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20 - ORGANIZATIONS/PRIVATE/Cambridge Analytica.md
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@ -70,25 +70,25 @@ relations:
start: 2016-07-29
end: 2016-12-12
role: "data management vendor, 5,912,500 dollars"
fn: 21
fn: 24
- type: contractor_to
with: "[[Cruz for President]]"
start: 2015-07-02
end: 2016-06-09
role: "vendor, 5,805,552.23 dollars in itemized disbursements"
fn: 19
fn: 22
- type: contractor_to
with: "[[John Bolton Super PAC]]"
start: 2014-07-07
end: 2016-09-29
role: "research and survey research vendor, 1,152,300 dollars"
fn: 19
fn: 22
- type: contractor_to
with: "[[Make America Number 1]]"
start: 2015-12-10
end: 2016-12-07
role: "media, survey research and consulting vendor, 1,476,484 dollars"
fn: 25
fn: 28
- type: contractor_to
with: "[[State Department]]"
start: 2017-02-20
@ -108,14 +108,14 @@ relations:
start: 2017-05
end: 2020-10-02
role: "formal investigation into data analytics in political campaigns"
fn: 39
fn: 42
- type: subject_of
with: "[[Senate Select Committee on Intelligence]]"
end: 2020-08-18
role: "Volume 5 of the committee's Russia report examined the company"
fn: 2
created: 2026-10-01
updated: 2026-10-12
updated: 2026-10-15
---
Cambridge Analytica, formally Cambridge Analytica LLC, was a [[Delaware]] limited liability company formed in December 2013 with its principal office at 597 Fifth Avenue in [[New York City]], and part of the family of companies of the British firm [[SCL Group]].[^1] [[Robert Mercer]] capitalized the company, [[Steve Bannon]] served on its board, and its chief executive officer was [[Alexander Nix]].[^2] The company filed for Chapter 7 bankruptcy protection in the [[United States Bankruptcy Court for the Southern District of New York]] on May 17, 2018 ([[In re Cambridge Analytica LLC]], Case No. 18-11500-shl).[^3]
@ -146,47 +146,51 @@ The [[Federal Trade Commission]] found, on the allegations in its complaint to w
The Senate committee wrote that, according to Kogan, the application ultimately collected approximately 30 million personality profiles "which were transferred to SCL Group," and noted in a footnote that his written testimony to a Senate subcommittee on June 19, 2018 states that the data was not transferred to SCL.[^17] The Information Commissioner's Office reported contrary evidence that Cambridge Analytica staff controlled "the manner and frequency" with which the data was harvested and that the harvested data was transferred to a "drop-zone" from which Cambridge Analytica extracted modeled data.[^18] Wylie told the committee that the Russian government sponsored some of Kogan's research and that Kogan traveled to Russia to present it; the committee quoted a March 15, 2014 email from an SCL employee to Nix, Wylie and a colleague referring to "the interesting work Alex Kogan has been doing for the Russians."[^17] Kogan denied awareness of any evidence the Trump campaign used the data.[^17]
The Information Commissioner's Office found that the application developed by Kogan and his company harvested data of up to 87 million people worldwide and that the personal information of at least one million UK users was among it.[^19] On July 24, 2019 the [[Securities and Exchange Commission]] stated that Cambridge Analytica paid an academic researcher, through a company he controlled, to collect and transfer Facebook data to create personality scores for approximately 30 million Americans.[^20]
[[Nicholas Confessore]] and [[Matthew Rosenberg]] reported in [[The New York Times]] on March 27, 2018 that in summer 2014 the company "received help from at least one employee at [[Palantir Technologies]]." According to documents the newspaper obtained, a Palantir employee in London, [[Alfredas Chmieliauskas]], whose LinkedIn page describes business development work, suggested that the company's data scientists create their own personality quiz to reach Facebook users' friend networks. The report states that beginning in 2013 Chmieliauskas corresponded with Wylie and a colleague and that they shared documents to brainstorm behavioral profiling, a product code-named "Big Daddy." A former SCL intern, [[Sophie Schmidt]], the daughter of [[Eric Schmidt]], urged the company in June 2013 to link up with Palantir, and emails indicated that Nix and Chmieliauskas sought to revive talks about election work through early 2014. Palantir first said it had "never had a relationship with Cambridge Analytica" and later the same day that "an employee, in 2013-2014, engaged in an entirely personal capacity with people associated with Cambridge Analytica." Wylie told British lawmakers: "There were senior Palantir employees that were also working on the Facebook data." He acknowledged that Palantir and Cambridge Analytica never signed a contract.[^21]
### Clients and payments recorded by the Federal Election Commission
Itemized disbursements to Cambridge Analytica in [[Federal Election Commission]] Schedule B records total $16,111,196.81 across 19 committees between June 2014 and March 2018, a figure that includes one entry marked "VOIDED: TO BE REFUNDED" ($10,027) and one memo-coded entry ($20,000); without them the total is $16,081,169.81.[^19] The largest recipients of payment by committee were [[Donald J. Trump for President, Inc.]] ($5,912,500 in five payments between July 29 and December 12, 2016), [[Cruz for President]] ($5,805,552 in 19 payments from July 2015 to June 2016), [[Make America Number 1]] ($1,476,484 in 13 payments from December 2015 to December 2016), the [[John Bolton Super PAC]] ($1,152,300 in 13 payments from July 2014 to September 2016), [[Keep the Promise II]] ($570,000 in December 2015 and January 2016) and [[Carson America]] ($438,065 from May 2015 to January 2016).[^19] The [[North Carolina Republican Party]] paid $215,000 between July 2014 and June 2015, the [[Thom Tillis]] committee $130,000 between October 2014 and December 2015, and the [[Jobs Growth and Freedom Fund]] $133,333.33 in October 2014.[^19] Two committees named Restoring American Leadership PAC and Restore American Leadership are recorded at $117,100 and $38,625 between May and December 2016, and the committees of [[Tom Cotton]] ($20,000, October 2014), [[Monica Wehby]] ($20,000, August and October 2014) and [[Patrick McHenry]] ($15,000, October 2014) also appear.[^19] Art Robinson for Congress, a committee whose registered address is 2251 Dick George Road, Cave Junction, Oregon, paid $20,000 in three payments between June 10 and November 5, 2014, and the committee Bob Huff for Congress reported the voided $10,027 entry on March 9, 2018.[^19][^20]
