Welcome to the Lobby Bar: Battleground 2025 – Navigating Pay-to-Play Laws

Episode Summary

On the inaugural episode of “The Lobby Bar” podcast, partners Charlie Ricciardelli and Tyler Rosen unpack the complexities of pay-to-play rules in New Jersey, Virginia and New York City. These jurisdictions all have “off-year” elections in 2025, with some featuring liability laws that can potentially knock companies out of government contracts based on violations.

Key Points

• New Jersey Features Rules That Could Impact Government Contracts: New Jersey has strict regulations on pay-to-play rules that could trigger bans on companies from holding or receiving government contracts that can last for the duration of an elected official’s term.
• Virginia Less Strict But Companies Must Be Mindful: Virginia’s rules include gift provisions and apply during pending bids.
• New York City Has a Different Structure: New York City’s rules allow candidates to self-police political contributions to ensure they are under the prescribed limits. There is no legal liability for a company as a whole, but there is liability for a company’s covered donors.
• Importance of Pre-Clearance: Pay-to-play rules are varied and can implicate federal regulations as well. Companies and organizations should be mindful of having a pre-clearance process in place to ensure compliance.

Voiceover (00:00):
From Skadden, you are listening to The Lobby Bar, a political law podcast where we strive to make political law accessible and hosts Charlie Ricciardelli and Tyler Rosen deliver practical insights on the compliance challenges and regulatory developments that matter to legal, compliance and government affairs professionals across all industries.

Charles Ricciardelli (00:23):
Hi, I’m Charlie Ricciardelli.

Tyler Rosen (00:24):
And I’m Tyler Rosen.

Charles Ricciardelli (00:26):
We’re partners in political law at Skadden, Arps in Washington DC, and welcome to The Lobby Bar, our inaugural episode of a political law podcast. In all full disclosure, the firm came to us and asked us to have a podcast, and it turns out they’re interested in political law, we’re interested in political law, but really, I think, part of the issue is that we are the only people left who don’t have a podcast, at least over the age of 14. So, here we are. Tyler, do you want to do a little bit about what we plan to do here?

Tyler Rosen (00:52):
Yeah, I mean, I think we thought it would be a good opportunity to chat about political law, which is something that we both love doing and it’s pretty interesting, I mean, as far as areas of the law go, and hopefully, you all find it interesting and enjoy it too, in which case we’ll keep doing it.

Charles Ricciardelli (01:04):
The plan here is to pick apart different components of political law that we find particularly interesting. Obviously, any developments that we think folks should know about, or again, just things that we think warrant a deeper dive. And so, today’s episode, we’ve picked Battleground 2025, for lack of a better title, where we’re going to unpack some unique political law issues that companies are facing, frankly, in this off-year election, specifically in Virginia, New Jersey and New York City.

Tyler Rosen (01:35):
That’s right. So, we’re going to get deep into the platforms of the candidates. We’re going to hear about what they’re running on, and then we’re going to wrap it up with Charlie’s Choices, the big Ricciardelli endorsement that everybody’s looking for.

Charles Ricciardelli (01:44):
Exactly. So, we’re absolutely doing none of those things for any number of reasons, not least of which is it’s hard to imagine or hard to conjure anything less valuable than my political hot takes or predictions and certainly endorsements. More seriously, we obviously relish the fact that we’re a nonpartisan practice.

(02:03):
So, if you came here for hot political takes, unfortunately you’re probably going to have to make do with mildly amusing, hopefully political observations and deep dives into political law. So, what we do want to do, however, is talk about some common themes that we see in the off years in again, Virginia, New Jersey and New York City.

Tyler Rosen (02:24):
That’s right. And the thing that New Jersey, New York City, Virginia all have in common, of course, is that all places where Charlie has lived, which is why we picked them.

Charles Ricciardelli (02:33):
Yeah, more specifically, they all have pay-to-play rules. So, I think although I have lived in all those places, I think the audience may be slightly more interested in us unpacking the pay-to-play rules in those jurisdictions.

(02:43):
Political law never takes a year off. Again, just because we’re not in a “election year,” these off-year elections have potential pay-to-play implications. So, let’s talk about them and we’re going to unpack, then in turn, we’ll talk about New Jersey, we’ll talk about Virginia and we’ll talk about New York City and we’ll talk about how these laws are a little bit different.

