Rick HasenVerified account

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

It is not a legal brief, it is an FEC general counsel report approved by the commissioners

I'll take a look, but I'm not sure why this would have the force of law in a felony criminal conspiracy case. Dubious Chevron applies.

there is analogous discussion of thing of value in bribery cases, e.g., U.S. v. Senator Menendez case I link to in Slate piece

I don't know how many times I can say I am not disputing the interpretation of thing of value. I think I will add it to my Twitter bio.