opinion 2002-09, where Target Wireless asked the Commission if it must
require disclaimers on ads sent via text message to cell phones.10 Given
technological requirements at the time – including character limits on text
messages – the FEC applied the “small items” exemptions to those political
“ads.” Similar questions were put to the FEC by Google (AO 2010-19),
Facebook (2011-09), and by a digital ﬁrm, Revolution Messaging (2013-18),
who asked about disclaimers on mobile banner ads.11 In the Google case, the
Commission allowed ad sponsors who purchased character-limited online ads
to link to the committee’s website, which contained the full disclaimer for the
group. They did not justify this under the “small items” exemption, though, and
they limited the application of the linking option to FEC-registered committees.
In the Facebook and Revolution Messaging cases, however, the FEC could not
reach a consensus on how to apply disclaimer requirements in those cases. (For
Social_Media_and_Democracy