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[8] The Supreme Court recognized that [a] restriction on the amount of money a person or group can spend on political communication during a campaign necessarily reduces the quantity of expression by restricting the number of issues discussed, the depth of their exploration, and the size of the audience reached. [9] Similar to the reaction to the law enacted in the 1940s in which labor unions created PACs to get around the law, the individuals and groups regulated by the 1974 FECA amendments instituted new campaign practices to cope with the law

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One of the ways the Washington bureaucracy responded was to institute a requirement that all outreach workers had to be college-educated as a condition of their employment