Thread by @josh_nelson

Google intends to launch a pilot program allowing political campaigns to send unsolicited spam email to Gmail users without being subject to its spam filtering algorithm.

The FEC will soon be weighing in on whether this constitutes an in-kind contribution to campaigns. 1/24

In a comment I just submitted to the FEC, & in the thread below, I make the case that Google’s campaign spam proposal would in fact constitute an in-kind contribution to Republican campaigns.

Continue reading for highlights, or view my full comment here: civicshout.com/gmail-spam-com…

Google’s proposal to allow political campaigns to send spam without consequence would directly undermine Democrats’ adherence to best practices and our significant monetary investments in the opt-in status quo. 3/24

Democrats have spent the past 20 years developing infrastructure and adhering to email deliverability best practices to build a significant advantage in small dollar online fundraising. 4/24

These investments include maintaining training programs on best practices for digital staff, developing an ecosystem of vendors, consultants & technology providers dedicated to growing opt-in email lists, & investing real $ in acquiring opt-in permission to email supporters. 5/24

All of these investments were made in order to adhere to well-established best practices for email deliverability, including those specified by Gmail itself. 6/24

As a Gmail spox told @lachlan in April in response to Republican complaints of bias in spam filtering, “Gmail users can move messages to spam, or to any other category. Gmail automatically adjusts the classifications of particular emails according to these user actions.” 7/24

In other words, to the extent that Republican campaign emails are disproportionately landing in Gmail spam folders, it is in large part due to the fact that Republican campaigns are disproportionately sending unsolicited spam that recipients do not want to receive. 8/24

Changing the opt-in email status quo now – particularly just before an election – amounts to penalizing Democrats for making investments in following clearly-established best practices. 9/24

It would give a distinct electoral advantage to Republican campaigns and committees who have ignored those same best practices for years to their own detriment. 10/24

Google’s proposal to allow political campaigns to send unsolicited spam would also reward Republicans' disingenuous claims of Big Tech bias and mimic their preferred policy. 11/24

The proposed pilot program is clearly in response to disingenuous Republican claims that Google and other Big Tech companies are biased against conservative causes. 12/24

Following the release of an academic paper purporting to demonstrate such bias, Republican operatives orchestrated a public relations and advocacy effort designed to pressure Gmail to change its rules to allow campaigns to send unsolicited spam emails. 13/24

The deeply flawed study failed to account for the fact that Republican campaigns are notorious for sending scammy & deceptive emails to people who didn’t sign up to receive them, & that GOP campaigns frequently fail to follow basic email deliverability best practices 14/24

Regardless, Fox News & other right-wing outlets pounced on the study as proof that Gmail was intentionally undermining GOP fundraising efforts. Fox News alone published no less than 4 separate stories promoting the study within a 20-day period in April. 15/24

On April 26, the Republican National Committee, National Republican Congressional Committee and National Republican Senatorial Committee filed a joint complaint formally requesting that the Commission investigate whether Gmail is censoring Republican political emails. 16/24

The very next day, on April 27, Sen. Josh Hawley sent a letter to Google CEO Sundar Pichai accusing the company of “dictating the outcomes of an election” and demanding answers to a series of conspiratorial questions. 17/24

Finally, on June 16, a group of Republican senators introduced the Political BIAS Emails Act. 18/24

This bill would, according to one of the sponsors, “prohibit large email platforms like Google’s Gmail from using filtering algorithms on emails sent from a political campaign unless the owner or user of the email account took action to apply a label such as spam.” 19/24

To date, this legislation has been cosponsored by 28 Republican senators and zero Democratic senators. 20/24

The @FEC should be fully aware that Google’s proposed pilot program is nearly identical in substance to this highly-partisan bill that is part of the Republican agenda and is not supported by a single elected official in the Democratic Party. 21/24

Surely it’s not a coincidence that Google’s July 1 advisory opinion request was made just 15 days after the highly-partisan Political BIAS Emails Act was introduced in the U.S. Senate. 22/24

By implementing the proposed pilot program, which has been described in the press as “a sop to Republicans,” Google would be intentionally catering to the Republican agenda in response to a pressure campaign orchestrated by Republican operatives and politicians. 23/24

For both of the reasons outlined above, I respectfully submit that the Commission must conclude that Google LLC’s proposed pilot program would constitute an in-kind contribution to Republican campaigns and committees. 24/24