A federal election complaint filed by Americans for Public Trust alleges that Daniel J. Sullivan Jr.—nicknamed “Decoy Dan”—may have illegally coordinated with the 907 Initiative, a dark-money group that spent heavily against incumbent Republican Sen. Dan Sullivan in Alaska’s U.S. Senate race. The complaint, supported by reporting from The New York Times, claims that a consultant linked to both the 907 Initiative and the Decoy Dan campaign played a central role in the alleged coordination.
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The core issue is whether the Decoy Dan campaign and 907 Initiative violated federal election law by working together to influence the outcome of a closely contested Senate race.
The controversy comes as Alaska’s ranked-choice voting system faces scrutiny for its vulnerability to candidate confusion and ballot-stacking tactics, with the Senate race potentially affecting the balance of power in Washington.
Alleged Coordination and Complaint Details
Americans for Public Trust’s complaint to the Federal Election Commission outlines how Amber Lee, a consultant for the Decoy Dan campaign, also served as a director and corporate secretary for the 907 Initiative. The group spent nearly $1.5 million against Sen. Dan Sullivan through August, including about $575,000 in the 90 days before the August primary, according to the complaint. Federal Communications Commission records cited in the complaint show a single 907 Initiative ad buy of $112,365 for anti-Sullivan ads airing June 3-9.
The complaint alleges that Lee’s dual roles could constitute illegal coordination under federal law, which prohibits corporations from making in-kind contributions to campaigns. The law considers an ad coordinated if it is paid for by an outside group, names a candidate within 90 days of an election, and involves a shared vendor or agent. The complaint claims all three conditions are met, citing Lee’s work for both the campaign and 907 Initiative during the relevant period. Decoy Dan’s pre-primary FEC report lists $4,380.41 owed to Lee’s firm for campaign services.
"I have not been in contact with her or her campaign."
— Daniel J. Sullivan Jr., candidate
Recruitment Allegations and Ballot Confusion
The New York Times reported that aides to Democrat candidate Mary Peltola and the Democratic Senatorial Campaign Committee sought out individuals named Dan Sullivan in Alaska, with Jerid Kurtz, a DSCC-linked operative, traveling to Petersburg before Decoy Dan filed his candidacy. Peltola’s campaign and the DSCC deny recruiting anyone, and Decoy Dan has maintained through his attorney that his campaign is genuine.
Texts reviewed by the Times suggest Peltola advisers discussed a scheme to confuse voters, referencing a focus group and expressing confidence that voters could be misled by a spoiler candidate. Alaska’s ranked-choice voting system, which lists Decoy Dan as “Sullivan, Daniel J. Jr.” above the incumbent “Sullivan, Dan S.” on the ballot, has drawn criticism for enabling such confusion. In the August primary, Decoy Dan received 2.5% of the vote, with polls showing the race within 1-2 percentage points.
Responses and Ongoing Investigations
The 907 Initiative has stated it is “in full compliance with applicable campaign finance laws, including federal coordination rules.” Lee has said she is an unpaid board member who does “not manage [907’s] independent expenditure activity.”
Alaska Division of Elections Director Carol Beecher decertified Decoy Dan’s candidacy, finding it was not filed in good faith, but Alaska courts allowed him to remain on the ballot without ruling on intent. Gov. Mike Dunleavy has ordered a state investigation, citing new reporting that “substantially supports” the Division of Elections’ findings, and federal prosecutors have reportedly issued subpoenas.
The complaint notes that whether any violation was “knowing and willful”—a threshold for felony charges—remains undetermined and would require proof of intent. No charges have been filed, and the article notes that only investigators can determine the facts. Lee reportedly left the campaign in mid-August but remains on the 907 Initiative board.
The FEC complaint and ongoing investigations are expected to clarify whether campaign finance laws were breached and if further action will be taken.
