Bobby

“Audio: "Paid for by Ellen." (29.2s) — truncated/garbled. On-screen: [28.4s] "PA PAID FOR BY TLIC ES" (5.6% height, 0.0s visible), [28.8s] "PAD FOR BY LLIN", [29.2s] "PAID FOR BY ILLINGISEUTUR OR", [29.6s] "PAD FOR BY ILINGIS" — no address/phone/website and no "Not authorized by any candidate or candidate's committee."”  at 28.4s

Trigger: The ad is designated an electioneering communication, expressly identifies a clearly identified federal candidate for a covered race ("That someone is Julianna Stratton and she's running for US Senate"), and estimated reach (10,000,000) far exceeds the 50,000 threshold for House/Senate races. Being classified as an EC presupposes airing inside the 60-day/30-day pre-election window, and nothing in the transcript or on-screen text contradicts that (references to Gov. Pritzker, an active Illinois Senate campaign). I therefore treat the rule as applying. Compliance: The disclaimer is materially deficient on multiple independent grounds. (1) Content: the audio disclaimer is only a partial "Paid for by ..." with no permissible address, phone, or website, and there is no "Not authorized by any candidate or candidate's committee" statement anywhere in the audio or on-screen text — required here because the sponsor is a non-authorized PAC (Illinois Future PAC) and the ad plainly advocates for the candidate. (2) Timing: the written disclaimer fragments appear only from ~28.4s to the end of the spot, roughly 1.2 seconds of cumulative on-screen presence, well short of the 4-second minimum. (3) Size: the payor-line text is measured at approximately 5.6% of frame height in the frames where it appears, which would meet the 4% floor, but that does not cure the duration and content failures. Even allowing generous latitude for OCR/ASR garbling of the sponsor name ("Ellen" / "ILLINGISEUTUR" almost certainly = "Illinois Future PAC"), the missing contact information, missing non-authorization statement, and sub-4-second display cannot be excused as transcription noise — no text resembling "not authorized" or a URL/address appears at any timestamp. Fail.

“[28.4s] "PA PAID FOR BY TLIC ES" ... [29.2s] "CHOO CH OS MIANA___ . .5. SEN PAID FOR BY ILLINGISEUTUR OR" ... [29.6s] "EEE - AE CHOO CI PAD FOR BY ILINGIS (AD ANALYSIS"”  at 28.4s

A sponsorship identification is in fact present on screen: OCR fragments from 28.4s through 29.6s repeatedly read "PAID FOR BY ILLINOIS FUTUR...", which is legally equivalent in substance to the template phrase "This advertisement was sponsored, paid for, or furnished... by Illinois Future PAC" (the audio at 29.2s likewise says "Paid for by..."). So the substantive content requirement is arguably met, and the largest rendering (20.6% of frame height) clears the 4% height minimum. However, the rule's one_time_minimum timing requirement of 4 seconds of continuous visibility is not satisfied: the disclaimer text first appears at 28.4s and the last captured frame is at 29.6s, giving roughly 1.2 seconds of on-screen presence in an ad whose audio ends at ~29-30s. Each captured frame is logged with 0.0s visible duration, and there is no earlier occurrence of any sponsor identification anywhere in the timeline. Because the sponsor ID is crammed into the final ~1.2 seconds rather than held for at least 4 seconds, the ad fails this rule on timing even though the wording itself would qualify.

“[29.2s] Paid for by Ellen. (audio; on-screen at 28.4s-29.6s: "PAID FOR BY ILLINOIS FUTUR[E PAC]")”  at 29.2s

47 CFR 73.1212(d) applies only where films, records, transcriptions, talent, scripts, or other material/services for a political or controversial-issue program are *furnished* to the station (free or at nominal charge). The evidence here shows an ordinary purchased 30-second electioneering spot: the ad closes with a paid-for attribution ("Paid for by [Illinois Future PAC]" in both audio — ASR-garbled as "Ellen" — and on-screen text), and the metadata shows sponsor spend of $100,000 for paid placement. Nothing in the transcript or on-screen text indicates the material or any talent/script/service was furnished to the broadcaster rather than paid for as commercial time, so the trigger condition (uses_furnished_material) does not appear to be met and the beginning-and-end announcement obligation of (d) is not engaged; the applicable requirement would be the single paid sponsorship identification under 73.1212(a)/(e). Note for the human reviewer: even if (d) were deemed to apply, the ad is ~30 seconds — well under the 300-second threshold in the timing params — so only one announcement is required, and the closing "Paid for by Illinois Future PAC" is legally equivalent to the required sponsorship attribution (it identifies the true sponsor and discloses paid sponsorship, which is what 73.1212 requires; the "sponsored, paid for, or furnished, in whole or in part, by" template wording is not mandated verbatim). So the ad would pass on timing/content grounds regardless; the only genuine open question is whether any material was in fact station-furnished, which cannot be determined from the audio/video alone and requires station documentation.