Listening To Lobbyists
White House Chief of Staff Susie Wiles’ Former Lobbying Clients Who Have Lobbied The White House This Year
By Jon Golinger
Introduction
“Well, you have to stop listening to lobbyists.”
– Donald Trump, August 20, 2024[1]
During the 2024 Presidential campaign, Donald Trump said he would not listen to lobbyists if he were elected again.[2] However, with Trump’s first big official public act as President-elect, he broke that promise when he announced two days after the election that he was appointing former corporate lobbyist Susie Wiles to be his new White House Chief of Staff.[3] Since the White House Chief of Staff has historically been the gatekeeper for the President and one of the most powerful Presidential advisers and people influencing the operations of the federal government, Trump has undoubtedly been “listening” to Wiles.
This report examines the first batch of federal lobbying disclosures filed in late April 2025 that disclose the federal lobbying activity done during the first three months of the Trump Administration. These disclosures reveal that six of Wiles’ former corporate lobbying clients reported lobbying the White House that Wiles as Chief of Staff oversees between January and March 2025. This included a tobacco company Wiles was lobbying for just last year which is engaged in regulatory and legal battles with the Food and Drug Administration over public health restrictions aimed at preventing kids from smoking.
Since the lobbying reports do not require disclosing who was in any of the lobbyists’ meetings or calls with the White House, we have no way to know whether Wiles was directly involved in discussions related to her former lobbying clients. But this level of access alone – coupled with Trump’s repeal of the Ethics Executive Order that would have required executive personnel such as Wiles to recuse themselves from discussions regarding their former lobbying clients – raises ethical red flags that erode public trust.
Wiles should disclose whether, as White House Chief of Staff, she has been involved in meetings or discussions regarding her former lobbying clients, reveal whether she has been engaged in decision-making about any issues she lobbied the government on, and recuse herself going forward from any matters that could benefit her former clients.
Key Findings
- Six of Wiles’ former lobbying clients have disclosed lobbying White House offices that Wiles oversees – the White House Office and the Executive Office of the President[4] – in the first three months of the Administration. The lobbying reports did not disclose who specifically the lobbyists met with.
- Tobacco company Swisher International, which Wiles represented for five years – and as recently as March 2024 last year – reported lobbying the Executive Office of the President, which Wiles oversees, on issues related to tobacco products, the Food and Drug Administration (FDA), and the Center for Tobacco Products reforms.[5] In addition, a lobbying firm led by Wiles’ daughter also lobbied the Executive Office of the President for Swisher.[6] Swisher has fought the FDA to block restrictions on its sale of flavored cigarettes under the label “Swisher Sweets” with what the FDA has called “youth-appealing flavors” such as grape, cherry, wild cherry, and strawberry.[7]
- Wiles’ other former lobbying clients who disclosed lobbying the White House during January-March 2025 are:
- Mosaic, a fertilizer producer lobbying on critical minerals and trade
- Kruger, a toilet paper and packaging company lobbying on tariffs
- Zeta Global, a digital marketing company lobbying on AI policy
- Citizens for Responsible Energy Solutions, lobbying on tax credits
- General Motors, lobbying on autonomous vehicles and fuel economy
Background
As detailed in Public Citizen’s November 2024 report Meet Susie Wiles,[8] federal lobbying disclosures show that Trump White House Chief of Staff Susie Wiles was a registered federal lobbyist from November 2017 through March 2024.[9] During that time, Wiles was registered to lobby the federal government for 42 different clients, including large corporations, government contractors, and business associations.[10] On behalf of her clients, Wiles was registered to lobby the White House, Congress, and federal agencies.[11]
Wiles’ History as a Federal Lobbyist
As a federal lobbyist, Wiles worked for two lobbying firms: Ballard Partners and Mercury Public Affairs.