Itemized disbursements to Cambridge Analytica in [[Federal Election Commission]] Schedule B records total $16,111,196.81 across 19 committees between June 2014 and March 2018, a figure that includes one entry marked "VOIDED: TO BE REFUNDED" ($10,027) and one memo-coded entry ($20,000); without them the total is $16,081,169.81.[^22] The largest recipients of payment by committee were [[Donald J. Trump for President, Inc.]] ($5,912,500 in five payments between July 29 and December 12, 2016), [[Cruz for President]] ($5,805,552 in 19 payments from July 2015 to June 2016), [[Make America Number 1]] ($1,476,484 in 13 payments from December 2015 to December 2016), the [[John Bolton Super PAC]] ($1,152,300 in 13 payments from July 2014 to September 2016), [[Keep the Promise II]] ($570,000 in December 2015 and January 2016) and [[Carson America]] ($438,065 from May 2015 to January 2016).[^22] The [[North Carolina Republican Party]] paid $215,000 between July 2014 and June 2015, the [[Thom Tillis]] committee $130,000 between October 2014 and December 2015, and the [[Jobs Growth and Freedom Fund]] $133,333.33 in October 2014.[^22] Two committees named Restoring American Leadership PAC and Restore American Leadership are recorded at $117,100 and $38,625 between May and December 2016, and the committees of [[Tom Cotton]] ($20,000, October 2014), [[Monica Wehby]] ($20,000, August and October 2014) and [[Patrick McHenry]] ($15,000, October 2014) also appear.[^22] Art Robinson for Congress, a committee whose registered address is 2251 Dick George Road, Cave Junction, Oregon, paid $20,000 in three payments between June 10 and November 5, 2014, and the committee Bob Huff for Congress reported the voided $10,027 entry on March 9, 2018.[^22][^23]
The Trump campaign payments were reported as "data management" and "data management services." The campaign's reports for July, August, September and October 1 to 19, 2016 and the year-end report that carry them are amendments filed on November 19, 2018, December 20, 2018, March 13, 2019, April 5, 2019 and June 28, 2019, each the last in a chain of four or five filings that began with an original report filed between August 2016 and January 2017.[^21] The single payment of $5,000,000 is dated September 1, 2016.[^21] The Senate committee recorded that the first disbursement was on July 29, 2016 and that the payments continued through December 12, 2016.[^22]
The Trump campaign payments were reported as "data management" and "data management services." The campaign's reports for July, August, September and October 1 to 19, 2016 and the year-end report that carry them are amendments filed on November 19, 2018, December 20, 2018, March 13, 2019, April 5, 2019 and June 28, 2019, each the last in a chain of four or five filings that began with an original report filed between August 2016 and January 2017.[^24] The single payment of $5,000,000 is dated September 1, 2016.[^24] The Senate committee recorded that the first disbursement was on July 29, 2016 and that the payments continued through December 12, 2016.[^25]
The Bolton PAC's payments to the company began on July 7, 2014 with $25,000 for "research" and continued as "survey research" through September 29, 2016; over the same period the committee's receipts include ten contributions of $500,000 each from Robert Mercer, dated between April 28, 2014 and December 28, 2017.[^23] Make America Number 1, whose statement of organization of April 6, 2015 was submitted under a cover letter headed "Keep The Promise I" and whose amended statement signed on June 22, 2016 gives the name Make America Number 1, received $11,000,000 from Mercer on April 10, 2015, and $4,500,000 more in 2016.[^24][^25] The committee's disbursements in the same period include payments to Cambridge Analytica, $109,341.25 to Breitbart News Network LLC on November 25, 2015 for "list purchase expense," and $280,641 to Glittering Steel LLC for video production.[^25] The [[Mercer Family Foundation]] return for 2021 lists the [[Oregon Institute of Science and Medicine]] at 2251 Dick George Road, Cave Junction, Oregon, and earlier returns list grants to an organization of that name at Cave Junction, including $965,000 in tax year 2011.[^26] The foundation and the family's other filings are described at [[Mercer family]].
The Bolton PAC's payments to the company began on July 7, 2014 with $25,000 for "research" and continued as "survey research" through September 29, 2016; over the same period the committee's receipts include ten contributions of $500,000 each from Robert Mercer, dated between April 28, 2014 and December 28, 2017.[^26] Make America Number 1, whose statement of organization of April 6, 2015 was submitted under a cover letter headed "Keep The Promise I" and whose amended statement signed on June 22, 2016 gives the name Make America Number 1, received $11,000,000 from Mercer on April 10, 2015, and $4,500,000 more in 2016.[^27][^28] The committee's disbursements in the same period include payments to Cambridge Analytica, $109,341.25 to Breitbart News Network LLC on November 25, 2015 for "list purchase expense," and $280,641 to Glittering Steel LLC for video production.[^28] The [[Mercer Family Foundation]] return for 2021 lists the [[Oregon Institute of Science and Medicine]] at 2251 Dick George Road, Cave Junction, Oregon, and earlier returns list grants to an organization of that name at Cave Junction, including $965,000 in tax year 2011.[^29] The foundation and the family's other filings are described at [[Mercer family]].
### Contacts with the Trump campaign
Kaiser told the Senate committee that discussion of a commercial offer to the Trump campaign began in May 2015, that she and Nix met Bannon in Washington in September 2015, that [[Donald Trump]] telephoned Bannon during the meeting and directed that Nix and Kaiser come to New York to meet [[Corey Lewandowski]], and that "eight or ten weeks" of contract negotiations followed without result.[^27] Bannon told the committee he had no recollection of the call.[^27] Kaiser also said that almost every client meeting she had with a political figure was preceded by an introduction from Bannon, Rebekah Mercer or [[Kellyanne Conway]], whom the committee described as an advisor to the Mercers at the time, and that Conway was closely involved in moving the company from the Cruz campaign to the Trump campaign.[^28]
Kaiser told the Senate committee that discussion of a commercial offer to the Trump campaign began in May 2015, that she and Nix met Bannon in Washington in September 2015, that [[Donald Trump]] telephoned Bannon during the meeting and directed that Nix and Kaiser come to New York to meet [[Corey Lewandowski]], and that "eight or ten weeks" of contract negotiations followed without result.[^30] Bannon told the committee he had no recollection of the call.[^30] Kaiser also said that almost every client meeting she had with a political figure was preceded by an introduction from Bannon, Rebekah Mercer or [[Kellyanne Conway]], whom the committee described as an advisor to the Mercers at the time, and that Conway was closely involved in moving the company from the Cruz campaign to the Trump campaign.[^31]
[[Brad Parscale]] told the committee that the campaign's polling data was ingested into a visualization tool with the help of Cambridge Analytica developers, and that the tool was available on an iPad that Parscale carried.[^29]
[[Brad Parscale]] told the committee that the campaign's polling data was ingested into a visualization tool with the help of Cambridge Analytica developers, and that the tool was available on an iPad that Parscale carried.[^32]
