Headwaters Strategies: Lobbying Expenditure Report Findings
Headwaters Strategies: Lobbying Expenditure Report Findings
Data Source
Colorado Secretary of State lobbying disclosure system, accessed via the Colorado Information Marketplace (data.colorado.gov) SODA API. Dataset: “Professional Lobbyist Income in Colorado” (dxfk-9ifj) and “Professional Lobbyist Disclosure Report Summary” (df5p-p6jt). Data current as of March 11, 2026.
1. Meta Platforms / Facebook Income to Headwaters Strategies
Complete Timeline: Facebook (2019-2021) then Meta Platforms (2021-present)
Headwaters Strategies (Primary Lobbyist ID: 20095007203, ZIP 80264) reports income from Meta Platforms, Inc. (classified as Business Entity, Science/Technology industry) at the firm level, not broken out by individual lobbyist.
FY 2019-2020 (as “Facebook”)
| Month | Income |
|---|---|
| March 2020 | $5,000 |
| June 2020 | $5,000 |
| Subtotal | $10,000 |
FY 2020-2021 (as “Facebook”)
| Month | Income |
|---|---|
| July 2020 | $5,000 |
| September 2020 | $5,000 |
| October 2020 | $5,000 |
| November 2020 | $5,000 |
| December 2020 | $5,000 |
| March 2021 | $15,000 |
| May 2021 | $5,000 |
| June 2021 | $5,000 |
| Subtotal | $45,000 |
FY 2021-2022 (as “Meta Platforms, Inc.”)
| Month | Income |
|---|---|
| July 2021 | $5,000 |
| September 2021 | $10,000 |
| October 2021 | $5,000 |
| November 2021 | $5,000 |
| December 2021 | $5,000 |
| May 2022 | $15,000 |
| June 2022 | $15,000 |
| Subtotal | $60,000 |
FY 2022-2023 (as “Meta Platforms, Inc.”)
| Month | Income |
|---|---|
| August 2022 | $10,000 |
| September 2022 | $5,000 |
| October 2022 | $5,000 |
| November 2022 | $5,000 |
| Subtotal | $25,000 |
FY 2023-2024 (as “Meta Platforms, Inc.”)
| Month | Income |
|---|---|
| July 2023 | $30,000 |
| November 2023 | $14,000 |
| December 2023 | $7,000 |
| January 2024 | $21,000 |
| April 2024 | $14,000 |
| May 2024 | $7,000 |
| June 2024 | $14,000 |
| Subtotal | $107,000 |
Note: Significant jump from ~$5K/month to $14K-$30K/month beginning July 2023, coinciding with increased state-level activity on AI and children’s online safety legislation.
FY 2024-2025 (as “Meta Platforms, Inc.”)
| Month | Income |
|---|---|
| August 2024 | $14,000 |
| October 2024 | $14,000 |
| December 2024 | $14,000 |
| January 2025 | $7,000 |
| May 2025 | $8,500 |
| Subtotal | $57,500 |
FY 2025-2026 (as “Meta Platforms, Inc.” - partial, through Jan 2026)
| Month | Income |
|---|---|
| July 2025 | $8,500 |
| August 2025 | $8,500 |
| October 2025 | $8,500 |
| December 2025 | $8,500 |
| Subtotal | $34,000 |
TOTAL Meta/Facebook Income to Headwaters Strategies: ~$338,500
(Across all fiscal years from 2019-2020 through partial 2025-2026)
Other Lobbyists Receiving Meta Platforms Income in Colorado
Two additional individual lobbyists also receive income directly from Meta Platforms (likely Meta’s in-house government relations staff filing Colorado disclosures, not Headwaters personnel):
- Dan Sachs (ZIP 94965, California): ~$10,926 total (2021-2026), very small amounts ($245-$2,214/month)
- Ana Martinez (ZIP 94965, California): ~$102,015 total (2021-2026), varying amounts ($338-$8,639/month)
Combined with Headwaters, Meta’s total disclosed Colorado lobbying income payments: ~$451,441 (2021-2026).
2. Individual Lobbyist Disclosure Report Summaries
Adam Eichberg (Headwaters Strategies)
- Primary Lobbyist ID: 20095007150
- ZIP: 80264
- Registration start: 2009 (firm co-founder)
- Total monthly income trajectory:
- 2009-2010: $7,500-$8,500/month
- 2010-2013: $8,250-$9,000/month
- 2014-2015: $9,000-$10,000/month
- 2015-2018: $11,000-$12,000/month
- 2018-2023: $12,000/month (stable plateau)
- 2023-present: $15,000/month
- Annual gross lobbying income (estimated from monthly reports): ~$180,000/year at current rate
Note: These are Eichberg’s TOTAL monthly gross income from ALL lobbying activity, not broken down by individual client.