(03:00):
And then, try to wrap a little bit of a bow on it at the end with kind of a, so what should folks be doing about these laws, these and others, obviously. But why don’t we start, and I’ll just kick it off by level setting with what pay-to-play laws are. I suspect if you clicked into this podcast, there’s a decent chance you have an idea, but maybe not, and hopefully we’ve got some.

Tyler Rosen (03:19):
Welcome.

Charles Ricciardelli (03:20):
Exactly. We may have some new listeners. So, when we talk about pay-to-play laws, specifically what we’re about to talk about are strict liability pay-to-play laws, which are a raft of federal, state and local laws that can interfere or prohibit a company from doing government business as a result of political contributions made by the company, made by its PAC, and even made by some personnel, employees, officers or directors, and these are strict liability in nature.

(03:46):
Unlike under bribery statutes or honest services fraud, there doesn’t have to be any connection to a government decision or trying to get a contract, right? There’s got to be no corrupt intent behind them. They are really foot-fault laws where if you make a contribution, even with the best of intentions, motivations, purely personal contributions, you can trigger application of one of these pay-to-play rules.

(04:08):
And what is triggering that mean? In a lot of jurisdictions, it is an automatic timeout on entering into government contracts or under the federal rules, for example, the SEC rule, a ban on accepting compensation for doing the business. So, really serious penalties obviously, right? For companies out there that are doing a lot of state and local government business, this is a big deal, because it can knock you out of those contracts.

(04:32):
They don’t all work that way, but that is a common theme, and even if there isn’t a specific provision that knocks you out of business, that’s always lurking in the background as a possible repercussion for violating them. So, we’ll step through all of that, but while I have, in fact, it’s true, lived in New Jersey and Virginia and New York City, Tyler is born and bred in New Jersey, so I’m going to let him unpack the vagaries and mysteries of New Jersey pay-to-play for a little bit.

Tyler Rosen (04:57):
Yeah, I am a born and bred New Jerseyan, and so is there anything that I say about New Jersey over the next few minutes that may seem derogatory, it’s coming from a place of love. So, New Jersey has one of the older bodies of pay-to-play laws that are out there, and they date back to the mid-2000s and like a lot of pay-to-play rules, they emerged out of corruption scandals. New Jersey’s had some sort of colorful ones over the years, and this time there was an investigation into folks around the governor.

(05:28):
The governor at the time was recorded on a wire using the word Machiavelli with a businessman, and the allegation never ultimately was charged and prosecuted. The allegation certainly in the press was that that was the code word that meant that pay-to-play scheme was on.

(05:42):
I did some reading in preparation for this podcast, and apparently, defenders of the then-governor say that he was just really into Machiavelli and there was a decent chance at any given conversation, he might just talk about Machiavelli because he’s into Florentine political philosophy. But anyway, upshot is we ended up with pay-to-play rules in New Jersey and we ended up with a lot of them.

(06:00):
New Jersey - little known fact, is the state with the highest population density - and for many years, it was also the state with the highest pay-to-play law density. Under state law, every local jurisdiction was supposed to have its own pay-to-play rule. Most of them did, but finding them was a whole ordeal that they actually were supposed to send a copy of their pay-to-play rule into the State Department of Community Affairs.

(06:22):
And so, there was this department of community affairs website with old scanned copies of faxes of Haddonfield Township’s pay-to-play rule and whatever, and sometimes it didn’t match up with what was actually in the county or city code online. It was a whole maze to wander through.

Charles Ricciardelli (06:38):
It was as close to having to actually go to the Department of Community Affairs and pore through their files as you could actually do online. It was not efficient.

Tyler Rosen (06:47):
That’s right. And then, in 2023, the state relieved us of this obligation that amended the campaign finance law in a bunch of different ways. One of which was to negate all of these local pay-to-play rules. So now, we’re down at least just in the single digits of pay-to-play rules in New Jersey instead of several hundred.

(07:05):
So, let’s talk through those pay-to-play rules and focus on some of the bigger ones as an example. The main one that we sometimes refer to as the vendor pay-to-play rule, or the main ban type pay-to-play rule is under something called Chapter 51, which is significant for contributions to the governor, to the lieutenant governor and for the candidates for both of those offices.