Wiles worked at Ballard Partners from 2011 until 2019.[12] Trump’s Attorney General Pam Bondi was a lobbyist for Ballard Partners along with Wiles.[13] A third high-level Trump Administration official, Deputy Director of Presidential Personnel Trent Morse,[14] also lobbied for Ballard Partners.[15] Morse has been involved in the controversial firings by the Trump Administration of inspectors general[16] and independent agency officials such as members of the Federal Trade Commission and National Labor Relations Board.[17]
Wiles’ Lobbying For Swisher Tobacco Company
Wiles worked at Mercury Public Affairs from February 2022 until after she was named Trump’s Chief of Staff in November 2024.[18] At Mercury, federal lobbying disclosures show she was only registered to lobby for one client: SI Group Client Services, aka Swisher Tobacco Company[19], who she had previously lobbied for at Ballard Partners.[20] From January 2023 through March 2024, lobbying disclosures show that Mercury was paid $120,000 by Swisher for Wiles to lobby Congress on tobacco issues involving “FDA regulations.”[21] During this time period, Swisher was engaged in a regulatory and legal battle with the Food and Drug Administration (FDA).[22] Swisher sued to block FDA restrictions on Swisher’s sale of flavored cigarettes that are labeled as little cigars or cigars under the label “Swisher Sweets” with youth-appealing flavors such as grape and banana smash.[23] Several other tobacco regulatory battles remain ongoing.[24]
Lack of An Ethics Executive Order in the Current Trump Administration
On President Trump’s first day in office in January 2025, he revoked an executive order signed by former President Biden that set ethics and lobbying rules for executive branch appointees.[25] For decades, Presidents – including Trump in his first term – have signed Executive Orders creating ethics guardrails that go beyond the requirements of criminal law. For example, President Biden’s Ethics Order, adopted on January 20, 2021[26], required all Executive Branch Personnel to sign an “Ethics Pledge” that legally bound them to abide by a ban on gifts from lobbyists and other ethics restrictions including a revolving door ban for any who were registered lobbyists in the previous two years, requiring them to:
- Refrain, for a period of two years, from participating in any particular matter involving specific parties that is directly and substantially related to their former employer or former clients, including regulations and contracts.
- Refrain from participating in any particular matter or specific issue on which they lobbied within the two years before their appointment.
- Refrain from seeking or accepting employment with any executive agency that they lobbied within the two years before their appointment.
In the recommendations section of Public Citizen’s November 2024 report Meet Susie Wiles,[27] we advised that, in order to guard against ethics problems, Wiles should:
- Disclose the full list of what exactly she did for each client she lobbied the federal government for: the names of the individuals she lobbied, what she asked those individuals to do or not to do, and what resulted from her lobbying.
- Recuse herself from all decision-making involving her past lobbying clients and the federal agencies that are making decisions that affect her lobbying clients.
- Accept a Voluntary Permanent Post-Employment Ban on Lobbying the White House or Federal Government on behalf of any clients after she leaves the White House.
At the time of this report’s release, as far as we are aware, White House Chief of Staff Wiles has done none of these things.
