Allegation notice. Allegations from the cited record; outcomes noted where adjudicated.
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FEC · CrossClick (XCLK)

“Voters for Hillary” — A SuperPAC as Pump Vehicle

Seventeen days before Cane's DiScala indictment was unsealed, the “Voters for Hillary” SuperPAC was formed (30 Jun 2014), with Cane providing a $10,700 loan. The PAC raised ~$500,000 through loans at up to 18% interest, then paid $73,000 to CrossClick Media (XCLK) — a worthless Nevada penny stock (170M shares at $0.0001) represented by Cane Clark LLP — while PAC insiders held controlling positions in CrossClick: a circular pump.

Listen to this brief
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How it worked

The same insiders sat on both sides of every transaction: treasurer Hodgins directed PAC funds to Finiks (which he controlled), Finiks held CrossClick stock (dominated by MCKEA, where Hodgins was general partner). PAC-to-CrossClick payments inflated XCLK with no business activity; press releases about a “$10.7M pledge” manufactured retail buying. The 18%-interest loan structure ensured lender control over timing.

Open the filed qui tam complaint at this section — the operative pleading (United States ex rel.), jumped to the matching allegation; the filed PDF is one click away.

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Forensic brief

The complete forensic brief behind this summary — the full record with exhibits. Page through it below, or open it larger for the document summary and key relations.

Forensic brief — “Voters for Hillary” 1 / —
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A Super PAC that spent nothing on politics

On 30 June 2014 — seventeen days before Cane's federal indictment was unsealed — a Super PAC called Voters for Hillary was registered. It had begun life in 2014 as the “Foundation for a Greater America” before being renamed to ride the momentum of Hillary Clinton's 2016 presidential announcement.1

It was a political committee in name only. ProPublica's review of federal campaign reports found that Voters for Hillary spent no money supporting Clinton or any other candidate. Of roughly $500,000 it raised before Clinton announced, the great majority arrived not as donations but as loans — most from registered Republicans. The PAC existed to do one thing: lend institutional legitimacy to a worthless penny stock.2

A pro-Clinton Super PAC, formed two weeks before a securities-fraud indictment, funded almost entirely by loans from Republicans at usurious interest, that spent $0 on politics.

Cached copy of the ProPublica investigation (opens locally; the live article is linked in the footnotes): 70

  1. Robert Faturechi & Derek Willis, “On Like Donkey Kong”: How a Dubious Super PAC Boosted a Questionable Penny Stock, ProPublica (May 27, 2016) (co-published with The Daily Beast) (PAC registered Jun. 30, 2014; created in 2014 as “Foundation for a Greater America”). See also Update: FEC Looking at Super PAC That Hyped Penny Stock, ProPublica (Jul. 7, 2016); Inside the ‘Voters for Hillary’ Stock-Market Scam, The Daily Beast.
  2. Id. (federal reports show PAC spent no money on any candidate; ~$500,000 raised mostly as loans from registered Republicans).
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One family on both sides of the trade

The scheme worked because the same people controlled the PAC and the stock it was promoting. Milton Ault III served as chairman of Voters for Hillary. His wife, Kristine Ault, was the managing member of MCKEA Holdings — the Carson City, Nevada entity that was CrossClick Media's controlling shareholder.1

  • Milton Ault III — PAC chairman; pitched the “major deal” between the PAC and CrossClick.
  • Kristine Ault — managing member of MCKEA Holdings, CrossClick's majority shareholder.
  • James Hodgins — managing member of Finiks Capital LLC (another major CrossClick shareholder) and, per his own LinkedIn, a general partner of MCKEA Holdings.
  • Gary Gottlieb — CrossClick executive who confirmed Kristine Ault's company became controlling shareholder in October 2014, when Milton Ault pitched the PAC deal.

