As a result, the IRS traditionally has permitted organizations described in IRC 501(c)(4) to engage in lobbying and political campaign activities if those activities are not the organization's primary activity. Internal Revenue Service rules also protect groups organized under Section 501(c)(4) as nonprofit organizations dedicated to social welfare from having to reveal the names of their donors or the amount of funds the individual donors have contributed. This protection dates back to the United States Supreme Court's 1958 ruling in "NAACP v. Alabama", when the Court held that disclosure of names could render private donors vulnerable to retaliation. Nonprofit organizations dedicated to social welfare are not required to apply for IRS certification in order to operate under Section 501(c)(4) tax exemption rules. However, being certified by the IRS can help organizations attract more donations and provide some protection against further scrutiny. In 2013, examples of 501(c)(4) groups included Organizing for Action, organized to promote President Obama's legislative priorities, and the conservative advocacy organization Crossroads GPS, founded in part by Karl Rove. On January 21, 2010, the U.S. Supreme Court decided "Citizens United v. Federal Election Commission", which overturned many previous restrictions on political campaign spending and allowed nearly unlimited and often anonymous spending by corporations and other groups to influence elections. Some Tea Party leaders began forming political action committees as offshoots of their 501(c)-tax-exempt organizations. By late September 2010, tax-exempt non-profit groups had spent in excess of $100 million on the mid-term elections, more than double the expenditure from a similar point in the election cycle four years earlier. Public-interest advocacy groups such as Public Citizen and Democracy 21 complained that the IRS and Federal Election Commission were failing to provide adequate oversight for 501(c) nonprofit organizations that were pouring money into political campaigns. As "The New York Times" reported at the time:  Almost all of the biggest players among third-party groups, in terms of buying television time in House and Senate races since August, have been 501(c) organizations, and their purchases have heavily favored Republicans... They include 501(c)(4) "social welfare" organizations, like Crossroads, which has been the top spender on Senate races, and Americans for Prosperity, another pro-Republican group that has been the leader on the House side; 501(c)(5) labor unions, which have been supporting Democrats; and 501(c)(6) trade associations, like the United States Chamber of Commerce, which has been spending heavily in support of Republicans.