In the Supreme Court’s most recent campaign finance case, McCutcheon v. FEC, a bare majority of the Court struck down aggregate contribution limits for individuals. Whereas an individual’s total campaign contributions in a given two-year federal election cycle were previously limited to $123,200, individuals may now give as much as $3.6 million. McCutcheon has been praised for pushing campaign cash away from “shadow money” nonprofits and into the sunshine of disclosure, because it clears the way for donors to give large amounts to an unlimited number of candidates—a type of spending that is subject to disclosure obligations, unlike donations to 501(c) nonprofit groups. According to this line of thinking, deregulation not only increases the total amount of speech in the marketplace of ideas, but also tends to increase transparent speech. Chief Justice Roberts, writing for the plurality in McCutcheon, conveyed this idea when he wrote that aggregate limits “may in fact encourage the movement of money away from entities subject to disclosure.” Indeed, Professors Samuel Issacharoff and Pamela S. Karlan made just this contention fifteen years ago.