# No Going Back PAC **No Going Back PAC Inc.** is a federal super PAC registered on **September 1, 2026** — nine weeks before the midterm election — that went from a single-race direct-mail channel to a twenty-state television program in four weeks. FEC committee **C00960435**, c/o **Bulldog Compliance**, 100 Cummings Center Ste 306-P, Beverly MA 01915, treasurer **Charles Gantt**. The *New York Times* reported it as financially backed by [[MAGA Inc]]. It has disclosed **no receipts**. Everything known about it comes from its 24- and 48-hour independent- expenditure notices, of which there have been **fourteen since September 16, 2026**. ## The four-week arc | Date | What it filed | Scale | |---|---|---| | 2026-09-01 | Form 1 registration | — | | 2026-09-08 to 09-18 | Direct mail in one race, via Minute Mail Consulting Group LLC | $935,988.48 pro-Paxton + $935,988.48 anti-Talarico, filed three times (see below) | | 2026-09-25 | 65 lines, 41 candidates, 20 states; TV and mail through six vendors — the largest single Form 24 notice in the vault at the time | **$28,504,057.95** | | 2026-09-29 | 56 lines, ~25 House districts plus GA-Sen and NH-Sen; direct mail and text messaging through five vendors | $1,621,822.38 | | 2026-09-30 | 66 lines, 42 candidates, 20 states, 95% placed TV and connected TV | **$29,094,225.24** | | 2026-10-01 | 28 lines, House only, 22 districts; mail and texting through four vendors | $538,733.16 | | **2026-10-08** | **55 lines, 40 candidates, 19 states; 43 House lines and 12 Senate lines; two vendors carry 92.47%** | **$23,305,834.34** | The September 25 filing is recorded as [[No Going Back PAC 28.5M Multi-Race IE September 2026]], the September 30 filing as [[No Going Back PAC 29.1M National IE Program]], and the October 8 filing as [[No Going Back PAC 23.3M Multi-Race IE October 2026]]. 🔴 **$80,904,117.53 across three notices in sixteen days.** The October 8 notice (file **2018548**, `F24N`, received 18:55:46) is the third above $23M. The mix has shifted to the House — 43 of its 55 lines, carrying **$9,578,845.23**, against **$13,726,989.11** on 12 Senate lines — and **35 of the 55 lines sit under $250,000**. [[Del Ray Media LLC]] took **$14,110,252.00** of it and [[MHB Media Inc]] **$7,446,122.00**. The mirrored-pair signature holds: Ohio at **$2,575,572.50** each way and Alaska at **$868,130.50** each way, identical to the cent, same vendor, same document. 🔴 **Corrected 2026-10-02.** This table previously omitted the 2026-09-25 notice entirely, which made the arc read as a jump from $935,988.48 of Texas mail straight to $1.6M and then an "eighteen-fold increase" to $29.1M. That is not what happened. **The committee's first eight-figure notice was $28,504,057.95 on September 25** — 24 days after registration — and the $1,621,822.38 notice of September 29 was a *smaller, wider* follow-up, not a step on the way up. The real shape is: $28.5M, then $1.6M, then $29.1M, then $0.5M. Two notices above $28M inside six days, with the national TV program present from the first one (Del Ray Media LLC carried $15,050,266.00 of the September 25 notice, 53% of it). Across the four notices the committee has filed **$59,758,838.73**, derived by summing files 2015230, 2015798, 2016106 and the 2026-09-29 notice. ## The Del Ray Media overlap $14,240,802.00 of the September 30 notice — 48.9% — went through **Del Ray Media LLC**, which is [[MAGA Inc]]'s placement vendor on every tranche of [[MAGA Inc 20M Texas Senate IE Program]]. A further $13,386,409.00 went through **MHB Media Inc**. This is the first FEC-traceable corroboration in this vault of the reporting that MAGA Inc is behind this committee. It is **not** evidence of a transfer: money moving between the two would appear as a Schedule A receipt or an affiliated transfer, and this committee has reported none. What the filings show is a shared media buyer, which is what should be stated until the October periodic report says otherwise. A second shared-vendor thread runs through **Minute Mail Consulting Group LLC**, which this committee used for its September Texas mail and which [[Digital Freedom Fund]] used for a $2,970,198.67 Ohio Senate mail program filed 2026-09-30. > [!warning] Both vendors reached a third committee > As of 2026-10-01 the open question on these two buyers was whether a third committee would appear on either > vendor. Two committees sharing a buyer is procurement; three is a network with a visible seam. > **Both reached a third committee the next day.