The ACLU submitted these comments in response to a Notice of Proposed Rulemaking from the Federal Elections Commission, proposing to re-define the term “public communication” and offers two alternatives to govern disclosures and disclaimers for internet-based election communications. The comments offer commentary on both alternatives and ways to build upon them, while expressing strong support for the notion that internet communications advocating support or opposition for candidates for office should be subject to substantially the same disclosure and disclaimer requirements as are imposed on election communications in other media, and the ACLU’s historical opposition to disclosure requirements with respect to ads that do not expressly advocate for the election or defeat of a candidate.