The committee recorded that the Cruz campaign spent about $5.8 million on the company and the campaign of [[Ben Carson]] more than $430,000, citing a [[CNN]] report, and that within a week of Cruz leaving the race the employees working on his campaign began moving to the Trump campaign.[^27] [[Rick Gates]] told the [[Federal Bureau of Investigation]] that the campaign decided shortly after the Republican National Convention to use the company, that the [[Republican National Committee]] did not want to use it, that Brad Parscale was reluctant, that [[Jared Kushner]] wanted to use it and negotiated a package with payment at the end of the campaign.[^22] Kushner told the committee that the Mercers aggressively advocated use of the company and that the campaign engaged it to secure the Mercers' support.[^22] Parscale said he decided to hire the company in June 2016 after approval from [[Paul Manafort]] and Kushner, that he declined its offer of "psychographic profiling" services, and that he used Republican National Committee data rather than the company's data.[^22][^30]
The committee recorded that the Cruz campaign spent about $5.8 million on the company and the campaign of [[Ben Carson]] more than $430,000, citing a [[CNN]] report, and that within a week of Cruz leaving the race the employees working on his campaign began moving to the Trump campaign.[^30] [[Rick Gates]] told the [[Federal Bureau of Investigation]] that the campaign decided shortly after the Republican National Convention to use the company, that the [[Republican National Committee]] did not want to use it, that Brad Parscale was reluctant, that [[Jared Kushner]] wanted to use it and negotiated a package with payment at the end of the campaign.[^25] Kushner told the committee that the Mercers aggressively advocated use of the company and that the campaign engaged it to secure the Mercers' support.[^25] Parscale said he decided to hire the company in June 2016 after approval from [[Paul Manafort]] and Kushner, that he declined its offer of "psychographic profiling" services, and that he used Republican National Committee data rather than the company's data.[^25][^33]
The committee obtained a campaign data team presentation of August 22, 2016 with a slide depicting data flowing in both directions between the campaign and Cambridge Analytica, with the company's node titled "Digital Media Psychographic Analysis," and another slide showing arrows between its "Psychographic Analysis" and both the Republican National Committee's "GOP Data Center" and the campaign's San Antonio operation, which it called "Project Alamo."[^30] The committee wrote that documents it obtained suggested that the company's data may have been used in support of the campaign and that the campaign may have leveraged its psychographic analysis capabilities.[^30] Gates told the FBI that he later learned campaign data was transmitted to and analyzed in the [[United Kingdom]], which concerned him.[^30] Kaiser said that Project Alamo was "built completely from scratch" from the Republican National Committee's Data Trust database and purchased data sets.[^30]
The committee obtained a campaign data team presentation of August 22, 2016 with a slide depicting data flowing in both directions between the campaign and Cambridge Analytica, with the company's node titled "Digital Media Psychographic Analysis," and another slide showing arrows between its "Psychographic Analysis" and both the Republican National Committee's "GOP Data Center" and the campaign's San Antonio operation, which it called "Project Alamo."[^33] The committee wrote that documents it obtained suggested that the company's data may have been used in support of the campaign and that the campaign may have leveraged its psychographic analysis capabilities.[^33] Gates told the FBI that he later learned campaign data was transmitted to and analyzed in the [[United Kingdom]], which concerned him.[^33] Kaiser said that Project Alamo was "built completely from scratch" from the Republican National Committee's Data Trust database and purchased data sets.[^33]
### Russian and WikiLeaks contacts
Wylie said that from spring 2014 through 2015 Cambridge Analytica representatives met representatives of Lukoil, that Nix's presentations included discussion of rumor and disinformation campaigns, and that in May 2018 he told the [[Senate Judiciary Committee]] that Lukoil "has formal information sharing agreements with the Russian Federal Security Service."[^31][^32] His written statement said that after a request for information from Lukoil executives in the spring of 2014, Cambridge Analytica discussed with Lukoil its experience with "foreign disinformation, rumour campaigns, microtargeting and its American data assets."[^32] Kaiser told the committee the discussions concerned a customer loyalty application for Lukoil's stations in Turkey, said she was told the data could also be useful for political activities there, and furnished a February 2015 presentation prepared by SCL Commercial; neither she nor Wylie believed that a contract resulted, and the committee stated that it did not independently corroborate the allegation that Lukoil intended to use the company to affect elections.[^31] The committee noted that the [[Office of Foreign Assets Control]] had added Lukoil to its Sectoral Sanctions Identifications List on September 12, 2014.[^31]
Wylie said that from spring 2014 through 2015 Cambridge Analytica representatives met representatives of Lukoil, that Nix's presentations included discussion of rumor and disinformation campaigns, and that in May 2018 he told the [[Senate Judiciary Committee]] that Lukoil "has formal information sharing agreements with the Russian Federal Security Service."[^34][^35] His written statement said that after a request for information from Lukoil executives in the spring of 2014, Cambridge Analytica discussed with Lukoil its experience with "foreign disinformation, rumour campaigns, microtargeting and its American data assets."[^35] Kaiser told the committee the discussions concerned a customer loyalty application for Lukoil's stations in Turkey, said she was told the data could also be useful for political activities there, and furnished a February 2015 presentation prepared by SCL Commercial; neither she nor Wylie believed that a contract resulted, and the committee stated that it did not independently corroborate the allegation that Lukoil intended to use the company to affect elections.[^34] The committee noted that the [[Office of Foreign Assets Control]] had added Lukoil to its Sectoral Sanctions Identifications List on September 12, 2014.[^34]
Wylie also told the committee that in spring 2014 Bannon approved focus groups about [[Vladimir Putin]] and Russian expansionism preparatory to a predictive model, and that Bannon and [[Konstantin Kilimnik]] were two of three people likely responsible for the idea.[^33] [[Sam Patten]], a consultant who worked for the company in Nigeria, Mexico, Kosovo and the Czech Republic, told the committee there was "no connection" between Kilimnik and Cambridge Analytica; Kaiser said that on the Nigerian project the company may have assisted its client in retaining former Israeli intelligence officers working privately to conduct opposition research.[^33]
Wylie also told the committee that in spring 2014 Bannon approved focus groups about [[Vladimir Putin]] and Russian expansionism preparatory to a predictive model, and that Bannon and [[Konstantin Kilimnik]] were two of three people likely responsible for the idea.[^36] [[Sam Patten]], a consultant who worked for the company in Nigeria, Mexico, Kosovo and the Czech Republic, told the committee there was "no connection" between Kilimnik and Cambridge Analytica; Kaiser said that on the Nigerian project the company may have assisted its client in retaining former Israeli intelligence officers working privately to conduct opposition research.[^36]