This is concealed control made visible: the chairman of the political committee announcing a $10.7 million “contract” was married to the person who controlled the company on the other side of it. The PAC's institutional legitimacy and the stock's majority owner were the same household.2

  1. CrossClick Media, Inc., Form 10-K (filed Nov. 2, 2015) (CIK 0001487659) (MCKEA Holdings as controlling shareholder, Kristine Ault managing member); ProPublica Investigation (Dec. 18, 2015).
  2. ProPublica Investigation (Dec. 18, 2015) (Hodgins as Finiks managing member and MCKEA general partner; Gottlieb on October 2014 takeover timing).
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Loans, not donations — at 18 percent

The capital structure was, in the words of campaign-finance expert Brett Kappel, unlike anything he had encountered: no other Super PAC in the 2016 cycle received more in loans, or relied on loans for so large a share of its revenue. Of five PACs that took six-figure loans that cycle, Voters for Hillary was the only one already repaying them — because the “lenders” were creditors seeking a return, not donors backing a candidate.1

LenderAmountBackground
Judson Church$250,000Registered Republican — largest single loan to an ostensibly pro-Clinton PAC.
Kyleen E. Cane$10,700Lent while under federal indictment for the $300M DiScala pump-and-dump.
Mary CoonsUndisclosedSpouse barred by the SEC for market manipulation.
Finiks Capital LLC$242,000Received a loan from the PAC (initially undisclosed); its managing member was also a general partner of MCKEA.

Milton Ault told ProPublica the lenders were “looking to profit from the interest rates the committee agreed to, which were as high as 18 percent.” Usurious commercial interest is not how political fundraising works — it is how a financing vehicle works.2

  1. ProPublica Investigation (Dec. 18, 2015) (Kappel; only five 2016-cycle PACs took six-figure loans; Voters for Hillary alone was repaying them).
  2. Id. (Ault: lenders sought profit from interest rates “as high as 18 percent”; $250,000 Church loan; $10,700 Cane loan; $242,000 loan to Finiks).
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The $73,000 round trip and the $10.7M phantom

The fraud needed documentary evidence of “business.” The PAC paid CrossClick roughly $73,000 for purported call-center services; in the months after Clinton announced, CrossClick paid roughly the same amount back. The money traveled in a circle and produced nothing — except a paper trail of apparent revenue.1

On top of the round trip sat the headline: CrossClick announced the PAC had pledged $10.7 million to its marketing. Its CEO called the PAC contract “a milestone” driving revenue “predicated largely on Ms. Clinton becoming a Presidential candidate.” After Clinton's 12 April 2015 announcement, the pump ran:2

MarkerValue
Shares outstanding, mid-2014~170,000,000 at $0.0001
Shares outstanding, end of April 20152,600,000,000
Peak run, by 6 May 2015~12× (+1,200%)
Daily volume at the spiketens of millions of shares
Aftermathcollapse back to near-worthless
Inflate on false information, sell into the spike, leave retail holders with nothing. The InvestorsHub boards put it plainly on 28 March 2015: “Soon the 1st lady announces her candidacy and it's on like Donkey Kong. Hope you have some shares :)”
  1. ProPublica Investigation (Dec. 18, 2015) (~$73,000 paid to CrossClick for call-center services; roughly the same amount paid back).
  2. Id. (CEO “milestone” statement, Dec. 2014; Clinton announced Apr. 12, 2015; shares grew 170M → 2.6B; +1,200% by May 6, 2015; subsequent collapse).
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The same offshore plumbing as DiScala

CrossClick was not a new vehicle — it was a serial shell. The entity (CIK 0001487659) traded as Southern Products, Inc. (SNPD, 2010–2013), then Co-Signer, Inc. (XCLK, 2013–2014), then Cross Click Media Inc. (2014–2019), out of a Las Vegas suite, before its status was REVOKED.1

Cane Clark LLP sat on both sides: it was CrossClick's SEC filing agent (CIK 0001255294) and its creditor. CrossClick's 10-K disclosed promissory notes to Cane Clark dated 29 June 2012 and 30 November 2012 — giving Cane's firm a direct financial interest in the very stock the PAC would later inflate.2

