Oregon Secretary of State
Sent Via Email Only To: [email protected]
February 15, 2022
Dear Elections Division:
I am writing a formal complaint because I believe an individual and two political campaigns are violating Oregon campaign finance rules by not reporting transactions in accordance with the 2022 Campaign Finance Manual produced by the Oregon Secretary of State adopted by Oregon Administrative Rule No. 165-012-0005. An individual named Edward Goehring is purchasing political advertising on Facebook for the benefit of two separate Lane County Commissioner races, Joe Berney and Dawn Lesley (See Section 2 below).
According to Mr. Goehring’s personal website, www.edwardbgoehring.com, he is a “Social media manager for political campaigns, community organizations, businesses.” Mr. Goehring runs several community information pages on Facebook but the page in question is the “Lane County Tribune.” Past Orestar records have stated that Mr. Goehring has worked on several political campaigns in the Eugene area. Additionally, Mr. Goehring is registered as Independent Expenditure Filer (ID 19502) but hasn’t reported any transactions.
Mr. Goehring has and is continuing to run political ads from the “Lane County Tribune” Facebook page that support or oppose candidates. These advertisements appear to benefit two commissioners’ races, Joe Berney, Friends of Joe Berney (PAC ID 18745) and Dawn Lesley, Dawn Lesley for Action (PAC ID 21530). According to Facebook’s new page transparency public advertising database (please see the attached link), Mr. Goehring has run 25 advertisements for the benefit of the two races since the beginning of 2022, thirteen advertisements to benefit Berney, twelve advertisements to benefit Lesley. During the last 30 days (Jan 7- Feb 5) the “Lane County Tribune” placed $699 worth of advertising.
I believe these advertisements for the benefit of Joe Berney should be reported as an in-kind and the advertisements for the benefit of Dawn Lesley are either an independent expenditure or in-kind. I am unaware of any connection between Mr. Goehring and Lesley, however, the “Lane County Tribune” page has posted the same content as “Re-Elect Lane County Commissioner Joe Berney” page nearly simultaneously, which indicates it is the same person posting for both pages. This indicates that there is communication between Mr. Goehring and Joe Berney, and should be reported as in-kind contributions. I have provided three instances of this in “Section 1” in the screenshots below. Please note the timestamps.
The 2022 Campaign Finance Manual produced by the Oregon Secretary of State, page 12 states the following: A person must register as an Independent Expenditure Filer if any of the following are true:
- a person makes independent expenditures of more than $250 in a calendar year for a communication to support or oppose any candidate or measure; B. a person makes independent expenditures of $250 or more for a communication that refers to a clearly identified candidate or measure that will appear on the ballot and the communication is published and disseminated to the relevant electorate within 60 calendar days before the primary election, 120 calendar days before the general election, or 90 calendar days before any other election; or C. a person makes independent expenditures more than $250 for a communication that refers to a political party and the communication is published and disseminated to the relevant electorate within 60 calendar days before the primary election, 120 calendar days before the general election, or 90 calendar days before any other election.
Additionally, see page 58 of the aforementioned manual describing what constitutes an in-kind donation or an independent expenditure.