The committee reported open-source accounts that during the 2016 campaign Nix emailed [[Julian Assange]] about the possible release of [[Hillary Clinton]]'s deleted emails, and that Assange said in October 2017 that [[WikiLeaks]] had rejected an approach by Cambridge Analytica. The committee obtained no additional information, and Bannon and others close to the campaign said they had no prior awareness of the contact.[^34] The committee also recorded that it was unable to obtain the company's corporate communications, which were in the hands of United Kingdom authorities, and that Nix "generally disregarded the Committee's requests for an appearance."[^35] It found "no convincing evidence that Russia's government or intelligence services worked with or through" Cambridge Analytica, Psy Group or Colt Ventures in furtherance of the 2016 interference.[^35] Cambridge Analytica, LLC is named among the respondents in matters under review 7207, 7268, 7274 and 7623 before the Federal Election Commission, in which Commissioners Shana Broussard and Ellen Weintraub issued a statement of reasons citing Volume 5 after a certification dated April 22, 2021; the text of the statement concerns the Russian Federation, the Internet Research Agency and the Trump committee and does not mention Cambridge Analytica outside the caption.[^36]
The committee reported open-source accounts that during the 2016 campaign Nix emailed [[Julian Assange]] about the possible release of [[Hillary Clinton]]'s deleted emails, and that Assange said in October 2017 that [[WikiLeaks]] had rejected an approach by Cambridge Analytica. The committee obtained no additional information, and Bannon and others close to the campaign said they had no prior awareness of the contact.[^37] The committee also recorded that it was unable to obtain the company's corporate communications, which were in the hands of United Kingdom authorities, and that Nix "generally disregarded the Committee's requests for an appearance."[^38] It found "no convincing evidence that Russia's government or intelligence services worked with or through" Cambridge Analytica, Psy Group or Colt Ventures in furtherance of the 2016 interference.[^38] Cambridge Analytica, LLC is named among the respondents in matters under review 7207, 7268, 7274 and 7623 before the Federal Election Commission, in which Commissioners Shana Broussard and Ellen Weintraub issued a statement of reasons citing Volume 5 after a certification dated April 22, 2021; the text of the statement concerns the Russian Federation, the Internet Research Agency and the Trump committee and does not mention Cambridge Analytica outside the caption.[^39]
### Regulatory and criminal proceedings in the United Kingdom
The Information Commissioner's Office issued a monetary penalty notice of £500,000 to Facebook on October 25, 2018, the highest fine permitted under the Data Protection Act 1998, citing lack of transparency and security failures relating to the harvesting of data.[^37] The office also executed a warrant at the company's premises at 8 p.m. on March 23, 2018, seized servers and other material, and reported that Cambridge Analytica and SCL Elections entered administration on May 3, 2018, that an enforcement notice of May 4, 2018 required it to answer a subject access request from the American academic [[David Carroll]] that had been made in January 2017, and that the deadline of June 3, 2018 passed without compliance.[^18] The office reported that Nix and Kogan had declined invitations to voluntary interviews under caution and that it would have issued a substantial fine had the company not been in administration.[^18] SCL Elections pleaded guilty at [[Hendon Magistrates' Court]] on January 9, 2019, the day set for trial, to failing to comply with the enforcement notice; press reports gave the penalty as a fine of £15,000 with £6,000 in costs and a victim surcharge of £170.[^38] The Information Commissioner's 2020 letter to Parliament gives the fine as £18,000.[^39]
The Information Commissioner's Office issued a monetary penalty notice of £500,000 to Facebook on October 25, 2018, the highest fine permitted under the Data Protection Act 1998, citing lack of transparency and security failures relating to the harvesting of data.[^40] The office also executed a warrant at the company's premises at 8 p.m. on March 23, 2018, seized servers and other material, and reported that Cambridge Analytica and SCL Elections entered administration on May 3, 2018, that an enforcement notice of May 4, 2018 required it to answer a subject access request from the American academic [[David Carroll]] that had been made in January 2017, and that the deadline of June 3, 2018 passed without compliance.[^18] The office reported that Nix and Kogan had declined invitations to voluntary interviews under caution and that it would have issued a substantial fine had the company not been in administration.[^18] SCL Elections pleaded guilty at [[Hendon Magistrates' Court]] on January 9, 2019, the day set for trial, to failing to comply with the enforcement notice; press reports gave the penalty as a fine of £15,000 with £6,000 in costs and a victim surcharge of £170.[^41] The Information Commissioner's 2020 letter to Parliament gives the fine as £18,000.[^42]
On October 2, 2020 the Information Commissioner, [[Elizabeth Denham]], wrote to the chair of the Digital, Culture, Media and Sport Committee that the office had concluded its investigation, that the company had purchased commercially available data amounting at one estimate to more than 130 billion data points, mostly about United States voters, to combine with Facebook-derived data from Kogan, that its models were mostly built from "off the shelf" tools, that the office found no further evidence to change its view that the company was not involved in the European Union referendum campaign beyond early inquiries about UK Independence Party data, and that it found no additional evidence of Russian involvement in the servers it obtained.[^39] The letter also reported evidence that in its last stages the company was drawing up plans to move its data offshore to avoid regulatory scrutiny, which it did not carry out before it ceased trading.[^39]
On October 2, 2020 the Information Commissioner, [[Elizabeth Denham]], wrote to the chair of the Digital, Culture, Media and Sport Committee that the office had concluded its investigation, that the company had purchased commercially available data amounting at one estimate to more than 130 billion data points, mostly about United States voters, to combine with Facebook-derived data from Kogan, that its models were mostly built from "off the shelf" tools, that the office found no further evidence to change its view that the company was not involved in the European Union referendum campaign beyond early inquiries about UK Independence Party data, and that it found no additional evidence of Russian involvement in the servers it obtained.[^42] The letter also reported evidence that in its last stages the company was drawing up plans to move its data offshore to avoid regulatory scrutiny, which it did not carry out before it ceased trading.[^42]
