FTX Trading Ltd. et al, Plaintiffs, against Fair Democracy, Defendant

Tweet by Brian Armstrong @brian_armstrong We get the U.S. election results in 6 days, and no matter how you slice it, it will be the most pro-crypto congress ever. But we're not slowing down post-election. Today I'm announcing that @coinbase has committed another $25M to support Fairshake PAC, which they will use leading up to the 2026 midterms to elect pro-crypto candidates. We're also supporting @standwithcrypto in their stretch goal to reach 4m advocates by the 2026 midterms. The crypto voter is already a force to be reckoned with, but it will continue to grow. We're going to keep showing up to protect our customer's rights and help get sensible legislation passed in major markets around the world.

FEC report showing a $2.5 million contribution by Ben Horowitz to BlackPAC. Aggregate year-to-date contributions by him to this PAC are $2.5 million.

Tweet thread by Paul Grewal (@iampaulgrewal): Seized crypto assets are not Congressionally appropriated funds, period. There is nothing new in the FEC complaint filed by a self-described crypto critic and Public Citizen’s research director, but it is notable that there is no minimum bar to file such a complaint, and this one – filed by individuals with no election law expertise and funded by who exactly? – appears to amount to a press release by another name. 1/4 @coinbase is proud of its hand-in-glove work with federal law enforcement. We remain committed to playing a trusted role for the U.S. Marshals Service’s cryptocurrency services requirement, which is funded by the sale of assets forfeited to the DOJ’s Assets Forfeiture Fund – not congressionally appropriated tax dollars. 2/4 It’s also worth noting that Coinbase has donated to Dem and GOP super PACs equally with $500K to House and Senate funds for each party, respectively, for 2024. White and Public Citizen appear to want to report a political bias which does not exist. 3/4 Very simply, the world view these researchers espouse in this document is not the law, as much as they wish it was. 4/4

Tweet by paulgrewal.eth (@iampaulgrewal) Aug 1, 2024 6:17 PM 1/3 Whether intentional or not, this is misinformation. Coinbase is not a federal contractor under the plain language of 11 CFR 115.1. USMS isn’t paying us with appropriated funds—something it made clear in the public RFP. Quoted tweet by Molly White (@molly0xFFF) July 30, 2024 5:15PM SCOOP: Coinbase appears to have violated campaign finance laws with a $25 million donation to the Fairshake cryptocurrency super PAC, made while they were in active negotiations for a federal government contract. https://citationneeded.news/coinbase-campaign-finance-violation/ Tweet by paulgrewal.eth (@iampaulgrewal) Aug 1 2/3 Image: Screenshot of the Code of Federal Regulations § 115.1 Definitions. (a) A Federal contractor means a person, as defined in 11 CFR 100.10 who— (1) Enters into any contract with the United States or any department or agency thereof either for— (i) The rendition of personal services; or (ii) Furnishing any material, supplies, or equipment; or (iii) Selling any land or buildings; (2) If the payment for the performance of the contract or payment for the material, supplies, equipment, land, or building is to be made in whole or in part from funds appropriated by the Congress. Tweet by paulgrewal.eth (@iampaulgrewal) Aug 1 3/3 Screenshot of a portion of the USMS Contract RFP: All funds associated with this RFP will be paid out of the Assets Forfeiture Fund. The Fund receives proceeds from the sale of property

AWARD PROFILE Contract Summary https://www.usaspending.gov/award/CONT_AWD_15M50024FA4400016_1544_15M50024DA4400010_1544 Share Download Delivery Order (DO) PIID 15M50024FA4400016 In Progress (10 months remain) Unlinked Award Awarding Agency Department of Justice (DOJ) Recipient COINBASE INC 550 WEST 34TH STREET 4TH FLOOR NEW YORK, NY 10001-1304 UNITED STATES Congressional District: NY-12 Related Awards Parent Award Unique Key CONT_IDV_15M50024DA4400010_1544 Dates Today Start Date Jul 01, 2024 Current End Date Jun 30, 2025 Potential End Date Jun 30, 2029 $ Award Amounts $7.0 Million Current Award Amount $7.0 Million Obligated Amount $7.0 Million Potential Award Amount Outlayed Amount $0.00 Obligated Amount $6,978,346.66 Current Award Amount $6,978,346.66 Potential Award Amount $6,978,346.66 View Transaction History Description AFD: CRYPTOCURRENCY MANAGED SERVICES - CLASS 1 BASE YEAR POP JULY 1, 2024 TO JUNE 30, 32025 North American Industry Classification System (NAICS)Code 52 : Fin

CONCLUSION FECA and FEC regulations prohibit a federal contractor from making a contribution to any political committee during the period in which a federal contract is being negotiated or performed. According to the definitions of the prohibited time period outlined in FEC regulations, Coinbase was prohibited from making campaign contributions beginning on March 4, 2024. The prohibition will continue until the completion of performance under the contract or the termination of negotiations (whichever is later). As the contract is still ongoing, Coinbase has been prohibited from making any contributions from March 4, 2024 through to the date of this complaint. Consequently, there is reason to believe Coinbase violated the federal contractor contribution prohibition by making a $500,000 contribution to a hybrid PAC, the Congressional Leadership Fund, and a $24,999,995 contribution to a super PAC, Fairshake, during the period it was negotiating and/or performing its federal contracts. Furthermore, both the Congressional Leadership Fund and Fairshake are aware of the prohibition on accepting contributions from federal government contractors, and may have violated FECA and FEC regulations if they had reason to believe Coinbase was negotiating a federal contract at the time they solicited and/or accepted the contributions.

A Coinbase spokesperson declined to answer questions about which entities were associated with the government contract or the political contribution, or to respond to broader inquiries about the apparent campaign finance violation, stating only that “Coinbase complies with all applicable laws, including campaign finance law.” A spokesperson for the Fairshake political action committee did not respond to requests for comment on the Coinbase entity that donated to the PAC, whether Fairshake had solicited the donation, or whether Fairshake had confirmed with Coinbase at the time of the donation their status as a federal contractor. The Fairshake website does note that federal contractors are prohibited from contributing to the super PAC.