Meta Platforms: Lobbying, dark money, and the App Store Accountability Act

An open-source intelligence investigation into how Meta Platforms built a multi-channel influence operation to pass age verification laws that shift regulatory burden from social media platforms onto Apple and Google's app stores.

Every finding in this repository is sourced from public records: IRS 990 filings, Senate LD-2 lobbying disclosures, state lobbying registrations, campaign finance databases, corporate registries, WHOIS/DNS records, Wayback Machine archives, and investigative journalism.

Status: Active investigation. 47 proven findings, 9 structurally possible but unproven hypotheses, and multiple pending FOIA responses.

Research period: 2026-03-11 to present

Meta spent a record $26.3 million on federal lobbying in 2025, deployed 86+ lobbyists across 45 states, and covertly funded a "grassroots" child safety group called the Digital Childhood Alliance (DCA) to advocate for the App Store Accountability Act (ASAA). The ASAA requires app stores to verify user ages before downloads but imposes no requirements on social media platforms. If it becomes law, Apple and Google absorb the compliance cost while Meta's apps face zero new mandates.

This investigation traced funding flows across five confirmed channels, analyzed $2.0 billion in dark money grants, searched 59,736 DAF recipients, parsed LD-2 filings, and mapped campaign contributions across four states to document the operation.

Meta's federal lobbying spending jumped from $19M (2022-2023) to $24M (2024) to $26.3M (2025) as ASAA bills were introduced in roughly 20 states. In Louisiana alone, 12 lobbyists were deployed for a single bill that passed 99-0.

Across all five Arabella Advisors entities (New Venture Fund, Sixteen Thirty Fund, North Fund, Windward Fund, Hopewell Fund), 4,433 grants totaling approximately $2.0 billion were analyzed. Not a single dollar went to any child safety, age verification, or tech policy organization. The Schedule I grant pathway through the Arabella network is definitively ruled out.

Five confirmed channels connect Meta's spending to ASAA advocacy: direct federal lobbying ($26.3M), state lobbyist networks (45 states), the Digital Childhood Alliance (astroturf 501(c)(4)), super PACs ($70M+), and state legislative campaigns (3 laws passed). A sixth channel through the Arabella dark money network is structurally possible but unproven.

These standalone HTML documents provide detailed views of the investigation:

• Full Investigation Documentation contains the complete OSINT investigation report with all five channels, evidence tables, and source citations.

• Funding Network Timeline maps the chronological development of Meta's lobbying infrastructure, DCA's formation, and ASAA legislative progress across states.

• Research Timeline tracks the investigation itself, showing when each finding was established and how threads connected.

(These are self-contained HTML files. Clone the repo and open them in a browser, or use Forgejo's raw file view.)

metafindings/
  data/
    processed/          24 research findings documents
    raw/osint_990/      Raw IRS 990 data extracts
  output/
    reports/            Summary reports, charts, and HTML documentation
    timeline/           Interactive timeline visualizations
    briefs/             Policy briefs and public comments
  OSINT_TASKLIST.md     Investigation task tracker with completion status

Meta retained 40+ lobbying firms and 87 federal lobbyists in 2025 (85% with prior government service). Meta's own LD-2 filings with the Senate explicitly list H.R. 3149/S. 1586, the App Store Accountability Act, as a lobbied bill. The filing narrative includes "protecting children, bullying prevention and online safety; youth safety and federal parental approval; youth restrictions on social media."

At the state level, confirmed operations include $338,500 to Headwaters Strategies (Colorado), $324,992+ across 9 firms and 12 lobbyists in Louisiana, and $1,036,728 in direct California lobbying (Q1-Q3 2025 alone). A Meta lobbyist brought the legislative language for Louisiana HB-570 directly to the bill's sponsor, Rep. Kim Carver, who confirmed this publicly.

DCA is a 501(c)(4) advocacy group that Meta covertly funds. Bloomberg exposed the funding relationship in July 2025. Under oath at a Louisiana Senate committee hearing, Executive Director Casey Stefanski admitted receiving tech company funding but refused to name donors.