Alyson Schmidt (Headwaters Strategies)
- Primary Lobbyist ID: 20115004298
- ZIP: 80264
- Registration start: 2010
- Total monthly income trajectory:
- 2010-2011: $1,125/month
- 2011-2014: $1,000-$4,400/month (variable)
- 2014-present: $8,333.33/month (stable)
- Annual gross lobbying income (estimated): ~$100,000/year at current rate
- Client income sources identified:
- Headwaters Strategies (internal firm): $7,500-$8,333.33/month (2017-2026)
- Colorado Hospital Association (former): $1,000-$4,100/quarter (2012-2017)
- Stephens Public Affairs Group LLC (former): $400-$2,524 (2010-2015)
Amber Janelle Burkhart (Headwaters Strategies)
- Primary Lobbyist ID: 20235028945
- ZIP: 80264
- Registration start: 2022 (at Headwaters; previously registered independently since 2014)
- Prior registration (2017-2021): Under primary ID 20185000267, different ZIP (80111), monthly income $200-$792 (was at Colorado Hospital Association)
- At Headwaters Strategies (2022-present):
- 2022-2024: $6,666.66/month
- 2024-present: $7,500/month
- Annual gross lobbying income (estimated): ~$90,000/year at current rate
- Client income sources identified:
- Headwaters Strategies (internal firm): $6,666.66-$7,500/month (2022-2026)
- Colorado Hospital Association (former employer): $200-$792/month (2017-2020)
- Colorado Consumer Health Initiative (former): $120-$367/month (2014-2015)
William C. Coyne (Headwaters Strategies)
- Status: Co-founder and Principal
- Note: Coyne does not appear in the Professional Lobbyist Disclosure Report Summary (df5p-p6jt) dataset, nor in the Professional Lobbyist Income (dxfk-9ifj) dataset under any name variation tested (Coyne, William, Will). This is unusual for a firm co-founder. Possible explanations:
- May file under a different registration structure
- May operate primarily as firm principal/manager rather than as a registered individual professional lobbyist
- Income data from FY 2025-2026 summary shows “William C. Coyne: $75,000” listed as internal firm payments, suggesting he receives compensation through the firm but may not file individual disclosure reports
- The emplobrpt.pdf (Client Lobbyist Directory) lists “William C Coyne” as registered with Headwaters Strategies
3. Headwaters Strategies: Full Client Portfolio and Revenue (Recent Fiscal Years)
FY 2024-2025 Complete Client Income
(Reported at firm level, Primary ID 20095007203)
| Client | Industry | Approx. Total |
|---|---|---|
| Healing Advocacy Fund | Healthcare/Medical | $110,000 |
| COLORADO TRIAL LAWYERS ASSOCIATION | Legal | $110,000 |
| One Colorado | Non-Profit | $83,000 |
| Gary Advocacy | Financial/Investment | $86,500 |
| Everytown for Gun Safety Action Fund | Non-Profit | $72,500 |
| Colorado Care Workers United | Labor Unions | $70,000 |
| Gilead Sciences, Inc | Healthcare/Medical | $60,000 |
| Colorado Wins | Labor Unions | $56,000 |
| Centennial State Prosperity | Labor Unions | $60,000 |
| Meta Platforms, Inc. | Science/Technology | $57,500 |
| Tesla Motors | Automotive | $57,000 |
| Retail Services & Systems, Inc. | Merchandise/Retail | $57,000 |
| Charter Communications Operating, LLC | Telecommunications | $49,000 |
| AIRBNB | Science/Technology | $51,000 |
| Environmental Defense Action Fund | Science/Technology | $47,000 |
| 5280 STRATEGIES LLC/CITY OF BLACK HAWK | Government | $49,500 |
| TRAILS | Mental Health | $45,000 |
| City of Boulder | Government/Civil | $40,000 |
| Arizona College | Education | $40,000 |
| Vivid Seats | Entertainment/Recreation | $39,000 |
| Inseparable Action, Inc | Mental Health | $35,500 |
| The Bell Policy Center | General Business | $28,000 |
| Business for Water Stewardship | Environmental Services | $25,000 |
| Patient Rights Advocate | Healthcare/Medical | $25,000 |
| The Capstone Group, LLC/ICBC | Financial/Investment | $25,000 |
| Charm Industrial | Technology | $25,000 |
| American Heart Association | Healthcare/Medical | $20,270 |
| PBM Accountability Project | Healthcare/Medical | $40,000 |
| COLORADO INDEPENDENT ENERGY ASSOC. | Energy | $20,000 |
| Western Resource Advocates | Environmental Services | $48,000 |
| Strawberry Park Natural Hot Springs | Entertainment/Recreation | $20,000 |
| Denver Zoological Foundation | Education | $10,000 |