The Insolvency Service announced in September 2020 that Nix had given an undertaking disqualifying him from acting as a company director for seven years from October 5, 2020, having, in the service's words, caused or permitted SCL Elections or associated companies to act with a lack of commercial probity by marketing services including "bribery or honey trap stings, voter disengagement campaigns, obtaining information to discredit political opponents and spreading information anonymously in political campaigns." The service did not say whether any such services were performed, and Nix told Reuters he had made no admission of wrongdoing.[^40] The Digital, Culture, Media and Sport Committee had recorded in February 2019 that the Insolvency Service was investigating the directors of SCL Elections, SCL Group, SCL Analytics, SCL Commercial, SCL Social and Cambridge Analytica (UK) under the [[Company Directors Disqualification Act 1986]].[^41]
The Insolvency Service announced in September 2020 that Nix had given an undertaking disqualifying him from acting as a company director for seven years from October 5, 2020, having, in the service's words, caused or permitted SCL Elections or associated companies to act with a lack of commercial probity by marketing services including "bribery or honey trap stings, voter disengagement campaigns, obtaining information to discredit political opponents and spreading information anonymously in political campaigns." The service did not say whether any such services were performed, and Nix told Reuters he had made no admission of wrongdoing.[^43] The Digital, Culture, Media and Sport Committee had recorded in February 2019 that the Insolvency Service was investigating the directors of SCL Elections, SCL Group, SCL Analytics, SCL Commercial, SCL Social and Cambridge Analytica (UK) under the [[Company Directors Disqualification Act 1986]].[^44]
### Emerdata and the end of the group
Emerdata Limited (Companies House number 10911848) was incorporated on August 11, 2017 with Wheatland as a director, and its persons with significant control from incorporation were Wheatland and Dr Alexander Bruce Tayler, each holding more than 25 percent and up to 50 percent until January 23, 2018.[^42] From January 23, 2018 the register shows Cambridge Analytica Holdings LLC, with an address on Orange Street in Wilmington, Delaware, as holder of more than 50 percent and less than 75 percent of shares and votes until August 9, 2022; since that date the register carries a statement that there is no registrable person.[^42] The register records the officers appointed on January 23, 2018 as Nix (resigned March 28, 2018), Johnson Chun Shun Ko (resigned May 9, 2018), Cheng Peng (resigned May 8, 2018) and Ahmad Al Khatib (resigned May 7, 2018); Tayler was a director again from March 28 to April 18, 2018, Gary Ka Chun Tiu from June 12, 2018 to December 3, 2024, and Wheatland until May 22, 2019.[^42] Rebekah and Jennifer Mercer were appointed directors on March 16, 2018 and remained in office as of the register consulted on October 1, 2026, with [[Jacquelyn James-Varga]] (appointed May 22, 2019) and Bradley David Golub (appointed December 3, 2024).[^42]
Emerdata Limited (Companies House number 10911848) was incorporated on August 11, 2017 with Wheatland as a director, and its persons with significant control from incorporation were Wheatland and Dr Alexander Bruce Tayler, each holding more than 25 percent and up to 50 percent until January 23, 2018.[^45] From January 23, 2018 the register shows Cambridge Analytica Holdings LLC, with an address on Orange Street in Wilmington, Delaware, as holder of more than 50 percent and less than 75 percent of shares and votes until August 9, 2022; since that date the register carries a statement that there is no registrable person.[^45] The register records the officers appointed on January 23, 2018 as Nix (resigned March 28, 2018), Johnson Chun Shun Ko (resigned May 9, 2018), Cheng Peng (resigned May 8, 2018) and Ahmad Al Khatib (resigned May 7, 2018); Tayler was a director again from March 28 to April 18, 2018, Gary Ka Chun Tiu from June 12, 2018 to December 3, 2024, and Wheatland until May 22, 2019.[^45] Rebekah and Jennifer Mercer were appointed directors on March 16, 2018 and remained in office as of the register consulted on October 1, 2026, with [[Jacquelyn James-Varga]] (appointed May 22, 2019) and Bradley David Golub (appointed December 3, 2024).[^45]
The Digital, Culture, Media and Sport Committee reported in February 2019 that Emerdata had not gone into administration, was the largest creditor of SCL Elections and was paying the administration costs, and listed shareholders as of August 10, 2018 that included Cambridge Analytica Holdings LLC, Tayler, Wheatland, trusts for the benefit of Rebekah, Jennifer and Heather Mercer, Alexander and Catherine Nix, five members of the Marland family, Henry and Roger Gabb, Nigel and Alexander Oakes, and Reza Saddlou-Bundy.[^41] The committee recommended that the [[National Crime Agency]] investigate the connections between SCL Elections and Emerdata.[^41] The committee also reported that SCL Insight Limited, owned by Nigel Oakes, had been spun off in the 2017 reorganization.[^41]
The Digital, Culture, Media and Sport Committee reported in February 2019 that Emerdata had not gone into administration, was the largest creditor of SCL Elections and was paying the administration costs, and listed shareholders as of August 10, 2018 that included Cambridge Analytica Holdings LLC, Tayler, Wheatland, trusts for the benefit of Rebekah, Jennifer and Heather Mercer, Alexander and Catherine Nix, five members of the Marland family, Henry and Roger Gabb, Nigel and Alexander Oakes, and Reza Saddlou-Bundy.[^44] The committee recommended that the [[National Crime Agency]] investigate the connections between SCL Elections and Emerdata.[^44] The committee also reported that SCL Insight Limited, owned by Nigel Oakes, had been spun off in the 2017 reorganization.[^44]
Emerdata entered administration on December 9, 2024, the register names Benjamin Stanyon and Nedim Patrick Ailyan as practitioners, records a cessation to act on April 8, 2026, and gives the registered office as care of Opus Restructuring LLP, Milton Keynes.[^42] SCL Group Limited, SCL Elections Limited and Cambridge Analytica (UK) Limited were in administration from May 3, 2018 to April 17, 2019, then in compulsory liquidation on a petition of August 13, 2018, which concluded on September 1, 2025; the first two were dissolved on January 31, 2026 and the third on January 30, 2026.[^43]
Emerdata entered administration on December 9, 2024, the register names Benjamin Stanyon and Nedim Patrick Ailyan as practitioners, records a cessation to act on April 8, 2026, and gives the registered office as care of Opus Restructuring LLP, Milton Keynes.[^45] SCL Group Limited, SCL Elections Limited and Cambridge Analytica (UK) Limited were in administration from May 3, 2018 to April 17, 2019, then in compulsory liquidation on a petition of August 13, 2018, which concluded on September 1, 2025; the first two were dissolved on January 31, 2026 and the third on January 30, 2026.[^46]
### Footnotes
@ -208,28 +212,31 @@ Emerdata entered administration on December 9, 2024, the register names Benjamin