Wiles’ Former Corporate Lobbying Clients Who Have Been Lobbying The White House
- Swisher Tobacco Company[28]
- According to federal lobbying disclosures, Wiles lobbied the federal government from 2019-2024 for tobacco company Swisher International, aka SI Group Client Services, maker of Swisher Sweets cigars and cigarillos.[29]
- Wiles lobbied for Swisher through March 2024 of last year.[30]
- According to news reports, Swisher has for years fought the Food and Drug Administration to block restrictions on its sale of flavored cigarettes that are labeled as little cigars or cigars under the label “Swisher Sweets” with youth-appealing flavors such as grape and banana smash.[31]
- Lobbying disclosure reports filed in April 2025[32] reported that lobbyists for Swisher – including a lobbying firm led by Wiles’ daughter[33] – lobbied the Executive Office of the President, which is overseen by Wiles, and other offices between January-March 2025 on the following subjects:
- Tobacco products and regulation
- Issues related to the Food and Drug Administration
- Issues related to the Center for Tobacco
- General Motors[34]
- According to federal lobbying disclosures, Wiles lobbied the federal government in 2019 for car manufacturer General Motors.[35]
- General Motors donated $1,000,000 to the Trump-Vance Inaugural Committee in March 2025.[36]
- Lobbying disclosure reports filed in April 2025[37] reported that lobbyists for GM lobbied the Executive Office of the President – overseen by Wiles – and other offices between January-March 2025 on the following subjects:
- Tariffs
- Vehicle fuel economy
- Autonomous vehicles
- Cybersecurity
- Citizens for Responsible Energy Solutions[38]
- According to federal lobbying disclosures, Wiles lobbied the federal government from 2017-2021 for energy policy group Citizens for Responsible Energy Solutions (CRES).[39]
- Lobbying disclosure reports filed in April 2025[40] reported that lobbyists for CRES with Ballard Partners, Wiles’ former lobbying firm, lobbied the Executive Office of the President – overseen by Wiles – and other offices between January-March 2025 on the following subjects:
- Clean Energy Tax Credits
- Kruger[41]
- According to federal lobbying disclosures, Wiles lobbied the federal government in 2018 for tissue and toilet paper company Kruger.[42]
- Lobbying disclosure reports filed in April 2025[43] reported that lobbyists for Kruger lobbied the Executive Office of the President – overseen by Wiles – and other offices between January-March 2025 on the following subjects:
- Newsprint and paper pulp tariffs
- The Mosaic Company[44]
- According to federal lobbying disclosures, Wiles lobbied the federal government from 2017-18 for chemical and fertilizer company Mosaic.[45]
- Lobbying disclosure reports filed in April 2025[46] reported that lobbyists for Mosaic lobbied the White House Office – overseen by Wiles – and other offices between January-March 2025 on the following subjects:
- Critical Minerals
- Transportation
- Trade
- Zeta Global[47]
- According to federal lobbying disclosures, Wiles lobbied the federal government in 2021 for digital marketing company Zeta Global.[48]
- Zeta Global donated $200,000 to the Trump-Vance Inaugural Committee in December 2024.[49]
- Lobbying disclosure reports filed in April 2025[50] reported that lobbyists for Zeta Global lobbied the White House Office – overseen by Wiles – and other offices between January-March 2025 on the following subjects:
- Data privacy
- Digital advertising
- Artificial intelligence policy
White House Chief of Staff Susie Wiles’ Former Lobbying Clients Who Lobbied the White House in the First Three Months of 2025
| Wiles’ Former Lobbying Clients | Firms Reporting Lobbying White House in 2025 | Lobbying Issues | Source: Lobbying Disclosure Reports for January-March 2025 |
| Citizens For Responsible Energy Solutions[51] | Ballard Partners (Wiles’ former firm) | Clean energy tax credits. | https://tinyurl.com/rw6tx64t |
| General Motors[52] | General Motors (company lobbyists) | Tariffs, vehicle fuel economy, autonomous vehicles, cybersecurity. | https://tinyurl.com/yc58ds6c |
| Kruger, Inc.[53] | Wise Capital Strategy | Newsprint and paper pulp tariffs. | https://tinyurl.com/3yt8p2eb |
| Mosaic Company[54] | Blue Star Strategies | Critical minerals, transportation, trade. | https://tinyurl.com/5n8vahj8 |
| Swisher Tobacco /
SI Group Client Services[55] |
Continental Strategy; Swisher International (company lobbyists) | Tobacco products and regulation, issues related to FDA and the Center for Tobacco products reforms, and TCJA extension. | https://tinyurl.com/579y38f2; https://tinyurl.com/34pzdad2 |
| Zeta Global[56] | Marble Arch | Data privacy, digital advertising, and artificial intelligence policy. | https://tinyurl.com/wd7kajat |
Recommendations
To guard against lobbying conflicts-of-interest that corrode the public trust, Wiles should:
- Disclose whether she has met with any of her former lobbying clients or lobbyists from her former firms while serving as White House Chief of Staff. If she did, she should disclose the subjects that were discussed and what the lobbyists asked for.
- Reveal whether, as White House Chief of Staff, she has been involved in any discussions or decision-making regarding issues she worked on as a lobbyist.