| Colorado Nature League | Wildlife Conservation | $15,000 |
| Coloradans for Legal Freedom | Attorney/Legal | $15,000 |
| COLORADO RIVER OUTFITTERS ASSOC. | Recreation | $10,000 |
Estimated FY 2024-2025 total firm revenue: ~$1.6-1.8 million
FY 2023-2024 Complete Client Income (Selected Large Clients)
| Client | Approx. Total |
|---|---|
| Healing Advocacy Fund | $120,000 |
| COLORADO TRIAL LAWYERS ASSOCIATION | $120,000 |
| Meta Platforms, Inc. | $107,000 |
| One Colorado | $65,000 |
| People United for Privacy | $64,000 |
| Colorado Wins | $62,000 |
| Charter Communications | $56,000 |
| Gary Advocacy | $56,000 |
| Arizona College | $55,000 |
| City of Boulder | $55,000 |
| AIRBNB | $52,000 |
| Charm Industrial | $45,000 |
| Centennial State Prosperity | $44,000 |
| Vivid Seats | $39,000 |
| Environmental Defense Action Fund | $38,500 |
| Everytown for Gun Safety | $37,500 |
| TRAILS | $36,000 |
| Tesla Motors | $36,000 |
| Business for Water Stewardship | $35,000 |
| Colorado Care Workers United | $35,000 |
| The Bell Policy Center | $32,000 |
| Retail Services & Systems | $30,000 |
| Ryman Hospitality Properties | $28,516 |
| RXN Group | $27,500 |
| Western Resource Advocates | $27,498 |
| American Heart Association | $25,000 |
| 5280 Strategies/City of Black Hawk | $22,500 |
| Colorado Nature League | $20,000 |
| The Capstone Group/ICBC | $20,000 |
| Coloradans for Legal Freedom | $15,000 |
| COLORADO INDEPENDENT ENERGY ASSOC. | $14,000 |
| Denver Zoological Foundation | $8,750 |
| COLORADO RIVER OUTFITTERS ASSOC. | $4,165 |
Estimated FY 2023-2024 total firm revenue: ~$1.5-1.7 million
NOTE: Meta Platforms was Headwaters’ 3rd largest single client in FY 2023-2024 at $107,000, behind only the Colorado Trial Lawyers Association and Healing Advocacy Fund (both at $120,000).
FY 2025-2026 (partial, through ~Jan 2026)
Estimated total firm revenue (annualized): ~$1.0-1.1 million (partial year) Meta Platforms income so far: $34,000
4. Meta Lobbying Expenditure Trends: Key Observations
Income Escalation Pattern
Meta/Facebook’s payments to Headwaters Strategies show a clear escalation pattern:
| Period | Monthly Rate | Annual Equivalent | Context |
|---|---|---|---|
| 2019-2020 | $5,000 (sporadic) | ~$10,000/year | Minimal engagement |
| 2020-2021 | $5,000-$15,000 | ~$45,000/year | Growing engagement |
| 2021-2022 | $5,000-$15,000 | ~$60,000/year | Rebranded to Meta |
| 2022-2023 | $5,000-$10,000 | ~$25,000/year | Lower year |
| 2023-2024 | $7,000-$30,000 | ~$107,000/year | Major escalation |
| 2024-2025 | $7,000-$14,000 | ~$57,500/year | Sustained high level |
| 2025-2026 | $8,500 | ~$34,000 (partial) | Ongoing |
The July 2023 Spike
The single largest monthly payment from Meta to Headwaters was $30,000 in July 2023. This coincided with:
- Growing national momentum on children’s online safety legislation
- Meta’s strategic pivot to supporting app-store-level age verification (shifting burden to Apple/Google)
- The Digital Childhood Alliance’s formation and activity
- Colorado’s increased focus on tech regulation bills
Meta as Share of Headwaters Revenue
- FY 2023-2024: Meta at ~$107,000 = approximately 6-7% of total firm revenue
- FY 2024-2025: Meta at ~$57,500 = approximately 3-4% of total firm revenue
- While not Headwaters’ largest client, Meta is a significant technology sector client alongside Charter Communications, AIRBNB, Tesla, and Charm Industrial
5. Digital Childhood Alliance (DCA) Connection
What Was Found
- No direct lobbying registration linking Headwaters Strategies to the Digital Childhood Alliance was found in CO SOS records
- No DCA expenditure or income appears in the Headwaters Strategies disclosure data
- The DCA is organized as a 501(c)(4) which does not require donor disclosure
- Meta has been reported to fund the DCA, but DCA refuses to name specific funders
- The DCA pushes app-store-level age verification, which is the same policy position Meta advocates for
Gap Analysis
The connection between Headwaters Strategies’ lobbying for Meta and DCA’s advocacy work in Colorado cannot be established through CO SOS lobbying disclosure records alone. If DCA engages lobbyists in Colorado, those would be filed under separate registrations.
