# Club for Growth Action 6.3M to Win It Back PAC
**[[Win It Back PAC]]**, FEC committee **C00844613**, disclosed **$6,300,000.00** from
**[[Club for Growth Action]]** on its **October monthly Form 3X** — file **2020535**, `F3XN`, report code
`M10`, received **2026-10-13T13:08:01** (FEC local time), coverage **2026-09-01 to 2026-09-30**, signed by
treasurer Adam Rozansky.
## Terms
| Item | Detail |
|---|---|
| Recipient | **Win It Back PAC**, FEC **C00844613**, Super PAC (IE-only), first filed 2023-07-05, **2001 L St NW Ste 600, Washington DC 20036** |
| Contributor | **Club for Growth Action**, FEC **C00487470**, Super PAC (IE-only), first filed 2010-08-11, **2001 L St NW Ste 600, Washington DC 20036** |
| Structure | **Four itemised Line 11(c) rows** totalling $6,300,000.00. Three are itemised at or above $1M: **$2,200,000.00** (2026-09-02), **$1,600,000.00** (2026-09-03), **$2,100,000.00** (2026-09-08). The fourth is **$400,000.00** |
| Aggregate on the rows | **$10,835,000.00** cycle-to-date (filer-dependent; see the Rule 4c note) |
| Shared treasurer | **Adam Rozansky signs both committees** |
| Shared address | **Both committees file from 2001 L St NW Ste 600, Washington DC** |
| Disclosed | FEC **Form 3X**, October monthly, **file 2020535** |
### The recipient's September, reconciled
| Line | Figure |
|---|---|
| Total receipts, 2026-09-01 to 2026-09-30 | **$6,350,001.17** |
| Line 11(c), other political committees | **$6,300,000.00** — all of it Club for Growth Action |
| Line 11(a), individuals | $50,000.00 (one itemised donor) |
| Other receipts | $1.17 |
| Total disbursements | **$6,395,108.63** |
| Independent expenditure this period (summary line) | **$6,375,472.70** |
| Cash on hand, 2026-09-30 | **$126,792.10** |
| Cycle receipts to date | **$15,799,831.21** |
| Cycle disbursements to date | **$16,211,797.23** |
**Club for Growth Action is 99.21% of the month.** The committee took in $6.35M, spent $6.40M, and closed
September with **$126,792.10** — it is a pass-through operated at near-zero float.
### Where the money went
The month's Schedule E payees, from the same document:
| Payee | Amount |
|---|---|
| Vaulter LLC | $2,177,424.72 |
| Medium Buying LLC | $1,997,508.91 |
| Google Ads | $1,105,053.55 |
| The Trade Desk Inc. | $978,575.98 |
| ColdSpark | $64,739.32 |
| Darby House LLC | $47,490.00 |
| Club for Growth (memo-coded) | $4,680.22 |
> [!note] Rule 4h — the Schedule E on this document is a restatement
> All 23 Schedule E rows restate notices already filed. The $6,375,472.70 is **not new spending** and is
> excluded from the 2026-10-13 tranche's new-money total per Rule 4h. The payee stack above is published
> as the composition of money already disclosed, not as a new buy. The Club for Growth rows carry the
> memo code; per **Rule 4d** they restate dollars itemised elsewhere in the same document.
> [!warning] Rule 4c — the $10,835,000.00 aggregate is not a total
> The itemised rows carry a running cycle aggregate of **$10,835,000.00**. Per Rule 4c that column's
> meaning is filer-dependent and it is **not** publishable as a committee or relationship total. It
> indicates roughly **$4.5 million** of earlier Club for Growth Action money into this committee that has
> not been read into this vault from a filed document.
## Why it matters
**The donor and the recipient are the same operation.** Adam Rozansky is treasurer of record for both
committees and both file from **Suite 600 at 2001 L Street NW**. This is not an arm's-length contribution
between independent actors; it is [[Club for Growth]]'s money moved into a separately named vehicle that
then buys the advertising. The vault already records **Win It Back PAC** spending in [[KS-Sen-2026]]
against [[Adam Hamilton]] — $519,950.85 on receipt date 2026-10-09 — without any page explaining whose
money it was.
**The naming is the point.** A reader of a Schedule E sees *Win It Back PAC*. The organisation behind it
appears nowhere on the expenditure, and the link is visible only on a monthly receipt report filed six
weeks later. The same structural pattern this vault has recorded for the state-branded IE vehicles applies
to a national one.
**It compounds the donor-concentration problem already on the Club for Growth page.** Club for Growth
Action's own funding is heavily concentrated in [[Jeff Yass]] — the vault records roughly $19 million from
him in the 2024 cycle, making him that organisation's largest individual funder. Where Club for Growth
Action's 2026 money comes from is not on this document; its own Q3 report is due **2026-10-15**.
## Open questions
- **Club for Growth Action's own Q3 receipts**, due 2026-10-15 — whether the Yass concentration holds in
this cycle.
- The **$4.5 million** of earlier transfers implied by the aggregate column and not yet read.
- **Vaulter LLC** and **Medium Buying LLC**, which placed $4.17M of one month's buying between them and
have no page in this vault.
- Which races the September buying was in — the restated rows are not resolved to races on this page.
## See Also
- [[Win It Back PAC]] · [[Club for Growth]] · [[Jeff Yass]]
- [[KS-Sen-2026]] · [[Independent Expenditure]] · [[Super PACs]]
- [[Deals Hub]]