<P> It took another decision, by the U.S. Court of Appeals for the District of Columbia Circuit, Speechnow.org v. Federal Election Commission, to actually authorize the creation of super PACs . While Citizens United held that corporations and unions could make independent expenditures, a separate provision of the Federal Election Campaign Act, at least as long interpreted by the Federal Election Commission, held that individuals could not contribute to a common fund without it becoming a PAC . PACs, in turn, were not allowed to accept corporate or union contributions of any size or to accept individual contributions in excess of $5,000 . In Speechnow.org, the D.C. Circuit, sitting en banc, held 9--0 that in light of Citizens United, such restrictions on the sources and size of contributions could not apply to an organization that made only independent expenditures in support of or opposition to a candidate but not contributions to a candidate's campaign . </P> <P> Citizens United and SpeechNOW left their imprint on the 2012 United States presidential election, in which single individuals contributed large sums to "super PACs" supporting particular candidates . Sheldon Adelson, the gambling entrepreneur, gave approximately fifteen million dollars to support Newt Gingrich . Foster Friess, a Wyoming financier, donated almost two million dollars to Rick Santorum's super PAC . Karl Rove organized super PACs that spent over $300 million in support of Republicans during the 2012 elections . </P> <P> In addition to indirectly providing support for the creation of super PACs, Citizens United allowed incorporated 501 (c) (4) public advocacy groups (such as the National Rifle Association, the Sierra Club, and the group Citizens United itself) and trade associations to make expenditures in political races . Such groups may not, under the tax code, have a primary purpose of engaging in electoral advocacy . These organizations must disclose their expenditures, but unlike super PACs they do not have to include the names of their donors in their FEC filings . A number of partisan organizations such as Karl Rove's influential conservative Crossroads Grassroots Policy Strategies and the liberal 21st Century Colorado have since registered as tax - exempt 501 (c) (4) groups (defined as groups promoting "social welfare") and engaged in substantial political spending . This has led to claims of large secret donations, and questions about whether such groups should be required to disclose their donors . Historically, such non-profits have not been required to disclose their donors or names of members . See National Association for the Advancement of Colored People v. Alabama . </P> <P> In an August 2015 essay in Der Spiegel, Markus Feldkirchen wrote that the Citizens United decision was "now becoming visible for the first time" in federal elections as the super-rich have "radically" increased donations to support their candidates and positions via super PACs . Feldkirchen also said in the first six months of 2015 the candidates and their super PACs received close to $400 million: "far more than in the entire previous campaign ." He opined that super-rich donating more than ever before to individual campaigns plus the "enormous" chasm in wealth has given the super-rich the power to steer the economic and political direction of the United States and undermine its democracy . In October 2015, The New York Times observed that just 158 super-rich families each contributed $250,000 or more, while an additional 200 families gave more than $100,000 for the 2016 presidential election . Both groups contributed almost half of the "early money" for candidates in the 2016 presidential election as of June 30, 2015 through channels like super PACs legalized by the Supreme Court's Citizens United decision . </P>

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