DCA has no EIN in the IRS Business Master File, no incorporation record in any state registry searched (CO, DC, DE, VA, OpenCorporates), and no Form 990 on file. It processes donations through the For Good DAF (formerly Network for Good) as a "Project," not a standalone nonprofit. Its likely fiscal sponsor is NCOSEAction/Institute for Public Policy (EIN 88-1180705), NCOSE's confirmed 501(c)(4) affiliate with the same leadership.

DCA's domain was registered December 18, 2024. The website was live and fully formed the next day. Every blog post and testimony targets Apple and Google. Meta is never mentioned or criticized.

Meta committed over $70 million to four state-level super PACs: ATEP ($45M, bipartisan, co-led by Hilltop Public Solutions), META California ($20M), California Leads ($5M), and Forge the Future (Texas, Republican-aligned). Forge the Future's stated policy priority is "empowering parents with oversight of children's online activities," which mirrors ASAA language exactly.

Hilltop Public Solutions co-leads the $45M ATEP super PAC and is also involved in DCA's messaging coordination, making it the first firm confirmed in both Meta's PAC operation and the astroturf advocacy track.

All super PACs are registered at the state level rather than with the FEC, scattering disclosure filings across individual state ethics commissions instead of a single searchable federal database.

Meta's Colorado lobbyist Adam Eichberg simultaneously serves as Board Chair of the New Venture Fund, the flagship 501(c)(3) of the Arabella Advisors network. NVF transfers $121.3 million annually to the Sixteen Thirty Fund, a 501(c)(4) with no donor disclosure requirements.

The Arabella network operates four entities from 1828 L Street NW, Washington DC (suites 300-A through 300-D) with combined annual revenue exceeding $1.3 billion. All five entities' grant recipients were analyzed (4,433 grants, approximately $2.0 billion). Zero dollars went to any child safety organization, definitively ruling out the Schedule I grant pathway.

If Meta money flows through the Arabella network to DCA, it would have to travel via fiscal sponsorship, consulting fees, or lobbying expenditures, which are more opaque than grant disclosures.

ASAA has been signed into law in three states:

• Utah SB-142 (signed March 26, 2025, first in nation)
• Texas SB 2420 (signed May 2025, paused by federal judge December 2025)
• Louisiana HB-570 (signed June 30, 2025, effective July 1, 2026)

Roughly 17 additional states have introduced or are considering ASAA bills, including Kansas, South Carolina, Ohio, Georgia, and Florida. The federal version was introduced in May 2025 by Rep. John James (R-MI) and Sen. Mike Lee (R-UT).

Each finding below is documented with sources in the corresponding analysis file.

