i360

Background

i360 advertises itself as a data science, analytics, technology, and advertising company that maintains a “comprehensive data resource of all voting Americans” as a database of over 290 million consumers, 199 million of which are active voters.¹

Michael Palmer founded i360 after working as chief technology officer for Senator John McCain’s 2008 presidential campaign, Politico reported.²

The group was founded in 2009 “to fill the innovation gap between campaigns and organizations that promote free market candidates and causes and their opponents.” i360 developed what it describes as a “closed-loop suite of grassroots technology” to help political and commercial customers target “target and segment their customers with predictive modeling,” and use customer data to build targeted online and TV advertising campaigns.³

Politico described i360 as “the Koch data mine,” reporting in 2014 that the Koch brothers and allied groups including Freedom Partners were investing tens of millions of dollars in i360.⁴

Stance on Climate Change

i360 has close ties to the Koch brothers’ Freedom Partners Chamber of Commerce (FCPP). The Koch network has spent millions of dollars funding a wide range of groups denying the existence of man-made climate change.⁵

Funding

i360 is related to a complex network of companies managed by Freedom Partners Chamber of Commerce (FPCC). Demeter Analytics, a fully owned subsidiary of FPCC, has been located at the same address as i360. The Center for Media and Democracy’s PR Watch noted FPCC is most likely the “funding conduit” for i360, while FPCC in turn acts as a conduit for hundreds of millions of dollars from the Koch brothers and their network. i360 may also have been a replacement for an earlier FCPP group called Themis Trust.⁶

Freedom Partners Chamber of Commerce has 100% ownership of Demeter Analytics, what Politico described as the holding company for i360.⁷

Freedom Partners Companies

The below corporations have all at one time shared the address 2200 WILSON BLVD STE 102-533 ARLINGTON VA 22201, according to tax returns. Demeter Analytics Services Inc. has been listed at both 2300 CLARENDON BLVD SUITE 800 ARLINGTON VA 22201 and at the Wilson Blvd address, sometimes inside the same tax return (see “independent contractors” and “related organizations” in Freedom Partners 2016 990 form, for example).

The following hierarchy is based on “direct controlling entities” listed in Freedom Partners tax returns:

Freedom Partners
- American Strategies Group LLC (ASG)
  - Cavhoco, Inc.
    - KNSLT, Inc.
    - DBLDBL, Inc.
      - Thoco
        
        Demeter Analytics

According to Politico, ASG is set up with a corporate structure known as a “disregarded entity,” which “exists only as a part of its parent group ― in this case Freedom Partners ― for the purposes of mitigating legal risk and separating revenue streams for accounting and tax compliance purposes.”⁸

Freedom Partners also makes regular payments to its affiliated companies. The following “transactions” were listed in tax forms. Note that these totals do not always add up to compensation recorded in the “independent contractors” section of the related tax forms.

Transaction Key
B	Gift, grant, or capital contribution to related organization(s)
L	Performance of services or membership or fund-raising solicitations for related organization(s)
M	Performance of services or membership or fundraising solicitations by related organization(s)
P	Reimbursement paid to related organization(s) for expenses

Recipient & Transaction Type	2012	2014	2015	2016	Grand Total
Cavhoco, Inc.	$1,000,000	$17,502,228	$13,750,000	$8,250,000	$40,502,228
B	$1,000,000	$17,502,228	$13,750,000	$8,250,000	$40,502,228
Demeter Analytics Services, Inc.		$11,000,000	$15,111,185	$9,752,910	$35,864,095
L				$303,178	$303,178
M		$11,000,000	$11,000,000	$9,449,732	$31,449,732
P			$4,111,185		$4,111,185
Freedom Partners Action Fund		$89,026	$277,870	$366,896	$733,792
B			$89,026		$89,026
L				$277,870	$277,870
Grand Total	$1,000,000	$28,591,254	$29,139,055	$18,369,806	$77,100,115

Political Funding

The following is a list of the top 50 contributors to i360 according to data from OpenSecrets.org. Note that the Freedom Partners’ PAC is listed as the group’s top spender.⁹

View the attached spreadsheet for a complete listing of nearly 241 committees who have contributed to i360 (.xlsx) including processed FEC data.

