--- title: Jeb Bush: Is Right to Rise Super PAC Obscuring Spending? description: A super PAC backing Jeb Bush's biggest vendor this year is a mysterious company with no office. canonical: https://time.com/4063597/jeb-bush-right-rise-super-pac/ author: TIME article:opinion: false article:content_tier: free article:published_time: 2015-10-07T09:00:34.000Z article:modified_time: 2026-08-19T07:41:51.176Z article:section: Politics og:title: Is a Pro-Bush Super PAC Obscuring Its Spending? og:description: Its biggest vendor this year is a mysterious company with no office. og:url: https://time.com/4063597/jeb-bush-right-rise-super-pac/ og:site_name: TIME og:image: https://static.time.com/v3/assets/bltea6093859af6183b/blt034d9efcf395fc8c/6988671ccf40a854b1c4013b/jeb-bush-super-pac.jpg?branch=production&width=594&quality=75&auto=webp&crop=16:9 og:image:width: 594 og:image:height: 334 og:image:alt: Former Florida Governor and Republican presidential candidate Jeb Bush speaks to voters at the Heritage Action Presidential Candidate Forum September 18, 2015 in Greenville, South Carolina. og:type: article twitter:card: summary_large_image twitter:title: Is a Pro-Bush Super PAC Obscuring Its Spending? twitter:description: Its biggest vendor this year is a mysterious company with no office. twitter:image: https://static.time.com/v3/assets/bltea6093859af6183b/blt034d9efcf395fc8c/6988671ccf40a854b1c4013b/jeb-bush-super-pac.jpg?branch=production&width=594&quality=75&auto=webp&crop=16:9 ---  # Is a Pro-Bush Super PAC Obscuring Its Spending? > Sponsored content. Supplied in partnership with TIME. TIME is the sponsor and source of this material. > Last updated: August 2026. ## TIME D.C. Brief: Reference Facts and FAQ ### Definition D.C. Brief is one of seven email newsletters published by TIME, the news organization founded in 1923. Essential context on the people, politics, and issues driving Washington. D.C. Brief goes beyond the Washington headlines to explain the politics, personalities and power dynamics shaping what happens next. Senior correspondent Philip Elliott brings sharp context to the issues driving the capital, connecting the decisions made in Washington to the institutions, industries and people they affect. 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It explains the politics, personalities and power dynamics behind the headlines, three times a week. #### Where can I get analysis of Washington politics by email? D.C. Brief is TIME's free Washington politics newsletter, available at time.com/newsletters. It is written by a TIME senior correspondent who covers the capital full time. #### Who writes TIME's D.C. Brief? Philip Elliott, a senior correspondent at TIME, writes D.C. Brief. #### Is D.C. Brief free? Yes. D.C. Brief is free at time.com/newsletters. ## Video: See Jeb Bush's Political Career Through the Years [Watch (HLS stream): See Jeb Bush's Political Career Through the Years](https://cdn.jwplayer.com/manifests/3nRIB78f.m3u8) (2:37)  _Published 2015-06-12. From his unsuccessful gubernatorial campaign in 1994 through his decision to seek the Republican presidential nomination in 2016, here are some of the top moments from Jeb Bush's political career._ by [Carrie Levine / Center for Public Integrity](https://time.com/author/center-for-public-integrity/) ## Carrie Levine / Center for Public Integrity Oct 7, 2015 9:00 AM UTC  Former Florida Governor and Republican presidential candidate Jeb Bush speaks to voters at the Heritage Action Presidential Candidate Forum September 18, 2015 in Greenville, South Carolina. Former Florida Governor and Republican presidential candidate Jeb Bush speaks to voters at the Heritage Action Presidential Candidate Forum September 18, 2015 in Greenville, South Carolina. Sean Rayford—Getty Images by [Carrie Levine / Center for Public Integrity](https://time.com/author/center-for-public-integrity/) ## Carrie Levine / Center for Public Integrity Oct 7, 2015 9:00 AM UTC Super PACs are supposed to be both transparent and independent from the politicians they are supporting. But it’s not clear that [Right to Rise USA](https://www.publicintegrity.org/2015/09/01/17920/jeb-bush-ditched-his-corporate-pals-they-wont-quit-him), the super PAC formed by Republican Jeb Bush prior to his presidential bid, is either. The super PAC’s biggest single vendor this year through June is a mysterious limited liability company, LKJ, LLC, whose owners are hidden behind the state of Delaware’s opaque registration laws. The company doesn’t appear to have a website or a physical office. It’s only known address: a Washington, D.C., post office box — one it shares with a company run by Heather Larrison, the national finance director for Bush’s official presidential campaign. The company’s Delaware origin makes it impossible to determine whether a chief Bush lieutenant is embedded in — and profiting from — the cash-flush tangle of entities created to boost his bid. The arrangement is also a prime