- Recuse herself going forward from all decision-making involving her past lobbying clients, issues she lobbied on, and any discussions with federal agencies that are actively making enforcement or regulatory decisions that affect her former clients.
Sources
[1] This Past Weekend podcast interview, minute 32:27, August 20, 2024; https://www.youtube.com/watch?v=vC5cHjcgt5g
[2] Id.
[3] “Trump Names Susie Wiles as his White House Chief of Staff,” New York Times, November 7, 2024; https://www.nytimes.com/2024/11/07/us/politics/susie-wiles-trump-white-house-chief-of-staff.html
[4] “What do Cabinet members do,” CBS News, 11/22/24; https://www.cbsnews.com/news/what-cabinet-members-do/; see also “White House Offices Research Guide,” George W Bush Library; https://www.georgewbushlibrary.gov/sites/default/files/2022-09/White%20House%20Offices%20Research%20Guide.pdf
[5] LDA Report filed by Swisher International, Inc. on 4/21/25, https://lda.senate.gov/filings/public/filing/986d3fdb-7524-4235-8ff0-7b153aa28b21/print/
[6] LDA Report filed by Continental Strategy on 4/17/25; https://lda.senate.gov/filings/public/filing/24887031-38f0-4a21-b2e5-fb2a65b077a7/print/; “Katie Wiles is a Director at Continental Strategy,” Continental Strategy website (accessed 4/30/25); https://www.continentalstrategy.com/katie-wiles; “Lobbying firm promotes Katie Wiles as her mother becomes Trump’s chief of staff,” Florida Times-Union, 11/8/24; https://www.jacksonville.com/story/news/politics/2024/11/08/susie-wiles-daughter-katie-promoted-at-continental-strategy/76137658007/
[7] “FDA takes action against four tobacco manufacturers for illegal sales of flavored cigarettes labeled as little cigars or cigars,” FDA news release, 12/9/16; https://www.fda.gov/news-events/press-announcements/fda-takes-action-against-four-tobacco-manufacturers-illegal-sales-flavored-cigarettes-labeled-little
[8] Meet Susie Wiles’ Controversial Lobbying Clients: A Radioactive Waste Dump, Foreign Mining Companies, a Tobacco Company, and more, Public Citizen, 11/15/24; https://www.citizen.org/article/meet-susie-wiles-controversial-corporate-lobbying-clients/; see also “Inside the Lobbying Career of Susie Wiles, Trump’s New Chief of Staff,” NY Times, 11/21/24; https://www.nytimes.com/2024/11/21/us/politics/susie-wiles-trump-lobbying.html; “Trump’s incoming chief of staff is a former lobbyist. She’ll face a raft of special interests,” Associated Press, 11/21/24; https://apnews.com/article/susie-wiles-donald-trump-chief-of-staff-8e820df743aea61bb966f779541c9820;
[9] LDA Reports filed for “Susan Wiles,” accessed November 13, 2024; https://tinyurl.com/354yp2sd; The most recent lobbyist report filed disclosing lobbying activity by Wiles was on April 10, 2024 covering lobbying activity from 1/1/24-3/31/24; https://lda.senate.gov/filings/public/filing/53da428d-ab2e-4be4-95e5-b2f355c6a267/print/
[10] LDA Reports filed for “Susan Wiles,” accessed November 13, 2024; https://tinyurl.com/354yp2sd; FARA Statement filed 1/22/19, stating that Susan Wiles was registering to lobby on behalf of the People’s Democratic Party of Nigeria; https://efile.fara.gov/docs/6415-Short-Form-20190122-94.pdf
[11] Id.
