# No Going Back PAC 29.1M National IE Program
On **September 30, 2026**, [[No Going Back PAC]] disclosed **$29,094,225.24** of independent expenditures
across **66 Schedule E lines**, against or for **42 distinct candidates in 20 states**, in a single FEC
48-hour report. Every expenditure in it is dated the same day it was filed.
**The day before, the same committee filed $1,621,822.38.** This is an eighteen-fold increase in
twenty-four hours, and the medium changed with the scale: the September 29 notice was direct mail and text
messaging; **$27.63 million of this one — 95% — is "placed media: TV and connected."**
## Terms
| Item | Detail |
|---|---|
| Spender | **NO GOING BACK PAC INC.**, FEC committee **C00960435**, c/o Bulldog Compliance, 100 Cummings Center Ste 306-P, Beverly MA 01915 |
| Registered | **2026-09-01** |
| Disclosed | FEC **48-hour** independent-expenditure report (**Form 24, file 2015798**), received **2026-09-30 at 20:52:44**, signed the same day by treasurer **Charles Gantt** |
| Lines | **66** Schedule E rows, every expenditure dated **2026-09-30** |
| Total | **$29,094,225.24** |
| Split by chamber | **$14,007,800.55** across 9 Senate targets · **$15,086,424.69** across 33 House targets |
| Amendments | None. `F24N` original, zero amendment rows, zero memo rows |
| Notice count | **Fourteen** Form 24 notices since 2026-09-16 |
| Funding source | **Undisclosed** until the October periodic report. Reported by the *New York Times* as financially backed by [[MAGA Inc]] |
### Vendors — the finding is here
| Vendor | Amount | Share |
|---|---|---|
| **Del Ray Media LLC** | $14,240,802.00 | 48.9% |
| [[MHB Media Inc]] | $13,386,409.00 | 46.0% |
| Whistlestop Strategies LLC | $576,512.66 | 2.0% |
| Optimates LLC | $491,996.52 | 1.7% |
| Electoral Communications Group LLC | $168,486.90 | 0.6% |
| PT Strategy LLC | $136,348.00 | 0.5% |
| Caliber Contact | $90,116.16 | 0.3% |
| 1892 LLC | $3,554.00 | <0.1% |
**Del Ray Media LLC is [[MAGA Inc]]'s placement vendor.** It is the buyer on every tranche of
[[MAGA Inc 20M Texas Senate IE Program]]. The *New York Times* reported that No Going Back PAC is
financially backed by MAGA Inc; **$14.2 million routed through MAGA Inc's own media buyer in a single
notice is the first FEC-traceable corroboration of that reporting in this vault.**
> [!warning] A shared vendor is not a transfer
> What the filings establish is that two committees use the same placement firm. They do **not** show money
> moving from MAGA Inc to No Going Back PAC — that would appear as a Schedule A receipt or an affiliated
> transfer, and this committee has disclosed no receipts at all yet. State the vendor overlap; do not state
> a transfer. The October periodic report is what settles it.
## The nine Senate targets
| State | Candidate | Direction | Amount |
|---|---|---|---|
| MI | [[Abdul El-Sayed]] | oppose | $3,986,901.00 |
| OH | [[Sherrod Brown]] | oppose | $2,575,572.50 |
| OH | [[Jon Husted]] | support | $2,575,572.50 |
| NH | [[Chris Pappas]] | oppose | $1,038,249.61 |
| NH | [[John E. Sununu]] | support | $1,035,285.36 |
| GA | [[Jon Ossoff]] | oppose | $876,164.27 |
| AK | [[Mary Peltola]] | oppose | $868,130.50 |
| AK | [[Dan Sullivan]] | support | $868,130.50 |
| GA | [[Mike Collins]] | support | $183,794.31 |
**El-Sayed is the single largest target in the filing**, and the Ohio and Alaska pairs are matched to the
cent in both directions — the signature of one media buy reported as the two halves that IE disclosure
requires.