(07:26):
Prior to 2023, it was broader. It covered contributions to the state party, to the legislative leadership committees and sort of a bigger thing. But even still, it covers the governor now. And in terms of the covered donors whose contributions implicate this rule, it’s a little bit like the Bill Hader-Stefon character from Saturday Night Live.

Charles Ricciardelli (07:44):
No, no. I’m sorry. I realized this is a podcast and my shaking my head isn’t going to get it done. No, I have no idea what you’re talking about. I don’t know if I’m dating myself or if I’m just revealing myself to be not particularly interesting or both. I don’t know who that is.

Tyler Rosen (07:59):
I think it’s more the latter. It was like a SNL character from 10 to 15 years ago. He was like the New York City club kid basic archetype who would be brought on as a recurring character until we could give updates about the places where tourists should go.

Charles Ricciardelli (08:14):
Oh, okay. Is this an evolution of the Night at the Roxbury guys, but in New York?

Tyler Rosen (08:20):
A little different, but maybe, I don’t know, a different generation. But anyway, his whole thing would be like in this case be like New Jersey’s hottest club is Chapter 51, it’s got everything. You’ve got covered for donors are the company, its subsidiaries, 10% owners and officers of a corporation, partners of a partnership, members of an LLC, shareholders and officers of a professional corporation, priors of sole proprietorship, PACs controlled by any of those. And then for any of the individuals, their spouse, civil union partner or resident child.

Charles Ricciardelli (08:52):
I’m not sure Bill Hader made this much more fascinating to go through covered donors.

Tyler Rosen (08:56):
Well, yeah. I mean, most of the things that he would include at these clubs are not things that we can talk about on a law firm podcast. But anyway, the point is it’s a bunch of different people and it depends on the type of legal entity that is doing business with the government. And so, it’s a broad law and it’s a specific law in terms of what it covers.

(09:16):
This Chapter 51 generally has a $200 de minimis exception, and the way that works is it exempts out contributions that are not reportable or not itemizable under New Jersey’s Campaign Finance Law, which is $200. And the thing is that it can result in a ban on business, just as Charlie said earlier, and that ban can last for a long time. The default is for it to last 18 months, but if the contribution is to a successful candidate for governor, then it actually lasts through the term of that governor.

(09:44):
So, if somebody gave to one of the gubernatorial candidates that’s running right now, if they gave in the spring, for instance, and that candidate wins, the company’s knocked out of business all the way through 2030, or January 2030, when the governor’s, soon-to-be governor elect term ends. It’s a pretty long tail on a political contribution that might just be $250.

(10:06):
The second rule that’s worth talking about, I think, and it’s actually sort of split, it’s now two rules. For a long time, we always thought about it as the state investment council pay-to-play rule. Now, there’s also the Police and Firemen’s Retirement System rule since New Jersey started an additional state pension fund, and the rules there are basically the same. And there, it covers a totally different group of covered donors, all of officers and directors and all that. It’s different.

(10:30):
The term that these rules use is IMP, which actually does sound like something that would’ve been in the Stefon sketch, but IMP is just short for Investment Management Professional, which means a few different things. I mean, somebody who solicits pension fund business and somebody who’s involved in providing investment advisory services to a New Jersey State plan, certain management personnel as well. But the point is it’s a different universe of people, maybe with some overlap, from what you have under Chapter 51 and also under the federal pay-to-play rules.

(11:00):
The rule has a totally different de minimis exception too. It’s $250, but only if you can vote for the candidate. If you can’t vote for the candidate, it applies broadly to any state candidate, even legislators, and to state party committees and the like, if you can’t vote for the candidate, there is no de minimis. So even investment advisors that have robust frameworks for dealing with the SEC pay-to-play rule, we’ll find gaps when it comes to the state investment council and the police and firemen’s systems rules.

(11:28):
The other rare thing for a state pay-to-play rule that you see with the SIC piece is that there’s a look back. Most state and local pay-to-play rules just cover contributions by somebody who is, at the time of the contribution, covered, however, covered is defined under that law. The state investment council and police and fireman’s rule covers somebody up to 12 months prior to their becoming an IMP. And so, it creates a challenge for companies that are moving people either into an IMP role or hiring when they could become an IMP, they’re thinking about those contributions.

