large contributions from individuals. The presidential elections in 2004 were largely affected by the section 527 organizations, where approximately 175 million was raised for presidential election campaigns. However, this changed with the presidential elections in 2008. Both the Democrats as the Republicans had reduced their reliance on section 527 organizations. They shifted towards the dependence on hard money, which is directly specified to a candidate. There were some reasons that the parties found new ways to use hard money. For example, there was more focus on grassroots fundraising activities. A grassroots movement is a movement which uses the people in a certain area as the basis of a political movement, so its bottom-upwards instead of top-down decision making. Furthermore, the internet was also used more extensively to raise money for campaigns. Despite the fact that it was mostly small money donations, it helped to raise an extensive amount of funds for their campaigns. At last, both the Democrats as the Republicans made use of so-called bundlers. These are individuals which are identified with the campaign that collect individual donations. Since the BCRA act increased the limit of donations to political parties, they had to use this third party as an exploit. In this way they could raise money for their campaign, but not with limitations of the act. (Matthew A. Melone)?Citizens United vs. FEC Citizens United, a non-profit corporation with an annual budget of approximately 12 million, released Hillary: The movie in January 2008. This movie was focused on the sole reason of criticising Hillary Clinton. She was a candidate of the Democratic party presidential elections at that time. This movie was broadcasted and largely promoted all over the country. The problem, however, was that the broadcasting of this movie was within the thirty days of the presidential elections, which was prohibited according to the McCain-Feingold act. As earlier mentioned, any broadcast communication which clearly identifies a candidate for an election within 30 days is prohibited. Citizens United feared that their movie conflicted with this legislation, and therefore they sought declaratory and injunctive relief against the FEC, where they noted that the act was unconstitutional. The district court denied this request and ruled that the act was constitutional and that this could also be applied to Hillary: The movie and all the advertisements about this movie. However, in 2009 the Supreme Court requested from both parties, Citizens United and the FEC, that they filed supplemental briefs whether the court should overrule the act of McCain-Feingold. (Matthew A. Melone), (Citizens United v. Federal Election Commission). In the Supreme Court, in short, it came down to the sole question whether the First Amendment had any right to prohibit corporations from engaging in political speech. The First Amendment states: ” Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the government for a redress of grievances.” (LII Staff,) The court ruling was that corporations were free in spending money on electioneering communications and therefore, it overruled the McCain-Feingold’s act. Furthermore, it also overruled Austin v. Michigan Chamber of Commerce, which stated that corporations were prohibited to use treasury money to oppose or support candidates in elections. Basically, corporations were after this case free to spend money on both, to advocate for the election of candidates, as on spending money on electioneering communications. The motivation was that the First Amendment did not allow the prohibition of corporations to use their right of free speech since its forbidden to distinguish between the identity of the speaker. Furthermore, for corporations, it is necessary to spend money to speak effectively on political issues, so its unconstitutional to prohibit this. The court overruled the Austin case on a couple of points because of several reasonings.