Newly Published Cambridge Analytica Documents Show Unlawful Support for Trump in 2016

Donald Trump speaking at a podium wearing a 'Make American Great Again' hat surrounded by people.
Donald Trump speaking with supporters at a campaign rally at Fountain Park in Fountain Hills, Arizona on March 19, 2016. Photo by Gage Skidmore.

A newly published trove of Cambridge Analytica emails and other documents from the 2016 election demonstrate how the data firm operated as a tool for a billionaire family to unlawfully influence U.S. politics and help elect President Trump.

Campaign Legal Center (CLC) has supplemented its 2016 complaint to the Federal Election Commission (FEC) with the newly available evidence.

The 757 pages of documents, published online by the Internet Archive, provide an inside view into Cambridge Analytica’s global and domestic operations in 2015 and 2016.

Many of the materials underscore how Cambridge Analytica, which was founded and owned by the billionaire Mercer family, facilitated illegal coordination between Make America Number 1, a Mercer-backed super Political Action Committee (PAC) supporting Trump’s 2016 election, and the 2016 Trump campaign.

Among the new details about the nature and scope of Cambridge Analytica’s activities are:

  • A never-before-published 27-page post-election report from February 2017 shows that Cambridge Analytica claimed credit for creating, producing, and distributing ads for the Trump campaign, which included “5,000+ ad campaigns” on behalf of Trump that generated “1.5 billion impressions.” According to Cambridge Analytica, its pro-Trump “persuasion” ads corresponded with a 3% average favorability increase for Trump and get-out-the-vote ads “drove a 2% increase in voters submitting absentee ballots.”
  • At the same time that Cambridge Analytica was producing the Trump campaign’s own ads, it was also conducting polling and developing “all of the creative” for the supposedly independent pro-Trump super PAC, Make America Number 1 (also known as “Defeat Crooked Hillary”). For example, in the final days of the 2016 election, Cambridge Analytica targeted Michigan with “72 hour voter turnout” videos on behalf of the super PAC that generated 6 million impressions; according to Cambridge Analytica, “If [the super PAC] had not made the final GOTV investment in the state, we can reasonably argue Trump would not have achieved his historic victory in Michigan.”

In 2018, Cambridge Analytica captured headlines after revelations that it misused the personal data of millions of Facebook users to build “psychographic” voter profiles to influence elections. The news put Facebook’s data privacy policies under new scrutiny and led to U.S. and U.K. investigations of Cambridge Analytica and its eventual dissolution.

What’s often overlooked, however, is how Cambridge Analytica operated to unlawfully deepen the impact of the Mercers’ political spending. The new documents offer additional insight into how Cambridge Analytica helped a big-money pro-Trump outfit cross legal lines.

Cambridge Analytica Functioned as a Conduit for Illegal Coordination

Cambridge Analytica was founded with a $15 million investment from hedge fund billionaire and GOP megadonor Robert Mercer. Its board included Robert Mercer’s daughter, Rebekah Mercer, and their longtime associate, Steve Bannon.

The newly published emails indicate that Cambridge Analytica staff understood that they were ultimately working for the Mercers; in fact, the firm’s New York office was shared with another Mercer venture, Reclaim New York. Cambridge Analytica staff also understood that Mercer-backed super PACs were expected to contract with the firm.

In one 2015 email, Cambridge Analytica CEO Alexander Nix wrote of Kellyanne Conway, who was heading the Mercer-backed super PAC Keep the Promise (KTP)—later renamed Make America Number 1—that “It was made crystal clear to Kellyanne from the beginning that KTP were to be engaging [Cambridge Analytica].”

Nix also noted that the Mercers installed Conway as the head of the super PAC: “She needs to be (firmly) reminded that the people that made this decision are the same people who empowered her as Head of the KTP PAC!”

