Lack of evidence to show coordination for an in-kind contribution, with caution to all campaigns 

There is also no evidence that Portland for All made, or Carmen for Portland received, an in-kind contribution in the form of a candidate endorsement video or related communications.

The Auditor’s Office reaches this conclusion due to the lack of evidence supporting coordination between Portland for All and Rubio to create, post or disseminate the endorsement video. Rubio and her campaign were not involved in coordinating to create the endorsement video or any decisions about it, as documented in the determination letter. Without coordination, a communication made for the benefit of a candidate is not an in-kind contribution to the candidate. In this case, the lack of coordination meant the video and related communications did not constitute a contribution to the Carmen for Portland campaign.

The Auditor’s Office cautions, however, that though it concludes there was not coordination between Rubio’s campaign and Portland for All in this case, the communications between the two entities walked a fine line. The Auditor’s Office uses this determination to educate candidates and their supporters about where the Auditor’s Office will draw that line.