Spender	2011/2012	2013/2014	2015/2016	2017/2018	Grand Total
Freedom Partners Action Fund		$22,840,471	$29,724,646	$1,023,350	$53,588,467
Americans for Prosperity			$1,457,183	$23,000	$1,480,183
Cruz for President			$314,894	$6,333	$321,227
Portman for Senate			$297,596		$297,596
Jeb 2016			$212,898		$212,898
New Day for America			$170,252		$170,252
Republican Party of Illinois			$120,446		$120,446
Kasich for America			$119,690		$119,690
CARLY for America Cmte			$99,084		$99,084
Marco Rubio For Senate 2016			$97,790		$97,790
Friends of John McCain			$82,874		$82,874
Richard Burr Cmte			$80,954		$80,954
Republican Party of Massachusetts			$43,096	$25,617	$68,713
Concerned American Voters	$2,225	$3,052	$60,155		$65,432
Republican Party of North Carolina			$65,313		$65,313
Friends of Todd Young			$59,749		$59,749
Rand Paul for US Senate 2016			$57,036		$57,036
Friends of Pat Toomey			$56,135		$56,135
Montana Republican State Central Cmte			$44,488	$11,299	$55,787
Tom Reed for Congress		$9,346	$25,395	$13,929	$48,670
Morgan Griffith for Congress		$3,027	$26,536	$18,290	$47,853
Arizona Grassroots Action		$5,500	$15,742	$24,239	$45,481
Charles Boustany Jr for Congress			$35,151		$35,151
Republican Party of West Virginia		$16,126	$11,306	$7,161	$34,593
Georgians for Isakson			$34,000		$34,000
Lisa Murkowski for US Senate			$31,959		$31,959
Lindsey Graham 2016			$30,951		$30,951
Republican Party of Kentucky			$28,520		$28,520
Faso for Congress			$11,259	$16,550	$27,809
Hurd for Congress		$6,736	$17,042	$3,884	$27,662
Friends of Kelly Ayotte			$27,321		$27,321
Bob Goodlatte for Congress Cmte		$2,950	$16,385	$7,082	$26,417
Rob Wittman for Congress		$4,559	$12,505	$8,329	$25,393
Wicker for Senate				$25,197	$25,197
Ron Desantis for Congress			$16,515	$6,500	$23,015
Scott Walker Inc			$22,782		$22,782
Strange for Senate				$22,519	$22,519
Tenney for Congress			$6,757	$15,683	$22,440
New York Republican Federal Campaign Cmte			$21,573		$21,573
Moran for Kansas			$21,097		$21,097
Women Speak Out PAC		$3,000	$14,731	$3,050	$20,781
Friends of Mike Lee			$20,124		$20,124

990 Forms

Freedom Partner Chamber of Commerce 990 forms regularly lists Demeter Analytics on its 990 forms. Demeter has shared an address with i360:

Key People

Michael Palmer — Founder and President.¹⁰
Chuck DeFeo — Vice President, Products.¹¹
Christopher F. Cardiff— COO.¹²
Ian Binder — Director of Infrastructure.¹³
Sheetal Kadia — Director Of Data Operations. ¹⁴
Robert Van Niman — Robert Van Niman, Chief Financial Officer (as of 2015).¹⁵

Past People

Hubbel Relat — Former General Counsel (Dec 2011 – Jan 2013). Relat has also held positions at the pro-industry groups Fueling US Forward and the American Energy Alliance, and Americans for Prosperity as well as Freedom Partners Chamber of Commerce.¹⁶
Kathryn Ciano — Former General Counsel.¹⁷

View a larger list of i360 employees via LinkedIn.

Actions

November 2018

Documents uncovered by the Center for Media and Democracy (CMD) and reported at Salon revealed how the Koch brothers worked with i360 developed persuasion models to target voters with tailored messages on certain issues. In 2016, i360 developed models while working with Sen. Rob Portman’s 2016 re-election campaign in Ohio.¹⁸

After polling, I360 found a “key local issue facing Ohio was the opioid epidemic” and subsequently created a a “heroin model” and a “heroin treatment model” that were effective at increasing voter support for Portman.¹⁹

“This manipulation of the opioid crisis for political gain has a perverse irony given the Kochs’ long-running work to provide corporate interests, including health care and pharmaceutical interests, with undue political power and influence over public policy decision,” Salon reported.²⁰

Heroin was only one example of models that i360 developed to craft tailored messaging for Portman’s campaign. Other issue-based models included gun control immigration, energy, pro-life, and marriage.²¹

February 2018

InDaily reported the South Austrlian Liberal Party was testing i360 on one of its campaigns. SA Liberals purchased a license to use i360’s direct campaigning tool, they reported.²²

In July 2018, by-election candidate Rebekha Sharkie called for a parliamentary inquiry into i360.²³

“I think the public should be quite concerned when unwittingly information is sourced about them from a multitude of data bases — social media and other data bases — in order to try and then pinpoint voters that they see as marginal voters and issues that they want to press them on,” Sharkie said. “Ultimately I think people should have far more knowledge of the information that is being sourced about them without their knowledge and most likely without their consent.²⁴

July 2015

Politico reported that Donald Trump, while a 2016 Republican Presidential candidate, was refused after he requested to purchase state-of-the-art data and analytics services” from i360. According to public FEC filings, candidate Ben Carson had been given access to filings, paying $11,000 per month to Demeter Analytic Services. “There is no evidence that any other presidential candidate has accessed the Demeter database,” the Center of Media and Democracy’s PR Watch reported.²⁵ ²⁶