1. Meta funds DCA, confirmed by Bloomberg reporters and partially admitted by Stefanski under oath at the Louisiana Senate Commerce Committee hearing (April 2025). Sources: Insurance Journal/Bloomberg July 2025, Deseret News Dec 2025, The Center Square LA.
2. Meta deployed 86+ lobbyists across 45 states for ASAA and related campaigns. Source: OpenSecrets, state lobbying registrations.
3. Meta spent $26.3 million on federal lobbying in 2025, an all-time record exceeding Lockheed Martin and Boeing. Source: OpenSecrets, Quiver Quantitative, Dome Politics.
4. Meta paid Headwaters Strategies $338,500 for Colorado lobbying between 2019 and 2026. Source: Colorado SOS SODA API.
5. Adam Eichberg simultaneously co-founded Meta's Colorado lobbying firm (Headwaters Strategies) and chairs the New Venture Fund board. Sources: Headwaters Strategies website, NVF board page, InfluenceWatch.
6. NVF transfers $121.3 million to the Sixteen Thirty Fund (c)(4) annually. Source: NVF Form 990 Schedule I, 2022-2024.
7. NVF does not directly fund any child safety or tech policy organizations via Schedule I grants. Source: NVF Form 990 Schedule I analysis, 2,669 recipients.
8. DCA and DCI share infrastructure: same registrar (GoDaddy), CDN (Cloudflare), email (Microsoft 365), and marketing platform (Elastic Email). Source: DNS/WHOIS analysis.
9. Pelican State Partners represents Meta as a lobbying client in Louisiana. Source: F Minus database, LA Board of Ethics.
10. DCA leadership comes from NCOSE: three of four senior staff have NCOSE connections (Stefanski, Hawkins, McKay). Source: DCA website, NCOSE public records.
11. DCA's John Read spent 30 years at DOJ Antitrust investigating app stores and Big Tech. Source: DOJ case filings, DCA team page.
12. ASAA has been signed into law in three states: Utah (SB-142, March 2025), Louisiana (HB-570, June 2025), and Texas (SB 2420, May 2025, paused by judge December 2025). Sources: State legislature records, news coverage.
13. The Sixteen Thirty Fund does not fund any child safety or tech policy organizations via Schedule I grants (306 of 318 recipients analyzed). Source: STF Form 990 Schedule I, 2024.
14. All five Arabella entities analyzed: 4,433 grants (approximately $2.0 billion) with zero dollars going to child safety or tech policy organizations. Schedule I pathway definitively ruled out across the entire network. Sources: NVF, STF, North Fund, Windward, Hopewell Form 990 Schedule I filings via ProPublica.
15. A Meta employee (Jake Levine, Product Manager) contributed $1,175 to ASAA sponsor Matt Ball's campaign apparatus on June 2, 2025. Source: Colorado TRACER bulk data.
16. A Google Policy Manager (Kyle Gardner) also contributed $450 to Matt Ball. Multiple tech company employees from ASAA-affected companies targeted the same ASAA bill sponsor. Source: Colorado TRACER bulk data.
17. Eichberg and Coyne (Headwaters principals) did not contribute to ASAA bill sponsors Ball or Paschal despite $20,000+ combined political giving. Source: Colorado TRACER bulk data.
18. No direct Meta PAC contributions to any ASAA sponsor across Utah, Louisiana, Texas, or Colorado. Source: FollowTheMoney.org multi-state search.
19. Todd Weiler (Utah SB-142 sponsor) does not accept corporate contributions and has not discussed ASAA directly with Meta. DCA served as the policy intermediary. Source: Investigative reporting, Weiler's public statements.
20. DCA has no EIN in the IRS Business Master File. Not found in any of four regional extracts (eo1-eo4.csv) covering all US tax-exempt organizations. Source: IRS BMF regional extracts.
21. DCI confirmed in IRS BMF with EIN 39-3684798, Delaware incorporation at 213 N Market St Wilmington, IRS ruling November 2025. Source: IRS BMF extract.
22. Meta's Forge the Future super PAC spent $1.3 million in Texas ahead of March 2026 primaries. Source: Texas Ethics Commission filings, news coverage.
23. DCA's website deployed less than 24 hours after domain registration: fully functional advocacy site with professional design, statistics, and Heritage/NCOSE testimonials. Source: Wayback Machine CDX API, 100+ snapshots.
24. 77-day pipeline from DCA domain registration (December 18, 2024) to Utah SB-142 signing (March 5, 2025). Site pre-loaded with ASAA talking points before any bill had passed. Source: WHOIS records, Utah Legislature.
25. Meta deployed 12 lobbyists for Louisiana HB-570, which passed 99-0. Disproportionate deployment indicates text-control and amendment-blocking rather than vote persuasion. Source: Investigative reporting, LA Board of Ethics.
26. Three California tech policy employees from Meta, Google, and Pinterest contributed to Matt Ball within 90 days. All from ASAA-affected companies, all out-of-state, targeting a newly-appointed senator. Source: Colorado TRACER bulk data.