(12:02):
The next pay-to-play role in our tour of New Jersey pay-to-play rules is the redeveloper executive order. And this one, look, I mean, as a New Jerseyan, I think it’s important just to be blunt about what it is. It is a rule that is specifically designed, it’s an executive order specifically designed to cover, to address corruption in the redevelopment of toxic waste sites and other sites in need of environmental remediation. I think historians, they look back at laws that as a society enacts as a reflection of that society.

(12:32):
I mean, I guess, you could look at it the other way and say at least New Jersey was tackling this problem and not letting that corruption fester, but it’s a commentary I think perhaps on my state of birth. And that one is, in some ways, pretty similar to Chapter 51, but it addresses that specific type of government interaction that’s redevelopment agreements for those properties in need of remediation.

(12:51):
There’s also Chapter 19 that covers all sorts of other pieces of it for school boards and local jurisdictions. It’s less of an issue usually for companies because it only applies to contributions by the company itself, and its 10% owners. So, it’s a sort of a narrower rule in terms of the covered donors.

(13:06):
And then finally, the last piece of what New Jersey has in pay-to-play is a reporting requirement. Separate and apart from these bands, there’s a Chapter 271, which gets at disclosure of political contributions, and that has two parts. One is a certification and disclosure requirement at the time of being awarded the contract and tied to a specific government contract.

(13:27):
And then, it also has an ongoing annual report, which is filed with ELEC, the state campaign finance regulator called FORM BE, where you may have to report contributions. And what’s interesting about that is it is just a disclosure requirement. And so, on some level, you could say, “Well, gee, we just need to track this stuff and then we’ll report what we need to report.”

(13:47):
The challenge is that if a company actually has reportable contributions on FORM BE, it has an obligation then to itemize the contracts that it has with state and local governments in New Jersey, which for some companies is not a big deal, but it actually can be quite a task to try to identify all of those contracts and report them.

(14:05):
And also, covered donors, again, are slightly different. It covers directors, it has a specified definition of officer with a component elements of that. So again, it’s just another overlay and complication in thinking about how to evaluate contributions in New Jersey.

(14:19):
To put a bow on it for New Jersey before we give it to Charlie for the other jurisdictions, I’m struck by that “Hamilton” line, “Everything’s legal in New Jersey.” I think Lin-Manuel Miranda, very talented at a lot of things, but not an expert on New Jersey pay-to-play rule because very little is legal in New Jersey when it comes to political contributions by firms that are doing government business.

(14:39):
It’s a real thing there, I would say. The agencies are very attuned to. They are making you certify in these jurisdictions. It’s something that bidders are attuned to. You actually see bid contests in New Jersey where a losing bidder says, “Well, we lost this bid, but we should disqualify that other bidder because they’ve violated these pay-to-play rules.” It’s not like there are some jurisdictions out there where you’ve got legacy laws from the 1970s that are like nobody’s thought about in a long time. They’re like Ozymandias out there in the desert. New Jersey is a very, very active jurisdiction when it comes to pay-to-play rules.

Charles Ricciardelli (15:14):
Active, and it’s a real thicket, which you’ve already alluded to or mentioned. You really need to make sure you’re taking all of the different rules into account, including the reporting piece of this. And it really echoes in other parts of political law as well to make sure that you are applying the right laws. And that sounds simple and maybe obvious, but it isn’t all the time, right?

(15:35):
When you’re talking about gift laws, some people will just go to the general gift law or in the ethics code and forget about specific lobbyist provisions, procurement code restrictions, et cetera. Similarly, here, if you’re, and Tyler mentioned this, you’re focused on the SEC rule, you could easily lose sight of the SIC rule or these reporting provisions. So, you really need to make sure that you’re evaluating the requests that come in through whatever program/pre-clearance program you have in place, holistically.

Tyler Rosen (16:02):
We’ll get questions, give us the bottom line, what can people give in New Jersey? And it’s like, there’s no answer to that question. It’s so fact-specific in terms of who the covered donor is and what your business is.

Charles Ricciardelli (16:11):
Yeah, that’s right. I’m going to step through Virginia and New York City much more quickly because they’re simpler and there aren’t 8 million rules as there are in New Jersey, which is helpful. It sets up, and I counterpoint to Tyler’s “Hamilton” reference, when you look at Virginia and you look at it from a campaign finance perspective, you think, “Well, pretty much everything is legal in Virginia because they don’t have campaign finance limits, corporations can give in Virginia.” In that regard, it’s a little bit of a free for all. So, we’re done. We can go home. No issue.

