Rick HasenVerified account

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.

Broad definition of contribution, thing of value, and solicit consistent with stated congressional purpose against foreign interference

Narrow definitions consistent with the rule of lenity and recent Supreme Court caselaw construing criminal statutes narrowly. McDonnell, etc

but inconsistent with repeated clear and broad purpose of Congress to guard against foreign interference in US elections