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 Documentationcontains the complete OSINT investigation report with all five channels, evidence tables, and source citations.

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

Research Timelinetracks 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.)
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:
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.

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