Tomorrow I am testifying at a hearing of Fair Political Practices Commission Subcommittee on the Political Reform Act & Internet Political Activity. I have posted my prepared testimony here. From the Introduction:

In my brief presentation today, which is accompanied by a set of Powerpoint slides, I hope to make three main points.
First, I present what I term the “Goldilocks approach:” The appropriate model for regulation of Internet-based campaign communications should focus on the role of money in the communications and unique features of Internet-based communications, following the approach of the PRA generally.
Second, I argue that the FPPC and Legislature should carefully examine existing campaign finance regulations and laws, and they should consider appropriate and sensible revisions related to Internet-based campaign communications that further goals of the PRA.
Third, and finally, I suggest that campaign finance regulators create a safe harbor from public disclosure (especially over the Internet) for low-dollar campaign-related activities. An exemption from public disclosure (as opposed to reporting to FPPC) may be constitutionally necessary to avoid threats of harassment, and likely represents good public policy.