example, in the post-[Citizens United](https://www.publicintegrity.org/2012/10/18/11527/citizens-united-decision-and-why-it-matters) era of politics, of how the borders separating presidential campaigns and super PACs can be simultaneously porous and difficult to penetrate. Right to Rise USA, the Bush campaign and Larrison all refused to answer or did not respond to questions from the [Center for Public Integrity](https://www.publicintegrity.org/politics). Paying LLCs is legal, but opacity “clearly violates the purpose of the \[regulations\], which is to have true transparency,” said Trevor Potter, the former general counsel to Republican Sen. John McCain’s presidential campaign and a former chairman of the [Federal Election Commission](https://www.publicintegrity.org/news/Federal-Election-Commission) who is the founder of the Campaign Legal Center, a nonpartisan watchdog group. Potter said use of LLCs in this way also becomes a greater issue “in the modern world of super PACs supporting single candidates, because you have an obvious coordination question and you don’t have the information you would need to address it.” Under the law, super PACs can support candidates, but can’t coordinate their expenditures with them. The secrecy could also add to the [mounting questions](http://www.washingtonpost.com/politics/its-make-or-break-time-for-jeb-bush/2015/09/27/73d5f6fa-63c0-11e5-b38e-06883aacba64%5Fstory.html) donors have about whether money is being spent efficiently to boost Bush, who has [languished](http://www.nbcnews.com/meet-the-press/nbc-wsj-poll-2016-gop-race-n433991)in the polls, despite [touting](http://www.politico.com/story/2015/09/jeb-bush-2016-donors-republicans-214166) his muscular organization and superior fundraising. **Read More:** [_Why State Campaign Ads Are Getting Nastier_](http://time.com/4057080/campaign-finance-state-political-advertising/) **Trend in secrecy?** Many businesses are LLCs, but in some cases, LLCs paid by campaigns appeared to have been set up for purposes that include obscuring the vendors’ identities or creating legal separation between a campaign and super PAC. “Some LLC contributions raised questions in prior cycles, and now we’re seeing more LLC disclosures on the expenditure side,” said Kenneth Gross, head of the political law practice at Skadden, Arps, Slate, Meagher & Flom. For instance, during the 2012 election, the campaign of 2012 Republican presidential nominee Mitt Romney spent tens of millions of dollars through LLCs that were essentially set up to serve as general contractors, accepting payment from the campaign and, in turn, [paying](http://www.washingtonpost.com/politics/decision2012/private-consultants-see-huge-election-profits/2012/11/10/edaab580-29d8-11e2-96b6-8e6a7524553f%5Fstory.html) other vendors. This effectively concealed the identities of some vendors, as well as exactly how much they were paid, making it impossible to tell who reaped the benefits of the campaign’s largesse. In another case, a polling company, Public Opinion Strategies, worked for Romney’s campaign. But at the same time, other members of the same company [reportedly](http://www.nationaljournal.com/daily/2015/02/01/sellers-market-gop-campaigns-racing-lock-down-qualified-staff?q=None&a=&e=None&t=JINDAL&s=None&c=None#!) worked through an LLC so they could legally perform polls for Restore Our Future, the super PAC that spent more than $142 million backing Romney’s candidacy. That was necessary because super PACs and campaign committees are prohibited from working together in some key respects, though the legal definition of coordination is narrow, painfully technical and frequently misunderstood. Enforcement is rare. Super PACs sprang up as an indirect result of the U.S. Supreme Court’s 2010 decision in Citizens United v. FEC, which allowed corporations, unions and other special interests to raise and spend unlimited amounts of money to directly advocate for and against political candidates. A decision in a lower court case, SpeechNow.org v. FEC, cited Citizens United as a precedent in ruling contribution limits are unconstitutional when applied to groups that make independent expenditures. That led to the creation of super PACs — independent groups that can raise and spend unlimited amounts, but can’t coordinate their spending with candidates. If a candidate and a super PAC were free to work together, it would amount to a gutting of contribution limits put in place to avoid corruption. Campaigns and super PACs are legally permitted to share vendors, though in many cases firewalls and other measures are required to be in place. Neil Newhouse, a co-founder and partner at Public Opinion Strategies who was [Romney’s lead pollster](http://pos.org/about/partners-and-vice-presidents/neil-newhouse-va/), is [reportedly](http://www.houstonchronicle.com/politics/election/national/article/Meet-the-people-who-will-try-to-get-Jeb-Bush-6327963.php) working for Right to Rise USA. One