6. Colorado Disclosure System Structure and Limitations
What Is Disclosed
- Monthly disclosure reports: Gross income for lobbying activities, subjects/bills and positions taken, expenses (media, gifts/entertainment, other), direct business associations
- Annual cumulative statement: Total gross income for lobbying for the fiscal year, due by July 15
- Income is reported at the FIRM level by client, not broken down to show which individual lobbyist served which client
- Individual lobbyists report their total monthly gross income from ALL lobbying (a single figure, not client-specific)
Key Limitations
- Colorado does NOT require clients/principals to disclose how much they pay to lobbyists; the disclosure obligation falls on the lobbyist/firm
- Colorado was criticized by the Center for Public Integrity for lack of transparency on lobbyists
- Individual lobbyists report only their total monthly gross income, making it impossible to determine from these records alone which specific clients each individual lobbyist (Eichberg, Schmidt, Burkhart, Coyne) serves
- The monthly figures represent “gross income for lobbying activities” which is a percentage of total compensation proportional to time spent lobbying
Data Accessibility
- Data is publicly available via the Colorado Information Marketplace API (data.colorado.gov)
- Key datasets: df5p-p6jt (Disclosure Report Summary), dxfk-9ifj (Professional Lobbyist Income by client)
- Data updates weekly (Mondays) from the SOS disclosure system
7. Other Notable Clients of Interest
Several Headwaters clients have policy interests that may intersect with Meta’s:
- People United for Privacy ($64,000 in FY 2023-2024): Privacy advocacy that could align with Meta’s opposition to certain data privacy regulations
- Charter Communications (~$49,000-$56,000/year): Telecommunications company with shared tech regulation interests
- AIRBNB (~$51,000-$78,000/year): Another major tech platform client
- Tesla Motors (~$36,000-$57,000/year): Another major tech company client
Headwaters’ client mix spans progressive nonprofits (One Colorado, Everytown for Gun Safety, Environmental Defense Action Fund), labor unions (Colorado Wins, Colorado Care Workers United), government entities (City of Boulder), healthcare organizations (Healing Advocacy Fund, American Heart Association), and major corporations (Meta, Tesla, AIRBNB, Charter, Gilead Sciences).
8. Adam Eichberg: New Venture Fund Connection
Adam Eichberg serves as Chair of the Board of the New Venture Fund (NVF), one of the largest fiscal sponsors in the U.S., managed by Arabella Advisors. He was also a founding board member of Windward Fund. Both are prominent dark money conduits. This dual role - lobbying for tech companies through Headwaters Strategies while chairing a major dark money fund - represents a significant nexus of political influence in Colorado and nationally.
Sources
- Colorado Information Marketplace - Professional Lobbyist Income: https://data.colorado.gov/Legislative/Professional-Lobbyist-Income-in-Colorado/dxfk-9ifj
- Colorado Information Marketplace - Disclosure Report Summary: https://data.colorado.gov/Legislative/Professional-Lobbyist-Disclosure-Report-Summary-in/df5p-p6jt
- Colorado SOS Online Lobbyist System: https://www.sos.state.co.us/lobby/Home.do
- Colorado SOS Annual Disclosure FAQs: https://www.coloradosos.gov/pubs/lobby/FAQs/annual.html
- Colorado SOS Monthly Disclosure FAQs: https://www.coloradosos.gov/pubs/lobby/FAQs/monthly.html
- Denver Post - Colorado lobbying law transparency: https://www.denverpost.com/2016/02/27/colorado-lobbying-law-offers-murky-picture-of-influence-on-politics/
- New Venture Fund - Adam Eichberg: https://newventurefund.org/who-we-are/board-of-directors/adam-eichberg-chair-of-the-board/
- Headwaters Strategies: https://headwatersstrategies.com/
- Meta Political Engagement: https://www.meta.com/people-practices/meta-political-engagement/