[12] “Inside the Lobbying Career of Susie Wiles, Trump’s New Chief of Staff,” NY Times, 11/21/24; https://www.nytimes.com/2024/11/21/us/politics/susie-wiles-trump-lobbying.html; “Citing health issue, Susie Wiles leaves Ballard Partners,” Florida Politics, 9/17/19; https://floridapolitics.com/archives/305979-citing-health-issue-susie-wiles-leaves-ballard-partners/
[13] LDA Report filed by Ballard Partners, 4/18/19 (listing Wiles and Bondi as Ballard Partners lobbyists for General Motors); https://lda.senate.gov/filings/public/filing/86c4b319-4b43-4369-936e-0559c0127c27/print/; Conflicted Justice: U.S. Attorney General-Nominee Pam Bondi’s Problematic Corporate Lobbying Clients, Public Citizen, 1/8/25; https://www.citizen.org/article/conflicted-justice/
[14] “Ex-Ballard lobbyist lands senior White House personnel spot,” Washington Examiner, 1/23/25; https://www.washingtonexaminer.com/news/white-house/3297599/ex-ballard-lobbyist-senior-white-house-personnel-spot/; “Trent Morse snags White House post,” Florida Politics, 1/23/25; https://floridapolitics.com/archives/717295-personnel-note-trent-morse-snags-white-house-post/
[15] LDA Report filed by Ballard Partners, 4/19/22 (listing Trent Morse as a lobbyist); https://lda.senate.gov/filings/public/filing/9e35c4a8-2e23-4a90-b12c-2d99331f817f/print/
[16] “Trump fires USAID inspector general who released report on impact of agency cuts,” CBS News, 2/12/25; https://www.cbsnews.com/news/trump-fires-usaid-inspector-general/; “How the SEC Responded to Trump’s Inspectors General Purge,” Bloomberg, 4/11/25; https://www.bloomberg.com/news/newsletters/2025-04-11/how-the-sec-responded-to-trump-s-inspectors-general-purge
[17] “Fired FTC commissioners sue Trump administration over ‘indefensible’ terminations,” The Guardian, 3/27/25; https://www.theguardian.com/us-news/2025/mar/27/fired-ftc-commissioners-sue-trump-administration; “Read the Trump Email Firing Member Wilcox and GC Abruzzo,” NLRB Edge, 1/30/25; https://www.nlrbedge.com/p/read-the-trump-email-firing-member
[18] “Mercury Announces Top Republican Political Strategist Susie Wiles as Co-Chair,” Mercury Press Release, 2/7/22; https://www.mercuryllc.com/announcements/mercury-announces-top-republican-political-strategist-susie-wiles-as-co-chair/; “Inside the Lobbying Career of Susie Wiles, Trump’s New Chief of Staff,” NY Times, 11/21/24; https://www.nytimes.com/2024/11/21/us/politics/susie-wiles-trump-lobbying.html
[19] Lobbying Disclosure Registrant Information: Swisher International, Inc., f/k/a SI Group Client Services; https://lobbyingdisclosure.house.gov/lookup.asp?reg_id=44300
[20] LDA Reports filed by Mercury Public Affairs, listing Susan Wiles as a lobbyist only for client SI Group Client Services, aka Swisher Tobacco Company, 2023-2024; https://tinyurl.com/5b94yyvs
[21] Id.