[^16]: Federal Trade Commission, *In the Matter of Cambridge Analytica, LLC*, Docket No. 9383, Opinion of the Commission, issued November 25, 2019, introduction, section I and note 1 (consent settlements with Alexander Nix and Aleksandr Kogan accepted July 24, 2019, matters 182-3106 and 182-3107); administrative complaint of July 24, 2019 (matter 182 3107). https://www.ftc.gov/system/files/documents/cases/d09389_comm_final_opinionpublic.pdf and https://www.ftc.gov/system/files/documents/cases/182_3107_cambridge_analytica_administrative_complaint_7-24-19.pdf
[^17]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 668 to 670 and notes 4326 to 4333 (Kogan testimony of June 19, 2018 before the Senate Commerce Committee subcommittee; Wylie proffer; email Beltran to Nix, Ward and Wylie, March 15, 2014, WYL001009). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^18]: UK Information Commissioner's Office, *Investigation into the use of data analytics in political campaigns: A report to Parliament*, November 6, 2018, sections 3.2.1 to 3.2.3 (pp. 31 to 37). https://www.statewatch.org/media/documents/news/2018/nov/uk-ico-report-investigation-into-use-of-data-political-campaigns-6-11-18.pdf
[^19]: OpenFEC API (https://api.open.fec.gov/developers/), Schedule B itemized disbursements, recipient names "CAMBRIDGE ANALYTICA," "CAMBRIDGE ANALYTICA, LLC" and "CAMBRIDGE ANALYTICA LLC" (90 unique line items, retrieved October 1, 2026); amounts summed by filing committee. Committee identifiers: Donald J. Trump for President, Inc. C00580100; Cruz for President C00574624; Make America Number 1 C00575373; John Bolton Super PAC C00542464; Keep the Promise II C00575431; Carson America C00573519; North Carolina Republican Party C00038505; Jobs Growth and Freedom Fund C00536540; Thom Tillis Committee C00545772; Art Robinson for Congress C00481341; Bob Huff for Congress C00665802. https://api.open.fec.gov/v1/schedules/schedule_b/?recipient_name=Cambridge+Analytica
[^20]: Federal Election Commission, committee record for ART ROBINSON FOR CONGRESS (C00481341), street address 2251 DICK GEORGE RD, Cave Junction, Oregon, treasurer Art Robinson, first filed April 17, 2010. https://api.open.fec.gov/v1/committee/C00481341/
[^21]: Federal Election Commission, Donald J. Trump for President, Inc. (C00580100), Schedule B, payments to Cambridge Analytica, LLC dated July 29, 2016 ($100,000), August 18, 2016 ($250,000), September 1, 2016 ($5,000,000), October 19, 2016 ($250,000) and December 12, 2016 ($312,500); amended reports file numbers 1291697 (receipt date November 19, 2018), 1301972 (December 20, 2018), 1319157 (March 13, 2019), 1322657 (April 5, 2019) and 1335968 (June 28, 2019), with originals 1096341, 1111849, 1119574 and 1146165 in the amendment chains. https://docquery.fec.gov/cgi-bin/fecimg/?201903139145702446 (September 2016 payment)
[^22]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 673 to 675 and notes 4358 to 4366 (FBI FD-302 of Rick Gates, October 29, 2018; Kushner transcript II, pp. 84 to 85; Parscale transcript, pp. 55 to 62), and note 4363 (FEC disbursements July 29 to December 12, 2016, totaling $5,912,500). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^23]: OpenFEC API (https://api.open.fec.gov/developers/), Schedule B itemized disbursements to Cambridge Analytica by John Bolton Super PAC (C00542464), July 7, 2014 to September 29, 2016; and OpenFEC Schedule A receipts of C00542464 from Robert Mercer of East Setauket, New York ($500,000 each on April 28, 2014, June 30, 2014, February 24, 2015, June 30, 2015, September 28, 2015, December 18, 2015, July 5, 2016, September 6, 2016, October 23, 2017 and December 28, 2017). https://api.open.fec.gov/v1/schedules/schedule_a/?committee_id=C00542464&contributor_name=MERCER
[^24]: Federal Election Commission, Form 1 Statement of Organization of committee C00575373, original filed April 6, 2015 under cover letter headed "Keep The Promise I" signed by treasurer Jacquelyn James (https://docquery.fec.gov/pdf/670/15031410670/15031410670.pdf), and amended Form 1 dated June 21, 2016, filed June 22, 2016, under the name "Make America Number 1" (https://docquery.fec.gov/pdf/183/201606229020090183/201606229020090183.pdf).
[^25]: OpenFEC API, Schedule A receipts and Schedule B disbursements of Make America Number 1 (C00575373), 2015 to 2016, including receipts from Robert Mercer of $11,000,000 (April 10, 2015, file 1027937), $500,000 (February 26, 2016), $2,000,000 (March 17, 2016) and $2,000,000 (July 14, 2016); disbursements to Cambridge Analytica ($842,748 and $633,736 under two spellings), to Breitbart News Network LLC ($109,341.25 on November 25, 2015, "list purchase expense," file 1071367, and $10,000 on January 27, 2016, "media prepaid"), and to Glittering Steel LLC (seven payments from July 17, 2015 to November 1, 2016 totaling $280,641). https://api.open.fec.gov/v1/committee/C00575373/
[^26]: Mercer Family Foundation, Form 990-PF for 2011, Part XV (grant to OISM, P.O. Box 1279, Cave Junction, Oregon, $965,000) (https://990s.foundationcenter.org/990pf_pdf_archive/201/201982204/201982204_201112_990PF.pdf); Form 990-PF for 2021, Part XV (Oregon Institute of Science and Medicine, 2251 Dick George Road, Cave Junction, Oregon, $250,000), ProPublica Nonprofit Explorer full text (https://projects.propublica.org/nonprofits/organizations/201982204/202213199349104431/IRS990PF).
[^27]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 673 to 674 and notes 4352 to 4357 (Kaiser transcript, pp. 144 to 156; Bannon transcript, p. 268; Maegan Vazquez and Paul Murphy, "Trump isn't the only Republican who gave Cambridge Analytica big bucks," CNN, March 21, 2018). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^28]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, p. 672 and note 4348 (Kaiser transcript, pp. 40 to 43). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^29]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, notes 447 and 448 (Parscale transcript, p. 64). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^30]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 675 to 678 and notes 4367 to 4379 (Parscale transcript, pp. 53 to 60; Trump Data Team Presentation, August 22, 2016, FLYNN_SSCI_00011770 and 00011773; FBI FD-302 of Rick Gates, October 29, 2018; Kaiser transcript, pp. 161 to 164). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^31]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 670 to 671 and notes 4334 to 4341 (Wylie proffer; Wylie written statement to the Senate Judiciary Committee, May 16, 2018; Kaiser transcript, pp. 66 to 67 and 121 to 123; SCL Commercial presentation for Lukoil, February 18, 2015; OFAC listing of September 12, 2014). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^32]: Christopher Wylie, written statement, "In the Matter of Cambridge Analytica and Other Related Issues," Senate Committee on the Judiciary, May 16, 2018, paragraphs 32 and 33. https://www.judiciary.senate.gov/download/06/03/2026/05-16-18-wylie-testimony
