RNC (Cao) v. FEC: Defendant's brief in opposition to the RNC’s motion for summary judgment

Defendant Federal Election Commission submits reply memorandum in support of its motion for summary judgment. Plaintiffs’ opposition essentially relies on two arguments: (1) “[T]he relevant issue [in this case] is the nature of Plaintiffs’ intended First Amendment activities”; and (2) those activities “are too far removed from federal elections and campaigns to be regulated.” (See Pls.’ Mem. in Opp. to Def. FEC’s Mot. for S.J. (“Pls.’ S.J. Opp.”) at 3.) FEC argues that each of these arguments is contrary to law and unsupported by the factual record and so requests that the Court grant summary judgment to the Commission.