[22] “U.S. Federal Court Cases – Swisher International v. FDA et al.” Campaign for Tobacco-Free Kids (describing Swisher’s lawsuit against the FDA from 2021-2024); https://www.tobaccofreekids.org/what-we-do/us/us-federal-court-cases
[23] “FDA takes action against four tobacco manufacturers for illegal sales of flavored cigarettes labeled as little cigars or cigars,” FDA news release, 12/9/16; https://www.fda.gov/news-events/press-announcements/fda-takes-action-against-four-tobacco-manufacturers-illegal-sales-flavored-cigarettes-labeled-little; “Eleventh Circuit Denies Swisher International’s Request For An Injunction of Further Enforcement by FDA,” Tobacco Law Blog, 2/15/22; https://www.tobaccolawblog.com/2022/02/eleventh-circuit-denies-swisher-internationals-request-for-an-injunction-of-further-enforcement-by-fda/; “Tobacco Companies Speak Out Against FDA Menthol Ban,” NACS Daily News, 4/29/22; https://web.archive.org/web/20220429145405/https://www.convenience.org/Media/Daily/2022/Apr/29/1-Tobacco-Companies-Speak-Out-Against-Ban_GR; Swisher Sweets Banana Smash Cigarillos, Swisher Sweets website (“Swisher Sweets Banana Smash is like a cocktail in paradise – mixed up and ready to go. Sit back and enjoy the smooth blend with smells from the tropics.”); https://swishersweets.com/products/swisher-sweets/?attribute_pa_blend=Banana+Smash&variation_id=227 (last accessed 5/1/25)
[24] “Three Federal Tobacco Regulatory Measures Up For Change in 2025,” The Network For Public Health Law, 1/29/25; https://www.networkforphl.org/news-insights/three-federal-tobacco-regulatory-measures-up-for-change-in-2025/
[25] “Trump axes Biden-era ethics order, lobbying restrictions,” The Hill, 1/22/25; https://thehill.com/lobbying/5101352-trump-axes-biden-era-ethics-order-lobbying-restrictions/
[26] Executive Order 13989 of January 20, 2021; https://www.federalregister.gov/documents/2021/01/25/2021-01762/ethics-commitments-by-executive-branch-personnel
[27] Meet Susie Wiles’ Controversial Lobbying Clients: A Radioactive Waste Dump, Foreign Mining Companies, a Tobacco Company, and more, Public Citizen, 11/15/24; https://www.citizen.org/article/meet-susie-wiles-controversial-corporate-lobbying-clients/
[28] Swisher website; www.swisher.com/businesses/ (last accessed 4/30/25)
[29] LDA Registration for Ballard Partners, listing Susan Wiles as a lobbyist, for client SI Group Client Services, affiliated with Swisher International, filed 4/26/19; https://lda.senate.gov/filings/public/filing/f77e8958-e7c1-47a0-a6a4-95fc87137548/print/; LDA Report for Ballard Partners terminating SI Group Client Services as a client, fled 4/20/22; https://lda.senate.gov/filings/public/filing/6b16ff34-6081-41c3-9d5b-21a81aacc489/print/; LDA Registration for Mercury Public Affairs, LLC, listing Susan Wiles as a lobbyist, for client SI Group Client Services, filed 1/23/23; https://lda.senate.gov/filings/public/filing/f777b504-87cc-4609-a198-e7a67c06de00/print/
[30] LDA Report filed by Mercury Public Affairs, 4/10/24; https://lda.senate.gov/filings/public/filing/53da428d-ab2e-4be4-95e5-b2f355c6a267/print/
[31] “FDA takes action against four tobacco manufacturers for illegal sales of flavored cigarettes labeled as little cigars or cigars,” FDA news release, 12/9/16; https://www.fda.gov/news-events/press-announcements/fda-takes-action-against-four-tobacco-manufacturers-illegal-sales-flavored-cigarettes-labeled-little; “Eleventh Circuit Denies Swisher International’s Request For An Injunction of Further Enforcement by FDA,” Tobacco Law Blog, 2/15/22; https://www.tobaccolawblog.com/2022/02/eleventh-circuit-denies-swisher-internationals-request-for-an-injunction-of-further-enforcement-by-fda/; “Tobacco Companies Speak Out Against FDA Menthol Ban,” NACS Daily News, 4/29/22; https://web.archive.org/web/20220429145405/https://www.convenience.org/Media/Daily/2022/Apr/29/1-Tobacco-Companies-Speak-Out-Against-Ban_GR