## The largest House targets
Plain names here; most of these candidates do not yet have vault pages.
| State | Candidate | Direction | Amount |
|---|---|---|---|
| FL | Jared Moskowitz | oppose | $2,383,986.00 |
| NY | Thomas Suozzi | oppose | $2,417,922.00 |
| FL | Kathy Castor | oppose | $1,808,458.00 |
| NC | Jamie Ager | oppose | $1,114,873.62 |
| MI | Sean McCann | oppose | $912,922.00 |
| TX | Johnny Garcia | oppose | $789,831.00 |
| IA | Lindsay James | oppose | $760,098.60 |
| MT | Samuel Kelley Forstag | oppose | $612,333.00 |
| TX | Bobby Pulido | oppose | $600,333.00 |
| WA | Marie Gluesenkamp Perez | oppose | $573,750.00 |
| VA | Elaine Luria | oppose | $562,360.00 |
| PA | Janelle Stelson | oppose | $488,140.00 |
| CO | Jessica Willow Killin | oppose | $318,050.00 |
| TX | Vicente Gonzalez | oppose | $276,125.00 |
| NM | Gabriel Vasquez | oppose | $245,875.00 |
States touched, all 20: AK, AL, CO, FL, GA, IA, KY, MI, MT, NC, NH, NJ, NM, NY, OH, PA, SC, TX, VA, WA.
## Why it matters
**The committee's shape changed overnight, not just its budget.** Four weeks ago this was a Texas direct-mail
channel. Two days ago it was a 25-district national mail program. Today it is a 20-state television buy
running on two media firms. A vehicle that can do that in four weeks was built to do it.
**It is the second-largest single disclosed IE filing in the vault**, behind only
[[Texas PAC 61.4M Texas Senate IE]] — and unlike Texas PAC, which is one race, this is a national program.
**The only reason any of it is visible is the 48-hour notice requirement.** The committee has disclosed no
receipts. Its donors are not knowable before the October periodic report, and the spending is already done.
## Threshold note
No single line in this filing reaches $10M — the largest is $3,986,901.00. It qualifies as a Deal under
**§7.4a** (ruled 2026-09-27), which treats a Form 24 notice whose Schedule E lines sum to $10M or more as a
single buy whatever the line structure. The unit is the filing, not the line item.
## Open question carried onto this page
Three of this committee's earlier filings — 2026-09-10, 2026-09-16 and 2026-09-18 — carry an **identical
$935,988.48 / $935,988.48 Paxton-Talarico pair**, same amounts to the cent, same expenditure date, same
vendor (Minute Mail Consulting Group LLC), and **none flagged as an amendment**. Three identical buys and
one buy reported three times look the same in the data.
- If all three are real: **$5,615,930.88** in [[TX-Sen-2026]].
- If it is one buy reported three times: **$1,871,976.96**.
[[TX-Sen-2026]] uses the conservative single-pair figure. **The October periodic report resolves it**, and
that is a $3.7M difference in the Texas ledger. This question was previously parked on the race file; it
belongs here, on the committee's own Deal page.
## Aggregate-column warning
Do **not** quote a cycle total from this notice's aggregate column. This committee populates it as a
**committee-wide running total** that increments on every line including both halves of a support/oppose
pair — verified on file 2015608 on 2026-09-29, where aggregates climb monotonically across unrelated
offices inside one document. That column is a signal, not a quantity. Derive any cycle figure
by summing the fourteen notices and cite the file numbers.
## See Also
- [[No Going Back PAC]] · [[MAGA Inc]] · [[MAGA Inc 20M Texas Senate IE Program]]
- [[Texas PAC 61.4M Texas Senate IE]] · [[Texas PAC]] · [[America PAC]]
- [[TX-Sen-2026]] · [[MI-Sen-2026]] · [[OH-Sen-2026-Special]] · [[NH-Sen-2026]] · [[AK-Sen-2026]] · [[GA-Sen-2026]]
- [[Abdul El-Sayed]] · [[Sherrod Brown]] · [[Jon Husted]] · [[Mike Collins]]
- [[Independent Expenditure]] · [[Super PACs]] · [[Dark Money]]
- [[2026 Senate Races Hub]]
- [[Deals Hub]]