(16:43):
Now, so fast, there is a pay-to-play law in Virginia. It was passed in 2010. It’s very different, and it’s different in some meaningful ways. It’s not that different in terms of covered donors. Some of the same suspects show up here: contributions by the company, contributions by officers and directors can trigger this rule. In terms of covered recipients, you’re looking at giving to the governor. If the governor has a PAC, cabinet secretaries, it’s a little bit unusual given that Virginia governors are limited to one term, that the secretaries aren’t elected.

(17:14):
Makes a little bit more sense when you realize, and here’s a fun curveball, it also covers gifts, right? Everything we’ve been talking about has been in the political contribution space, but don’t lose sight of the fact that there are pay-to-play rules that are triggered by providing gifts, things of personal value to public officials, like take them to a baseball game or dinner, et cetera. So, in that context, it makes a little bit more sense.

(17:34):
Where it’s meaningfully different, however, is you have a little bit less of this crystal ball problem. You can make a contribution in New Jersey and trigger a ban for frankly, up to five and a half years. In Virginia, it’s different. You actually have to give during a proceeding or during the pendency of a bid under certain laws. So, it’s circumscribed, right?

(17:56):
I mean, it’s still on the books, it’s still a legal issue, you still need to be vetting for it, but it’s potentially easier to deal with, although we’ll talk a little bit about that in a minute, but it’s at least theoretically knowable. Are we in the midst of a contracting process under these laws? If not, then we don’t have an issue under the pay-to-play law.

(18:15):
New York City’s law is also very different. It’s actually quite a bit different in that it’s really, it’s not an issue necessarily for the company. There’s actually no legal liability for the company or the donor under this law. It really functions as lower limits for the candidates on accepting contributions.

(18:33):
So, the way that this works in practice is if you’re doing business in New York City, you are supposed to report or disclose your covered donors: CEO, COO, CFO, people in functional equivalent roles, some employees who have senior managerial responsibility and discretion over soliciting and administering New York City contracts, 10% owners. You report all of them to New York City, and they go into a doing business database.

(18:59):
And then, the candidates are supposed to essentially self-police to make sure that they’re not accepting contributions over the limit set by this “pay-to-play rule,” right? And those limits are relatively low, $400 for citywide candidates, $320 for borough presidents, $250 for city council. Keep in mind, again, this is an area where, and Tyler referred to this when he was talking about the New Jersey SIC rule, you have to be cautious when you’re thinking about the federal pay-to-play rules, not just automatically or reflexively overlaying the de minimis under those rules and forgetting about this.

(19:33):
Again, it’s a meaningfully different regime in that there’s no legal liability for you. Somewhat similarly, in Virginia, the rule doesn’t trigger an automatic ban on contracts the way New Jersey does. So, if you think about this, some clients will say, “Well, gee, that’s great. There’s no actual ban. Is there some way I can dial down my concern over this or take a different approach to these jurisdictions?”

(19:58):
The answer to that is no, in my view, because as I mentioned at the outset, even in the absence of a black letter provision that says, “Well, if you make this contribution, you cannot enter into contracts,” that’s always a possible consequence of violating these rules. You always may be asked to certify that you haven’t made a bad contribution.

(20:18):
Competitors may raise this if you’re in violation of these pay-to-play rules. And ultimately, you’ve got to remember, it’s within these agencies’ discretion whether or not they do business with you. And if you want to make a public official or procurement officer squeamish, a really good way to do that is to violate something that’s called a pay-to-play rule, because now they feel like they’re implicated.

(20:38):
And so again, even if the legal provision isn’t there saying you’re automatically out of business, loss of business is a real potential consequence that you need to think about when dealing with these laws, which is sort of a segue to the so what section of the podcast.

Tyler Rosen (20:54):
So what?

Charles Ricciardelli (20:54):
Maybe we’ll make that a recurring part of the podcast, where we drone on for 15 to 20 minutes...

Tyler Rosen (20:56):
Yeah, I like that. So what?

