During a third season episode of NBC's The West Wing (“Gone Quiet,” which originally aired on November 14, 2001), staffers of fictional president Josiah Bartlett convened to plan strategy for Bartlett's upcoming re-election campaign. When the conversation turned to campaign advertising, Toby (the president's communications director), Sam (Bartlett's speech writer), Bruno (the campaign manager), and Connie (Bruno's assistant) had the following exchange1:
TOBY: Look, we can't spend soft money on a primary ad any-
SAM: No, he's passing the magic words test.
TOBY: What magic words test?
SAM: The US Supreme Court, Buckley v. Valeo. The court cre-
ated a loophole by ruling [that hard money] only applies to
communications that in express terms advocate the elec-
tion or defeat of a clearly-identified candidate for federal
BRUNO: You don't put “vote Bartlett” in the ad, you can pay for
it with unmarked bills from a bank heist if you want to.
CONNIE: And we should know. There's also endnote 52, where
the Court said campaign-finance laws only apply to com-