27. Pelican State Partners represents both Meta and Roblox in Louisiana. Both are ASAA beneficiaries, enabling "broad industry support" framing. Source: F Minus database.
28. DCA's coalition count inflated from 50+ to 140+ with only six organizations ever publicly named. No member list has been published on the website. Source: DCA website, Wayback Machine.
29. NCOSE has a confirmed 501(c)(4) affiliate: NCOSEAction / Institute for Public Policy (EIN 88-1180705), IRS ruling May 2025, same address and leadership as NCOSE. Source: IRS BMF, NCOSE website.
30. Network for Good is a Donor Advised Fund, not a payment processor. DCA is classified as "Project" (ID 258136) in the system. For Good explicitly limits grants to 501(c)(3) organizations. Source: For Good website, IRS determination.
31. A Meta lobbyist drafted HB-570's legislative language, confirmed by sponsor Rep. Kim Carver. The bill as originally written placed age verification burden exclusively on app stores, not platforms. Source: Investigative reporting, Carver's public confirmation.
32. Sen. Jay Morris's amendment expanded HB-570 to include app developers alongside app stores, leading to a conference committee compromise. Source: LA Legislature records.
33. Nicole Lopez (Meta Director of Global Litigation Strategy for Youth) testified in both Louisiana and South Dakota for ASAA bills, serving as Meta's national ASAA spokesperson. Source: Legislative hearing records.
34. The Sixteen Thirty Fund's $31 million lobbying budget and $13.1 million in professional fees contain zero mentions of child safety, digital policy, age verification, or app stores. Source: STF Form 990 Part IX.
35. John R. Read (DCA Senior Policy Advisor) lists "Digital Childhood Alliance" as his employer in Colorado TRACER records. Contributed $100 to AG candidate Hetal Doshi (October 2025). Source: Colorado TRACER.
36. Matt Ball received 8% of total fundraising from tech industry employees. He is the only 2026 Colorado senate candidate with contributions from Meta, Pinterest, Instacart, Anthropic, and Google employees. Four of eight dual-maxed donors are tech employees. Source: Colorado TRACER analysis.
37. NCOSE Schedule R reveals a two-entity evolution: the original NCOSE Action (EIN 86-2458921, c4 reclassified to c3) was replaced by the Institute for Public Policy (EIN 88-1180705, c4). All 19 NCOSE-to-Institute transaction indicators are marked "No" despite shared leadership. Source: NCOSE Form 990 Schedule R, 2019-2023.
38. For Good DAF pathway definitively ruled out: 59,736 grant recipients across five years (approximately $1.73 billion) searched with zero matches for DCA, DCI, NCOSE, NCOSEAction, or any related entity. Source: For Good DAF grant data.
39. NCOSE lobbying spending tripled from $78,000 to $204,000 concurrent with DCA launch and the ASAA legislative push (FY2023 to FY2024). Source: NCOSE Form 990 Part IX.
40. Forge the Future super PAC explicitly lists an ASAA-aligned policy priority: "Empowering parents with oversight of children's online activities across devices and digital environments." Source: Forge the Future filings.
41. Hilltop Public Solutions bridges Meta's super PAC and DCA operations. It co-leads ATEP ($45M) and is involved in DCA messaging coordination. First firm confirmed in both tracks. Source: ATEP filings, investigative reporting.
42. Meta super PACs are state-level entities (not FEC-registered), deliberately scattering filings across state ethics commissions to avoid centralized searchability. Source: FEC search (negative), state PAC registrations.
43. Meta's total documented political spending exceeds $70 million: $45M ATEP, $20M META California, $5M California Leads, with downstream flows to Forge the Future (TX) and Making Our Tomorrow (IL). Source: State PAC filings, news coverage.
44. Casey Stefanski never appears on any NCOSE 990 filing despite reportedly working there ten years. Not among officers, directors, key employees, or five highest-compensated. Source: NCOSE Form 990 filings, 2015-2023.
45. Meta's LD-2 filings explicitly list the App Store Accountability Act (H.R. 3149/S. 1586) as a lobbied bill. This is the first direct evidence from Meta's own federal filings connecting its $26.3M lobbying spend to the specific legislation DCA advocates for. Source: Senate LDA filing UUID b73445ed-15e5-42e7-a1e8-aeb224755267.
46. Meta simultaneously lobbies FOR ASAA and ON KOSA/COPPA 2.0, supporting legislation that burdens Apple and Google while opposing or amending legislation that would regulate Meta directly. Both appear in the same LD-2 filing. Source: Meta LD-2 Q1-Q2 2025.
47. LD-2 narrative mirrors DCA messaging: "youth safety and federal parental approval" framing in Meta's federal filings matches DCA's "parental approval" and "child protection" advocacy language. Source: LD-2 filing CPI issue code narrative.

