Colorado TRACER Campaign Contribution Analysis

Research Date: 2026-03-12 Data Source: Colorado Secretary of State TRACER Bulk Data Downloads (2024-2026) URLs: https://tracer.sos.colorado.gov/PublicSite/Docs/BulkDataDownloads/ Records Searched: ~132M of CSV data (65MB 2024, 50MB 2025, 17MB 2026)

Executive Summary

Analysis of Colorado TRACER bulk campaign contribution data found that neither Adam Eichberg nor Will Coyne contributed directly to ASAA bill sponsors Matt Ball or Amy Paschal. However, a Meta Product Manager (Jake Levine) contributed $1,175 to Matt Ball’s campaign and leadership PAC, and a Google Policy Manager (Kyle Gardner) contributed $450 to Ball’s campaign. Both Eichberg and Coyne made extensive personal contributions to Colorado Democratic candidates ($10,176 and $10,035 respectively), listing “Headwaters Strategies” as their employer and “Lobbyist” or “Consultant” as their occupation.

1. Adam Eichberg - Campaign Contributions

Address: 1122 Gaylord St., Denver, CO 80206 Employer: Headwaters Strategies Occupation: Lobbyist / Consultant

2024-2026 Contributions (21 total, $10,176)

Key Observation: Eichberg gives primarily to Democratic candidates at the $450 maximum (individual contribution limit for CO state races). He contributed $1,776 to Michael Bennet’s gubernatorial campaign - the largest single recipient. No contributions to ASAA bill sponsors Ball or Paschal.

2. Will Coyne - Campaign Contributions

Address: Various Denver, CO Employer: Headwaters Strategies Occupation: Lobbyist / Consultant

2024-2026 Contributions (36 total, $10,035)

Similar pattern to Eichberg - predominantly Colorado Democratic candidates at $200-$500 levels. Notable recipients:

• Michael Bennet for Governor: $1,450
• Jena Griswold for CO: $500
• Barb Kirkmeyer for CO: $500 (Republican - bipartisan giving)
• Seligman for AG: $500

No contributions to ASAA bill sponsors Ball or Paschal.

3. Meta/Facebook Employee Contributions

Individual Meta employees making personal contributions in Colorado:

KEY FINDING: Jake Levine → Matt Ball

Jake Levine, a Meta Product Manager based in Los Angeles, CA (4157 Tivoli Ave, 90066), contributed:

• $450 to “MATT BALL FOR COLORADO” (candidate committee) on 2025-06-02
• $725 to “BALL FOR ALL LEADERSHIP FUND” (political committee) on 2025-06-02
• Total: $1,175 to Matt Ball’s campaign apparatus

Significance: Matt Ball is a Colorado State Senator who sponsors SB26-051 (Age Attestation on Computing Devices), one of three ASAA-model bills in Colorado. A Meta employee contributing to an ASAA bill sponsor’s campaign creates a documented financial connection between Meta and the legislator pushing Meta’s preferred policy.

Caveat: This is a personal contribution from an individual employee, not a PAC or corporate contribution. Colorado’s individual contribution limit is $450 for candidate committees. The $725 to the leadership fund may exceed the candidate limit because leadership PACs have different rules.

4. Other Tech Company Employee Contributions to Matt Ball

Significance: A Google Policy Manager also contributed to Matt Ball. Google is directly affected by ASAA (as an app store operator). The combination of Meta employee + Google policy manager donating to the same ASAA sponsor is notable, though both companies take opposite sides of the ASAA debate (Meta supports it, Google is required to comply).

5. Headwaters Strategies Staff - Contribution Patterns

Neither Eichberg nor Coyne contributed to ASAA bill sponsors. Their giving patterns suggest:

1. Broad Democratic support: Both give to dozens of Democratic candidates across Colorado
2. Bipartisan exceptions: Both contributed to Barbara Kirkmeyer (Republican), suggesting strategic rather than purely partisan giving
3. 2025 gubernatorial focus: Both gave to Michael Bennet’s gubernatorial campaign
4. Standard lobbyist behavior: Wide distribution of maximum-limit contributions builds relationships across the legislature
5. No ASAA-specific targeting: Neither focused contributions on the specific legislators sponsoring Meta’s preferred bills

6. Contributions TO ASAA Bill Sponsors from Investigation Targets

To Matt Ball (SB26-051 sponsor):

To Amy Paschal (HB25-1287 co-sponsor):

No contributions from Eichberg, Coyne, Headwaters, Meta PAC, or Facebook PAC to either Ball or Paschal.

7. Conclusions

What This Establishes

1. A Meta employee (Levine) contributed $1,175 to ASAA sponsor Matt Ball - documented financial link
2. A Google Policy Manager also contributed to Ball - multiple tech company employees targeting the same legislator
3. Eichberg and Coyne are prolific political donors ($20K+ combined) but did NOT target ASAA sponsors
4. No Meta PAC or corporate contributions to ASAA sponsors found in Colorado TRACER data
5. Headwaters staff contributions follow standard lobbyist patterns - broad relationship-building, not issue-targeted

What Remains Unknown

1. Whether Jake Levine’s contribution was coordinated by Meta’s government affairs team or purely personal
2. Whether Meta’s ATEP super PAC ($45M) made independent expenditures supporting Ball or Paschal
3. Whether Headwaters or Meta made contributions to PACs that subsequently contributed to ASAA sponsors (indirect pathway)

Sources

• CO TRACER Bulk Downloads: https://tracer.sos.colorado.gov/PublicSite/DataDownload.aspx
• 2024 Contribution Data: 2024_ContributionData.csv (65MB, via TRACER bulk download)
• 2025 Contribution Data: 2025_ContributionData.csv (50MB, via TRACER bulk download)
• 2026 Contribution Data: 2026_ContributionData.csv (17MB, via TRACER bulk download)