** > > | Vendor | Committees | Status | > |---|---|---| > | **Del Ray Media LLC** | [[MAGA Inc]], this committee, [[Safety and Affordability PAC]] (file 2016050, $1,281,250.00), [[Congressional Leadership Fund]] (file 2015245, $6,256,089.39) | **four** | > | **Minute Mail Consulting Group LLC** | this committee, [[Digital Freedom Fund]], [[Defend US PAC]] (file 2016115, $3,795,467.12) | **three** | > > [[Safety and Affordability PAC]] also shares this committee's **compliance shop and treasurer** — Bulldog > Compliance, 100 Cummings Center Ste 306-P, Beverly MA, Charles Gantt — as do [[Digital Freedom Fund]] and > [[MAGA Inc]]. And its three House targets (Amish Shah, Bob Brooks, Rebecca Cooke) are three of the > twenty-five on [[CLF 18.7M House IE September 2026]]. That is a buyer, a compliance shop, a treasurer and a > target list shared across the president's super PAC, the House party committee and two new vehicles. **State > it as shared infrastructure, which the filings show; not as coordination, which they do not.** ## Unresolved: the triple-filed Texas pair Three filings — **2026-09-10, 2026-09-16 and 2026-09-18** — each carry an identical pair of **$935,988.48 supporting [[Ken Paxton]]** and **$935,988.48 opposing [[James Talarico]]**: same amounts to the cent, same expenditure date of September 8, same vendor, and **none flagged as an amendment**. - Three distinct buys would total **$5,615,930.88** in [[TX-Sen-2026]]. - One buy reported three times totals **$1,871,976.96**. Three identical buys and duplicate reporting are indistinguishable in the e-file data. [[TX-Sen-2026]] uses the conservative single-pair figure. **The October periodic report resolves this**, and the difference is $3.7M in the Texas ledger. ## Reading its filings > [!warning] The aggregate column is a committee-wide running total > This committee populates the Schedule E aggregate field as a running total that increments on **every** > line, including both halves of a support/oppose pair, and climbs across unrelated offices inside a single > document. Verified on file 2015608, 2026-09-29. Under FEC Back-Sweep Standard **Rule 4c** that column > cannot be published as a race or committee total. Derive any cycle figure by summing the fourteen notices > and cite the file numbers. ## Why it matters **It is a purpose-built late vehicle.** A committee registered nine weeks out, with professional compliance and no disclosed donors, that can place $29M of television in a day, is not a grassroots formation that grew. The capability was there from the start and the spending was timed. **The disclosure asymmetry is the whole design.** The 48-hour notice requirement is why the $29M is visible at all. The receipts side is quarterly, so the question of who paid for a 20-state television program running in the final five weeks is not answerable until after most of the money is spent. ## See Also - [[No Going Back PAC 29.1M National IE Program]] - [[MAGA Inc]] · [[MAGA Inc 20M Texas Senate IE Program]] · [[Texas PAC]] · [[America PAC]] - [[Digital Freedom Fund]] - [[TX-Sen-2026]] · [[MI-Sen-2026]] · [[OH-Sen-2026-Special]] · [[NH-Sen-2026]] · [[AK-Sen-2026]] · [[GA-Sen-2026]] - [[Ken Paxton]] · [[James Talarico]] · [[Abdul El-Sayed]] · [[Jon Husted]] - [[Independent Expenditure]] · [[Super PACs]] · [[Dark Money]] - [[Organizations Hub]]