[^33]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, p. 668 and notes 4318 to 4325 (Wylie proffer; Patten transcript, pp. 29 to 38; Kaiser transcript, pp. 67 to 68; Bannon transcript, pp. 253 to 256). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^34]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 678 to 679 and notes 4380 to 4383 (Betsy Swan, "Trump Data Guru Alexander Nix: I Tried To Team Up With Julian Assange," *The Daily Beast*, October 25, 2017; Kara Scannell, Dana Bash and Marshall Cohen, CNN, October 25, 2017). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^35]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 663 to 664 (section introduction, "Committee did not examine the effectiveness of the work these companies may have conducted"; limitations including Nix's non-appearance and the seizure of the company's corporate communications by U.K. authorities). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^36]: Federal Election Commission, Statement of Reasons of Commissioners Shana M. Broussard and Ellen L. Weintraub, MURs 7207, 7268, 7274 and 7623 (Russian Federation; Donald J. Trump for President, Inc.; Donald J. Trump; H. Russell Taub; Cambridge Analytica, LLC; Internet Research Agency; Paul Manafort), note 2 (certification dated April 22, 2021). https://www.fec.gov/files/legal/murs/7207/7207_47.pdf
[^37]: UK Information Commissioner's Office, *Investigation into the use of data analytics in political campaigns: A report to Parliament*, November 6, 2018, section 3.2.4 (p. 38). https://www.statewatch.org/media/documents/news/2018/nov/uk-ico-report-investigation-into-use-of-data-political-campaigns-6-11-18.pdf
[^38]: UK Information Commissioner's Office, *Investigation into the use of data analytics in political campaigns*, November 6, 2018, section 3.2.3 (trial set for January 9, 2019 at Hendon Magistrates' Court); "Cambridge Analytica Pleads Guilty In UK Data Access Case," *MediaPost*, January 9, 2019 (fine of £15,000, costs of £6,000, victim surcharge of £170, citing the ICO announcement) https://www.mediapost.com/publications/article/330338/ ; Ellen Tannam, "Cambridge Analytica owner hit with £15,000 fine for disobeying UK ICO," *Silicon Republic*, January 2019 (District Judge Kenneth Grant: "wilful disregard of the enforcement notice") https://www.siliconrepublic.com/enterprise/cambridge-analytica-scl-fine
[^39]: Elizabeth Denham, Information Commissioner, letter to Julian Knight MP, Chair, Digital, Culture, Media and Sport Committee, reference ICO/O/ED/L/RTL/0181, October 2, 2020, paragraphs 3 to 15. https://cy.ico.org.uk/media2/migrated/2618383/20201002_ico-o-ed-l-rtl-0181_to-julian-knight-mp.pdf
[^40]: "Ex-Cambridge Analytica head banned from running firms in UK," Reuters, published by Al Jazeera, September 25, 2020 (statement of the Insolvency Service of September 24, 2020; Mark Bruce, chief investigator; disqualification from October 5, 2020). https://www.aljazeera.com/economy/2020/9/25/uk-bans-ex-cambridge-analytica-boss-for-unethical-services
[^41]: House of Commons Digital, Culture, Media and Sport Committee, *Disinformation and "fake news": Final Report*, HC 1791, February 18, 2019, paragraphs 285 to 290, 296 and notes 327 to 329 and 338. https://publications.parliament.uk/pa/cm201719/cmselect/cmcumeds/1791/1791.pdf
[^42]: Companies House, EMERDATA LIMITED (company number 10911848), overview, officers, persons with significant control and insolvency pages, viewed October 1, 2026; personal appointments pages for Jennifer Lynne Mercer, Rebekah Anne Mercer, Jacquelyn James-Varga and Bradley David Golub. https://find-and-update.company-information.service.gov.uk/company/10911848
[^43]: Companies House, insolvency pages for SCL GROUP LIMITED (05514098), SCL ELECTIONS LIMITED (08256225) and CAMBRIDGE ANALYTICA(UK) LIMITED (09375920), viewed October 1, 2026 (administration May 3, 2018 to April 17, 2019; compulsory liquidation, petition August 13, 2018, winding up commenced April 17, 2019 and concluded September 1, 2025; dissolved January 31, 2026, January 31, 2026 and January 30, 2026). https://find-and-update.company-information.service.gov.uk/company/05514098/insolvency
[^19]: UK Information Commissioner's Office, *Investigation into the use of data analytics in political campaigns: A report to Parliament*, November 6, 2018, section 3.3.1. https://www.statewatch.org/media/documents/news/2018/nov/uk-ico-report-investigation-into-use-of-data-political-campaigns-6-11-18.pdf
[^20]: U.S. Securities and Exchange Commission, Press Release 2019-140, "Facebook to Pay $100 Million for Misleading Investors About the Risks It Faced From Misuse of User Data," July 24, 2019. https://www.sec.gov/newsroom/press-releases/2019-140
[^21]: Nicholas Confessore and Matthew Rosenberg, "Spy Contractor's Idea Helped Firm Harvest Facebook Data," *The New York Times,* March 27, 2018, as republished by WRAL. https://www.wral.com/spy-contractor-s-idea-helped-firm-harvest-facebook-data/17447632/
[^22]: OpenFEC API (https://api.open.fec.gov/developers/), Schedule B itemized disbursements, recipient names "CAMBRIDGE ANALYTICA," "CAMBRIDGE ANALYTICA, LLC" and "CAMBRIDGE ANALYTICA LLC" (90 unique line items, retrieved October 1, 2026); amounts summed by filing committee. Committee identifiers: Donald J. Trump for President, Inc. C00580100; Cruz for President C00574624; Make America Number 1 C00575373; John Bolton Super PAC C00542464; Keep the Promise II C00575431; Carson America C00573519; North Carolina Republican Party C00038505; Jobs Growth and Freedom Fund C00536540; Thom Tillis Committee C00545772; Art Robinson for Congress C00481341; Bob Huff for Congress C00665802. https://api.open.fec.gov/v1/schedules/schedule_b/?recipient_name=Cambridge+Analytica
[^23]: Federal Election Commission, committee record for ART ROBINSON FOR CONGRESS (C00481341), street address 2251 DICK GEORGE RD, Cave Junction, Oregon, treasurer Art Robinson, first filed April 17, 2010. https://api.open.fec.gov/v1/committee/C00481341/
[^24]: Federal Election Commission, Donald J. Trump for President, Inc. (C00580100), Schedule B, payments to Cambridge Analytica, LLC dated July 29, 2016 ($100,000), August 18, 2016 ($250,000), September 1, 2016 ($5,000,000), October 19, 2016 ($250,000) and December 12, 2016 ($312,500); amended reports file numbers 1291697 (receipt date November 19, 2018), 1301972 (December 20, 2018), 1319157 (March 13, 2019), 1322657 (April 5, 2019) and 1335968 (June 28, 2019), with originals 1096341, 1111849, 1119574 and 1146165 in the amendment chains. https://docquery.fec.gov/cgi-bin/fecimg/?201903139145702446 (September 2016 payment)
[^25]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 673 to 675 and notes 4358 to 4366 (FBI FD-302 of Rick Gates, October 29, 2018; Kushner transcript II, pp. 84 to 85; Parscale transcript, pp. 55 to 62), and note 4363 (FEC disbursements July 29 to December 12, 2016, totaling $5,912,500). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^26]: OpenFEC API (https://api.open.fec.gov/developers/), Schedule B itemized disbursements to Cambridge Analytica by John Bolton Super PAC (C00542464), July 7, 2014 to September 29, 2016; and OpenFEC Schedule A receipts of C00542464 from Robert Mercer of East Setauket, New York ($500,000 each on April 28, 2014, June 30, 2014, February 24, 2015, June 30, 2015, September 28, 2015, December 18, 2015, July 5, 2016, September 6, 2016, October 23, 2017 and December 28, 2017). https://api.open.fec.gov/v1/schedules/schedule_a/?committee_id=C00542464&contributor_name=MERCER
[^27]: Federal Election Commission, Form 1 Statement of Organization of committee C00575373, original filed April 6, 2015 under cover letter headed "Keep The Promise I" signed by treasurer Jacquelyn James (https://docquery.fec.gov/pdf/670/15031410670/15031410670.pdf), and amended Form 1 dated June 21, 2016, filed June 22, 2016, under the name "Make America Number 1" (https://docquery.fec.gov/pdf/183/201606229020090183/201606229020090183.pdf).
