower bound for both size and concentration? Is it one of those “I know it when I see it” kind of things?

        1. Jim Cook says:

          1. I think that’s a fair question to ask Americans Elect, since Americans Elect is setting the standard for itself. Have you asked Americans Elect about their special interest policy as it applies to these individuals? Have they answered? (I have, and they haven’t.)

          2. I think disclosure of the size of contributions made by individuals (and the names of those individuals) to political campaigns is essential for the public to establish how significantly those individuals are vested in those political campaigns.

          3. I think the location of the lower bound of size and concentration is a fair subject for debate.

          4. I think that “Representing $750 billion in sales” leaps well across that lower bound of size, and that being the Chair of the Promotion Marketing Association leaps well across that lower bound of concentration of interest.

  4. Hendrix says:

    Might I suggest that AE is much more successful at collecting contact and demographic info than at putting people in positions of political power to grant favors. That contact info is indispensable to marketing companies. These partnerships allow AE to share the valuable info they collect without explicitly selling it. Thus keeping to their privacy policy which states, “We do not sell your personal information to third parties. We may share your personal information with third parties for a variety of reasons.”

    1. Jim Cook says:

      Well, that puts the Conflict of Interest Policy (in which Americans Elect leaders have a conflict of interest if the Americans Elect leaders decide they do) in an interesting perspective.

  5. Gordon says:

    I get that the actual size and concentration of an individual’s interest which is sufficient to trigger the 1st half of the definition (“a special interest in usually a particular part of the economy”) is not specified, but that whatever it is, you believe Holbrook safely exceeds it.

    I would prefer to see the 2nd half of the definition (“receiving or seeking through political pressure special advantages from the government”) fulfilled by some action by the subject other than donating to Americans Elect.

    I sense there is something logically or rhetorically amiss, in using the act of donating to Americans Elect as part of the proof that one is a member of group from which Americans Elect has pledged not to receive donations.

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