Rick HasenVerified account

2/ and specific kind of contribution or donation is in the form of money or a thing of value.

we must be talking past each other.

Can you cite to the text that defines a contribution or donation as a thing of value in the abstract? That would help.

I think we agree the key phrase is this: "a contribution or donation of money or other thing of value." I read that as having two parts:

First, a contribution or donation. Second, a specific kind of contribution or donation: one of money or another thing of value.

giving opposition research to a campaign, for example, has been found to be an in-kind contribution to campaign http://eqs.fec.gov/eqsdocsMUR/28044192498.pdf …

Looks like 103-page legal brief. Where was the holding, ideally by a court and not an agency (as Chevron here is quite iffy).

See, for example, page 85. On this point, I believe FEC commissioners were unanimous. Other examples linked in slate piece