[32] LDA Report filed by Continental Strategy on 4/17/25, https://lda.senate.gov/filings/public/filing/24887031-38f0-4a21-b2e5-fb2a65b077a7/print/; LDA Report filed by Swisher International, Inc. on 4/21/25, https://lda.senate.gov/filings/public/filing/986d3fdb-7524-4235-8ff0-7b153aa28b21/print/
[33] LDA Report filed by Continental Strategy on 4/17/25; https://lda.senate.gov/filings/public/filing/24887031-38f0-4a21-b2e5-fb2a65b077a7/print/; “Katie Wiles is a Director at Continental Strategy,” Continental Strategy website (accessed 4/30/25); https://www.continentalstrategy.com/katie-wiles; “Lobbying firm promotes Katie Wiles as her mother becomes Trump’s chief of staff,” Florida Times-Union, 11/8/24; https://www.jacksonville.com/story/news/politics/2024/11/08/susie-wiles-daughter-katie-promoted-at-continental-strategy/76137658007/
[34] General Motors website; https://www.gm.com/ (last accessed 4/30/25)
[35] LDA Reports filed by Ballard Partners, 2019; https://tinyurl.com/ypatheps
[36] Federal Election Commission filing by Trump-Vance Inauguration Committee, Inc., 4/20/25; https://docquery.fec.gov/cgi-bin/forms/C00894162/1889684/f132
[37] LDA Report filed by General Motors on 4/21/25; https://tinyurl.com/yc58ds6c
[38] Citizens for Responsible Energy Solutions website, https://cresenergy.com/ (last accessed 4/30/25)
[39] LDA Reports filed by Ballard Partners, 2017-2021; https://tinyurl.com/2nzvjws8; “Trump Chief of Staff Susie Wiles Lobbied for Nonprofits Backed by Major Funders,” Inside Philanthropy, 11/13/24; https://www.insidephilanthropy.com/home/incoming-trump-chief-of-staff-susie-wiles-lobbied-for-nonprofits-backed-by-major-funders; “Meet the energy players with ties to Trump’s Chief of Staff,” E&E News by Politico, 11/25/24; https://www.eenews.net/articles/meet-the-energy-players-with-ties-to-trumps-chief-of-staff/
[40] LDA Report filed by Ballard Partners on 4/15/25; https://tinyurl.com/rw6tx64t
[41] Kruger website, https://www.kruger.com/ (last accessed 4/30/25)
[42] LDA Reports filed by Ballard Partners, 2018; https://tinyurl.com/22uxvyb6
[43] LDA Report filed by Wise Capital Strategy on 4/17/25; https://tinyurl.com/3yt8p2eb
[44] The Mosaic Company website, https://mosaicco.com/ (last accessed 4/30/25)
[45] LDA Reports filed by Ballard Partners, 2017-2018; https://tinyurl.com/2z6b5skw
[46] LDA Report filed by Blue Star Strategies on 4/17/25; https://tinyurl.com/5n8vahj8
[47] Zeta Global website, https://zetaglobal.com/ (last accessed 4/30/25)
[48] LDA Reports filed by Ballard Partners, 2021; https://tinyurl.com/ypymhytj
[49] Federal Election Commission filing by Trump-Vance Inauguration Committee, Inc., 4/20/25; https://docquery.fec.gov/cgi-bin/forms/C00894162/1889684/f132
[50] LDA Report filed by Marble Arch on 4/14/25; https://tinyurl.com/wd7kajat
[51] LDA Report filed by Ballard Partners on 7/19/21, https://lda.senate.gov/filings/public/filing/bf5944fd-a4d6-4ade-8cda-e022eccd3d2f/print/.
[52] LDA Report filed by Ballard Partners on 7/18/19, https://lda.senate.gov/filings/public/filing/7422400f-128c-48ff-8d1c-4fe00a4ff3de/print/.
[53] LDA Report filed by Ballard Partners on 7/18/18, https://lda.senate.gov/filings/public/filing/453e31c5-5340-4726-a502-d5a730e3409e/print/.
[54] LDA Report filed by Ballard Partners on 4/20/18, https://lda.senate.gov/filings/public/filing/7913ef19-779d-44be-b72c-7e3a4ca59ce6/print/
[55] LDA Report filed by Mercury Public Affairs on 4/10/24, https://lda.senate.gov/filings/public/filing/53da428d-ab2e-4be4-95e5-b2f355c6a267/print/
[56] LDA Report filed by Mercury Public Affairs on 1/19/22, https://lda.senate.gov/filings/public/filing/a162d421-3687-461b-8df7-9d570ff17539/print/.