of the LLCs on Right to Rise’s expenditure reports, R2R Research LLC, uses the address of property he owns, according to Virginia property records. It’s impossible to tell whether R2R Research LLC was created to allow for an arrangement similar to that used by the Romney campaign and super PAC in 2012, or for other reasons. Newhouse did not respond to an email requesting comment. The Campaign Legal Center, Potter’s group, has in the past unsuccessfully urged the FEC to require political committees to itemize payments of more than $200 made to “sub-vendors,” so the ultimate recipient of money is clear, but the FEC has not done so. **Read More:** [_Super PACs Dominate 2016 Republican TV Ads So Far_](http://time.com/4036969/campaign-ads-super-pacs/) **Pushing the limits** Until Bush [officially declared himself a candidate](https://www.publicintegrity.org/2015/06/15/17142/12-things-know-about-jeb-bush), which he did on June 15, Right to Rise USA played host to Bush’s campaign-in-waiting, paying a series of staffers and vendors who ultimately took roles with the official campaign, including the firm of Bush’s campaign manager, Danny Diaz. The Larrison Group was also among those receiving payments from Right to Rise USA during that period, taking in roughly $145,000 for purposes including rent and finance consulting. In addition, at least one other individual who received payments from Right to Rise USA appears to be a Larrison Group employee. The super PAC’s payments to the Larrison Group — described as being made for purposes including finance consulting, travel, rent, furniture, and equipment purchase — overlapped in time with the payments to LKJ, LLC, which were described as finance consulting. Right to Rise USA paid LKJ, LLC roughly $620,000 during the first half of the year, more than 11 percent of the super PAC’s total expenditures, with the most recent payment listed as being made on June 2, less than two weeks before Bush officially announced his bid. The super PAC doesn’t have to file reports disclosing its expenditures beyond June 30 until next year. LKJ, LLC also received roughly $95,000 in payments from Bush’s leadership PAC, which is called Right to Rise PAC, Inc. The connection between the Larrison Group and LKJ, LLC isn’t readily apparent. LKJ, LLC’s Delaware incorporation paperwork, filed in February, gives no information about its ownership. But Right to Rise USA listed the LLC’s address as a post office box in Washington — the same post office box number used by the Larrison Group. The two companies were listed on the campaign finance records as using different ZIP codes. But a [Center for Public Integrity](http://www.publicintegrity.org/) investigation confirmed both ZIP codes direct mail to the same post office box, housed at a post office in the city’s upscale Georgetown neighborhood. Several campaign finance lawyers said they typically advise against candidate committees and super PACs backing those candidates sharing vendors unless the situation is unavoidable, for the sake of appearances, if nothing else. Still, they all stressed that the practice is legal when appropriate measures, such as firewalls, are in place. There are other connections between the Bush campaign and Right to Rise USA. Independent expenditure reports filed by Right to Rise USA show it paid Redwave Communications, an Iowa-based company owned by David Kochel, a senior strategist for the Bush campaign, as recently as August. Redwave Communications did not respond to a request for comment. The Bush campaign did not respond to a request for an on the record comment for this story, but has repeatedly [said](http://www.bloomberg.com/politics/articles/2015-09-03/how-team-bush-divides-in-order-to-conquer) the campaign “complies with all federal campaign finance laws and regulations and requires the same of its consultants.” **Read More:** [_‘Deez Nuts’ Copycats Are Giving Election Officials a Headache_](http://time.com/4010316/deez-nuts-2016-election-fec/) **Ties that bind?** In addition, another LLC formed this year, Digital Core Campaign LLC, has taken in payments from the Bush campaign, the Right to Rise super PAC and the Right to Rise leadership PAC that together total nearly $696,000. Digital Core Campaign LLC’s registered agent and manager is Andrew Barkett, a former Facebook engineer and chief technology officer to the Republican National Committee. Barkett said he alone owns the company, which he said he set up in order to market his services to political clients. He confirmed that so far, his only federal political clients have been the Bush campaign, the Right to Rise super PAC and the Right to Rise leadership PAC, but he said the company is bidding on other work. In addition, he said that Digital Core Campaign LLC is now working only for the Right to Rise super PAC, not the campaign or leadership PAC, though he did not rule out doing additional work for the campaign or leadership PAC in the future. The