1. Meta funds flow through the Arabella network via non-grant mechanisms (fiscal sponsorship, consulting fees, lobbying expenditures). The Schedule I and For Good DAF pathways are both ruled out.
2. DCA operates under NCOSEAction (EIN 88-1180705) as fiscal sponsor. The personnel chain is direct (van der Watt to Hawkins to Stefanski), but NCOSE reports zero transactions with its c4 affiliate.
3. NVF's $36.7 million in lobbying expenditures support age verification advocacy.
4. Jake Levine's contribution to Matt Ball was coordinated by Meta's government affairs team rather than being purely personal.
5. STF's $31M lobbying fees and $13.1M professional fees include age verification advocacy, but aggregate reporting prevents confirmation.
6. Angela Paxton (Texas ASAA sponsor) was among the unnamed state senators supported by Forge the Future.
7. NCOSE's lobbying spend tripling is causally related to DCA/ASAA activity (timing is concurrent but program descriptions do not mention ASAA).
8. DCA's For Good donation page is cosmetic. Actual funding comes directly from Meta, not small-dollar DAF donations.

• NVF Schedule I Analysis
• STF Schedule I Analysis
• North Fund Schedule I Analysis
• Windward and Hopewell Schedule I Analysis
• Arabella 990 Findings
• NVF 990 Findings

• Headwaters Expenditures
• Koch Lobbyist Findings
• California Lobbying
• Meta National Lobbying
• Meta LD-2 Lobbying Disclosures

• DCA Team and Formation
• DCA Wayback Analysis
• DCA DNS/WHOIS
• DCA Corporate Registry
• DCA Incorporation Updated

• Colorado TRACER Findings
• FollowTheMoney Multi-State Search

• Cross-Reference Anomaly Analysis
• Five Threads Investigation
• NCOSE, For Good, and FEC Investigation

• Utah and Texas Findings
• Louisiana HB-570 Corrected
• Colorado GA Witness Findings

• Master Summary
• Anomaly Report
• Consolidated Findings

This investigation used Claude Code (Anthropic's CLI tool, running Claude Opus) was used as a research assistant for:

• Bulk data processing: parsing 4,433 IRS Schedule I grant records, 59,736 DAF recipients, 132MB of Colorado TRACER campaign finance data, and IRS Business Master File extracts covering all US tax-exempt organizations
• Cross-referencing findings across 24 analysis files and identifying patterns that span multiple research threads
• Drafting intermediate working documents and structured data summaries
• Web searches against public databases (OpenSecrets, ProPublica, state lobbying portals, WHOIS/DNS, Wayback Machine)

Claude Code did not independently choose what to investigate, decide what constitutes a finding, or determine what to publish. Every factual claim in this repository cites a primary source (IRS filing, Senate disclosure, state database, legislative record, or published reporting) that can be independently verified. The tool does not change whether Meta's LD-2 filing lists H.R. 3149, whether DCA has an EIN, or whether Stefanski admitted tech funding under oath. The records exist or they don't.

If you want to verify any finding, the source URLs and database identifiers are provided throughout. Start with the primary records, not with this repository.

This is an OSINT research product. All findings are based on public records. Source data is cited throughout.