[M___] is selling CACL and SNPD only out of OX and Northstar. He can buy or sell anything out of Trilogy.Cane's seized text message, Aug. 6, 2013, quoted in Government's Reply Memorandum Re Cane Wiretaps at 12–14, United States v. DiScala (E.D.N.Y. Jan. 5, 2018)

“SNPD” was CrossClick's ticker at the time. Cane's own message shows it being sold through Oxbridge and North Star — the identical offshore accounts used to manipulate Cubed and Crown Alliance Capital in DiScala. The Super PAC fraud was not a separate venture; it was the same offshore manipulation infrastructure for which Cane was under indictment, pointed at a new stock.3

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Fraud while on bond, and the walk-away from the FEC

The timing is the point. Cane's $10,700 loan to Voters for Hillary was made while she was on federal pre-trial release for a nearly identical $300 million pump-and-dump — the same worthless penny stocks, false legitimacy, concealed control, and retail victimization the DiScala indictment alleged. Pending prosecution did not deter the enterprise; it operated straight through it.1

When the stock collapsed, the regulatory mask came off. The PAC ceased all FEC filings in July 2015, immediately after the May peak. The FEC fined it $9,800 for one blown deadline, caught the initially unreported $242,000 Finiks loan and demanded an explanation — and the PAC simply never responded. A committee that spent $0 on candidates had no reason to keep filing once the fraud paid out.2

StatuteConduct
15 U.S.C. §78j(b) / Rule 10b-5PAC used to fake institutional investment; coordinated Ault control; $73,000 round trip.
18 U.S.C. §1343Fraudulent press releases over interstate wires claiming a $10.7M contract.
52 U.S.C. §30109$0 spent on candidates; undisclosed $242K Finiks loan; all filings abandoned July 2015.
18 U.S.C. §1962(c)Racketeering executed on bond, parallel in method to the DiScala conspiracy.

That continuity — a fresh securities fraud run during an active federal prosecution for the same conduct — is exactly what a RICO “pattern of racketeering activity” requires: not one scheme, but an enterprise that transcends any single indictment.3

  1. ProPublica Investigation (Dec. 18, 2015) (Cane lent while under federal indictment); Indictment, United States v. DiScala, No. 14-cr-399 (E.D.N.Y. Jul. 15, 2014).
  2. ProPublica Investigation (Dec. 18, 2015) (no FEC filings since July 2015; $9,800 fine; unanswered demand re unreported loans).
  3. 15 U.S.C. §78j(b); 18 U.S.C. §§1343, 1962(c); 52 U.S.C. §30109.
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Timeline

  1. 30 Jun 2014“Voters for Hillary” SuperPAC formed — 17 days before Cane's DiScala indictment is unsealed.
  2. 2014Cane lends the PAC $10,700 while under federal indictment; PAC raises ~$500,000, ~1/3 from loans at up to 18%.
  3. 2014$242,000 PAC loan to Finiks Capital LLC — before Clinton announces; not timely disclosed to the FEC.
  4. Dec 2014CrossClick CEO calls the PAC contract “a milestone,” predicting revenue “predicated largely on Ms. Clinton becoming a Presidential candidate.”
  5. Early 2015CrossClick announces the PAC “pledged $10.7M”; InvestorsHub message boards flood with promotion.
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Named parties

  • Kyleen Cane (PAC lender, $10,700, under federal indictment)
  • Milton Ault III (chairman) · Kristine Ault (MCKEA, CrossClick majority holder)
  • James Hodgins (managing member, Finiks Capital; GP of MCKEA)
  • Judson Church ($250,000 loan) · Mary Coons (lender; SEC-barred spouse)
  • CrossClick Media Inc. (XCLK, CIK 0001487659) · Cane Clark LLP
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Citations & pleadings