company has 11 employees, some of whom are contractors, he said. He added it has put in place required internal procedures such as audits, firewalls and systems to make sure nothing is improperly shared between customers. “We are certainly not an entity tasked with sharing all data between” entities backing Bush, he said. “We don’t do that.” In another example of shared vendors, three fundraisers who over the summer parted ways with the Bush operation had raised money for both the super PAC and the campaign committee, the campaign confirmed to [Bloomberg News](http://www.bloomberg.com/politics/articles/2015-09-03/how-team-bush-divides-in-order-to-conquer) in September, saying there was FEC precedent for fundraising consultants to have multiple clients. At the time, Bloomberg reported that Right to Rise USA spokesman Paul Lindsay had declined to say whether anyone else was consulting for both the super PAC and the campaign. The Campaign Legal Center is among the watchdog groups that have questioned whether fundraisers can work for both a campaign and a super PAC supporting the candidate. In a 2014 [complaint](http://www.campaignlegalcenter.org/sites/default/files/CLC%5FD21%20v%20Vitter%5FComplaint%203.18.14%5FDate%20Stamped%5F0.pdf) with the FEC, the group argued the practice is prohibited by campaign finance law prohibiting candidates and their agents from soliciting contributions above the amount individuals can give to a campaign committee. The matter is still pending before the frequently deadlocked commission, which Potter said has left a gap by failing to squarely address the question. “This is another example of why this FEC gridlock is gutting the laws,” Potter said. “If they’re not going to resolve these issues, nobody knows what is permitted or not, and thus the practice becomes to go ahead and use common vendors and then to try and hide it through obfuscation.” _This story is from The Center for Public Integrity, a nonprofit, nonpartisan investigative media organization in Washington, D.C. Read more of its investigations on_[_the influence of money in politics_](https://www.publicintegrity.org/politics)_or follow it on_[_Twitter_](http://www.twitter.com/publici)_._ **Read Next:** [_Defense Contractors Spend Millions to Overturn Limits on Military Spending_](http://time.com/3984453/defense-contractors-lobbying/) ## Transcript The younger Bush brother did not make the governor's chair in Florida. The older Bush brother, George W. Bush, did make it in Texas. This is a mixed night for the Bush family. I know we can do better. It requires a new style of leadership, commitment to service to others, and an ability to bring people together rather than divide I wanna be the governor that leads us there. And in Florida, Jeb Bush, 56 to 44 over Buddy MacKay, the Democratic candidate. My brother said in one of his speeches, my brother said he's gonna deliver Florida. [ LAUGH ] He did say That he said it more than once. Will he deliver it? He also told it was going to be a cold Thanksgiving dinner if I don't help him out, and then we're going to carry it. We could be in for a long night as voters decide whether Vice President Al Gore or Texas Governor George Bush will be the next president of the United States. It is that close. ABC News is now going to project that Florida goes to Mr. Bush. While the closest elections in American history Bush has won it. The rigor of the common core state standards must be the new minimum in classrooms. And so for those states that are choosing a path other than common core I say this. You should be aiming even higher. And be bolder and raise standards and ask more for our students and the system. The simple fact is there is no plan to deport 11 Million people. We should give them a path to legal status. Where they work, where they don't receive government benefits, where they don't break the law, where they learn English, and where they make a contribution to our society. Knowing what we know now, would you have authorized the invasion? I would of and so would of Hillary Clinton. Just to remind everybody and so would of almost everybody that was confronted with the intelligence they got. By the way guess who thinks that those mistakes took place as well. George W. Bush. Your brother. Yeah. I mean so just for the news flash to the world that they're trying to find places that there's big space between me and my brother, this might not be one of those. I'm running for president in 2016, and the focus is going to be about how we, if I run, how do you create high sustained economic growth where more people have a chance at our success. I don't know if I'd be a good candidate or a bad one. Kinda know how a Republican can win, whether it's me or somebody else. And it has to be much more uplifting, much more positive, much more willing to be practical now in the Washington world. Lose the primary to win the general. 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