[^28]: OpenFEC API, Schedule A receipts and Schedule B disbursements of Make America Number 1 (C00575373), 2015 to 2016, including receipts from Robert Mercer of $11,000,000 (April 10, 2015, file 1027937), $500,000 (February 26, 2016), $2,000,000 (March 17, 2016) and $2,000,000 (July 14, 2016); disbursements to Cambridge Analytica ($842,748 and $633,736 under two spellings), to Breitbart News Network LLC ($109,341.25 on November 25, 2015, "list purchase expense," file 1071367, and $10,000 on January 27, 2016, "media prepaid"), and to Glittering Steel LLC (seven payments from July 17, 2015 to November 1, 2016 totaling $280,641). https://api.open.fec.gov/v1/committee/C00575373/
[^29]: Mercer Family Foundation, Form 990-PF for 2011, Part XV (grant to OISM, P.O. Box 1279, Cave Junction, Oregon, $965,000) (https://990s.foundationcenter.org/990pf_pdf_archive/201/201982204/201982204_201112_990PF.pdf); Form 990-PF for 2021, Part XV (Oregon Institute of Science and Medicine, 2251 Dick George Road, Cave Junction, Oregon, $250,000), ProPublica Nonprofit Explorer full text (https://projects.propublica.org/nonprofits/organizations/201982204/202213199349104431/IRS990PF).
[^30]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 673 to 674 and notes 4352 to 4357 (Kaiser transcript, pp. 144 to 156; Bannon transcript, p. 268; Maegan Vazquez and Paul Murphy, "Trump isn't the only Republican who gave Cambridge Analytica big bucks," CNN, March 21, 2018). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^31]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, p. 672 and note 4348 (Kaiser transcript, pp. 40 to 43). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^32]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, notes 447 and 448 (Parscale transcript, p. 64). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^33]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 675 to 678 and notes 4367 to 4379 (Parscale transcript, pp. 53 to 60; Trump Data Team Presentation, August 22, 2016, FLYNN_SSCI_00011770 and 00011773; FBI FD-302 of Rick Gates, October 29, 2018; Kaiser transcript, pp. 161 to 164). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^34]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 670 to 671 and notes 4334 to 4341 (Wylie proffer; Wylie written statement to the Senate Judiciary Committee, May 16, 2018; Kaiser transcript, pp. 66 to 67 and 121 to 123; SCL Commercial presentation for Lukoil, February 18, 2015; OFAC listing of September 12, 2014). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^35]: Christopher Wylie, written statement, "In the Matter of Cambridge Analytica and Other Related Issues," Senate Committee on the Judiciary, May 16, 2018, paragraphs 32 and 33. https://www.judiciary.senate.gov/download/06/03/2026/05-16-18-wylie-testimony
[^36]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, p. 668 and notes 4318 to 4325 (Wylie proffer; Patten transcript, pp. 29 to 38; Kaiser transcript, pp. 67 to 68; Bannon transcript, pp. 253 to 256). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^37]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 678 to 679 and notes 4380 to 4383 (Betsy Swan, "Trump Data Guru Alexander Nix: I Tried To Team Up With Julian Assange," *The Daily Beast*, October 25, 2017; Kara Scannell, Dana Bash and Marshall Cohen, CNN, October 25, 2017). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^38]: U.S. Senate Select Committee on Intelligence, *Russian Active Measures Campaigns and Interference in the 2016 U.S. Election, Volume 5: Counterintelligence Threats and Vulnerabilities*, report released August 18, 2020, pp. 663 to 664 (section introduction, "Committee did not examine the effectiveness of the work these companies may have conducted"; limitations including Nix's non-appearance and the seizure of the company's corporate communications by U.K. authorities). https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf
[^39]: Federal Election Commission, Statement of Reasons of Commissioners Shana M. Broussard and Ellen L. Weintraub, MURs 7207, 7268, 7274 and 7623 (Russian Federation; Donald J. Trump for President, Inc.; Donald J. Trump; H. Russell Taub; Cambridge Analytica, LLC; Internet Research Agency; Paul Manafort), note 2 (certification dated April 22, 2021). https://www.fec.gov/files/legal/murs/7207/7207_47.pdf
[^40]: UK Information Commissioner's Office, *Investigation into the use of data analytics in political campaigns: A report to Parliament*, November 6, 2018, section 3.2.4 (p. 38). https://www.statewatch.org/media/documents/news/2018/nov/uk-ico-report-investigation-into-use-of-data-political-campaigns-6-11-18.pdf
[^41]: UK Information Commissioner's Office, *Investigation into the use of data analytics in political campaigns*, November 6, 2018, section 3.2.3 (trial set for January 9, 2019 at Hendon Magistrates' Court); "Cambridge Analytica Pleads Guilty In UK Data Access Case," *MediaPost*, January 9, 2019 (fine of £15,000, costs of £6,000, victim surcharge of £170, citing the ICO announcement) https://www.mediapost.com/publications/article/330338/ ; Ellen Tannam, "Cambridge Analytica owner hit with £15,000 fine for disobeying UK ICO," *Silicon Republic*, January 2019 (District Judge Kenneth Grant: "wilful disregard of the enforcement notice") https://www.siliconrepublic.com/enterprise/cambridge-analytica-scl-fine
[^42]: Elizabeth Denham, Information Commissioner, letter to Julian Knight MP, Chair, Digital, Culture, Media and Sport Committee, reference ICO/O/ED/L/RTL/0181, October 2, 2020, paragraphs 3 to 15. https://cy.ico.org.uk/media2/migrated/2618383/20201002_ico-o-ed-l-rtl-0181_to-julian-knight-mp.pdf
[^43]: "Ex-Cambridge Analytica head banned from running firms in UK," Reuters, published by Al Jazeera, September 25, 2020 (statement of the Insolvency Service of September 24, 2020; Mark Bruce, chief investigator; disqualification from October 5, 2020). https://www.aljazeera.com/economy/2020/9/25/uk-bans-ex-cambridge-analytica-boss-for-unethical-services
[^44]: House of Commons Digital, Culture, Media and Sport Committee, *Disinformation and "fake news": Final Report*, HC 1791, February 18, 2019, paragraphs 285 to 290, 296 and notes 327 to 329 and 338. https://publications.parliament.uk/pa/cm201719/cmselect/cmcumeds/1791/1791.pdf
[^45]: Companies House, EMERDATA LIMITED (company number 10911848), overview, officers, persons with significant control and insolvency pages, viewed October 1, 2026; personal appointments pages for Jennifer Lynne Mercer, Rebekah Anne Mercer, Jacquelyn James-Varga and Bradley David Golub. https://find-and-update.company-information.service.gov.uk/company/10911848
[^46]: Companies House, insolvency pages for SCL GROUP LIMITED (05514098), SCL ELECTIONS LIMITED (08256225) and CAMBRIDGE ANALYTICA(UK) LIMITED (09375920), viewed October 1, 2026 (administration May 3, 2018 to April 17, 2019; compulsory liquidation, petition August 13, 2018, winding up commenced April 17, 2019 and concluded September 1, 2025; dissolved January 31, 2026, January 31, 2026 and January 30, 2026). https://find-and-update.company-information.service.gov.uk/company/05514098/insolvency