During the 2004 election cycle, Americans went online in unprecedented numbers to obtain and exchange information about candidates and campaign issues. In addition to facilitating political debate, this explosion of online political activity has galvanized substantial expenditures of money - over $ 27 million was spent on online advertisements, e-mail list services, and other Internet activities during the 2004 elections alone. Because the pervasiveness of online campaign activity and related expenditures is only expected to increase in the coming years, the question of how campaign finance law should regard such activity is of both immediate and increasing importance.

The Internet is distinct from other media in that the low cost of entry and continued use makes speech possible for a broad cross-section of the general public. The medium's low-cost character is central to the campaign finance question insofar as it permits a broader pool of participants. Whereas the opportunity to be heard in television, radio, or print news must generally be purchased at substantial cost, anyone with access to a computer and a phone line can express her views online. "Marginalized voices [and] dissenting viewpoints ... flourish in the weblog universe" and can have a meaningful presence in that forum without expending substantial funds. The sheer volume of online political actors makes it less likely that monied parties will be able to dominate political debate on the Internet, as they can in other media...