In the final stretch of the 2016 election, the Mercers swung their support behind Trump—and, with it, millions in spending from their renamed super PAC, Make America Number 1, which was contracting with Cambridge Analytica. At the Mercers’ request, the Trump campaign also hired Cambridge Analytica.

Such an arrangement could unlawfully deepen the impact of the Mercers’ political spending.

A megadonor like Robert Mercer may only contribute millions to a super PAC if it operates independently of—and does not coordinate with—the candidate that it supports.

By the Mercer-owned Cambridge Analytica simultaneously working for the campaign and the super PAC, it was in a position to use strategic information gained from its work for Trump to develop and target the super PAC’s ads supporting Trump.

Federal law limits how a vendor may work for both a candidate and a super PAC backing that candidate. Unless a “common vendor” like Cambridge Analytica creates and complies with an internal firewall separating its work for the candidate from the work for the super PAC, it can act as a conduit for unlawful coordination.

Usually, it can be difficult to assess whether a vendor firewalled their work for the campaign from the super PAC because companies are not required to make their firewall policies public, and they tend to avoid disclosing details about internal operations.

Yet the newly published documents suggest a striking overlap between Cambridge Analytica’s work for Trump and for the Mercer-backed pro-Trump super PAC, which indicates that any firewall policy was not followed.

In one email, a Cambridge Analytica employee even confused the firm’s work for Trump and for the pro-Trump super PAC. Another document shows that Cambridge Analytica listed both the Trump and super PAC accounts on a shared project calendar.

The materials also show that the super PAC’s ads created by Cambridge Analytica were strikingly consistent with the message, themes, and content of ads run by the Trump campaign itself. For example, the ads on the left were run by the Trump campaign while the ads on the right were Cambridge Analytica-produced ads from the super PAC:

Trump campaign and Cambridge Analytica anti Hillary Clinton ads side-by-side for comparison

Digital ads in the 2016 election cycle were not publicly available, so these materials offer a rare glimpse into the digital ad campaigns actually created by Cambridge Analytica—and strongly indicate that the firm acted as a conduit for unlawful coordination.

Other Deep Ties Between the Super PAC and the Trump Campaign

Cambridge Analytica also presented other opportunities for illegal coordination. The firm was founded, owned, and managed by the Mercer family, who also funded and managed the pro-Trump super PAC. They requested that Trump hire the firm as a condition of their support.

However, not only did the Trump campaign hire Cambridge Analytica at the request of the Mercers, it also hired Cambridge Analytica board member and part-owner Steve Bannon as campaign CEO at the request of the Mercers.

The documents show that before joining the Trump campaign, Bannon had been involved in Cambridge Analytica’s day-to-day operations. Emails show, for example, that Bannon pitched the firm’s services to Arron Banks, the co-founder of a campaign for Britain to leave the European Union.

Bannon kept an ownership stake in Cambridge Analytica throughout the 2016 election, and emails indicate that Cambridge Analytica staff continued to refer to Bannon as “our very own” through 2017.

Meanwhile, the documents show that during the same period that Bannon was CEO of the Trump campaign, Cambridge Analytica worked with Bannon’s production company, Glittering Steel, to produce multiple super PAC ads attacking Clinton. One email from a Cambridge Analytica staffer referred to Glittering Steel as “our production partner.”

In other words, the Mercers’ pro-Trump super PAC contracted with one company partially owned by Trump’s campaign CEO, which subcontracted with another company owned by Trump’s campaign CEO, to produce and target ads supporting Trump. Those super PAC ads cannot be considered “independent” of the Trump campaign.

This election cycle, it could be even more difficult to identify whether the Trump campaign is similarly coordinating with a supportive super PAC. In 2020, the Trump campaign has structured its spending to disguise the identity of many of its vendors, meaning we don’t know whether the campaign and its super PAC are contracting with the same entities.  

Read CLC’s supplemental complaint.

Brendan directs CLC’s work before federal regulatory agencies, such as the Federal Election Commission (FEC).