Charles Ricciardelli (20:57):
... about the intricacies of the law. We got to keep people to the end, which I hear is important. So, what are we supposed to do about that? And again, many, if not most of you, who’ve clicked into this podcast, and thank you, probably know this, and probably have good policies and procedures in place to deal with this. But just to say it, and again, to level set, the only way to deal with these issues is through some sort of a pre-clearance policy.

(21:18):
You need to have a requirement where some combination, some subset of your employees, maybe all your employees has to raise their hand and come and get legal or compliance to approve before they, and spoiler alert, some family members make or solicit political contributions, at least in some jurisdictions because once they’ve made the contribution and the strict liability trigger is pulled, there’s often nothing you can do about it.

(21:45):
Some of these jurisdictions there are limited cure provisions, but as a general matter, you can’t get that contribution back. You can’t cure it. So there needs to be some policy in place. You need to spend a good amount of time thinking about who we are going to subject to this pre-clearance policy, and that’s often the hardest piece of the exercise, frankly.

(22:05):
Do we want to go broad and make sure we’re bringing everybody into the funnel? Is that going to be too burdensome? Do we want to tailor this to the folks who we really think are likely to be covered? So, you need to give some thought to that. In addition, give some thought to, are we going to require them to pre-clear everywhere, or is our footprint so well-defined in terms of where we may do business that we can only pre-clear in these jurisdictions.

Tyler Rosen (22:25):
I’ve seen clients start to go down that road, and if the rules were all like Virginia or all like New York City, I think that would be a viable approach that you say, “Are we doing business here?” And then, if the answer is yes, then at that point, you pre-clear contributions.

(22:38):
The problem is like the New Jersey’s of the world, and we picked these states because they have elections right now, but they’re also indicative of the types of rules that you see out there. Houston has a rule of law like Virginia. There’s lots of places that have a prospective ban like New Jersey does. The challenge with trying to limit the footprint, it’s like the apocryphal, probably apocryphal, Yogi Berra quote, “Predictions are hard, especially about the future.” You may not be doing business in New Jersey right now, but if three years later an opportunity comes down the road, then the contributions that you were letting go through become a big problem.

Charles Ricciardelli (23:12):
Yeah. Not to mention, this is something I was thinking about when you were talking about the New Jersey reporting rule, which is if you make covered contributions now, you have to disclose detailed information about your contracts.

(23:23):
The little secret that a lot of companies have, especially really in particular, larger or more complex companies, is they may not always know where their contracts are. And just going through that exercise, I mean, it is knowable they can do it, but there’s a serious administrative burden to figuring out where you have these contracts.

(23:42):
And so, on the other side of that, if you’re trying to get comfortable that you’re going to allow a contribution in a jurisdiction because you don’t think you do business there or you’re not even going to pre-clear in that jurisdiction, it’s really hard to get to a place where you’re really confident that every different component of your company doesn’t have a contract, isn’t in the middle of, they could be about to sign the RFP that afternoon, and how do you get comfortable with that? So, an ounce of prevention, worth a pound of cure type of deal.

Tyler Rosen (24:12):
It doesn’t feel like an ounce of protection that when you’re explaining to executives or to their spouses, “Hey, guess what? If you want to make a political contribution, you’ve got to run it through compliance or legal.”

Charles Ricciardelli (24:22):
That’s true. One of the many times, it’s nice to be outside counsel where you just said, “Well, here, this is the advice. Good luck.” Although, that tends to backfire when you get pulled in to be the bad guy to explain it to the CEO and maybe her spouse.

(24:36):
So, I think we’ve covered off-year elections in the pay-to-play rules in the jurisdictions where I’ve lived. Thanks everybody for joining this inaugural Lobby Bar podcast. We appreciate you tuning in, if that’s the, I don’t even know, is that the right phrase for a podcast? In any event, hopefully you will subscribe, continue to listen. We’re aiming to do this periodically, hopefully at least every month. So, tell your friends, tell your family, and we appreciate you joining us.

Tyler Rosen (25:02):
And if there’s things you’d like to see us address or if you have ideas, the so what or anything else that you’d like us to cover, no promises, but we’re certainly interested in feedback and ideas that people have.

Charles Ricciardelli (25:12):
Absolutely. And come for the political law and stay for these outdated, almost middle-aged popular culture references.

Tyler Rosen (25:21):
We hit SNL and “Hamilton,” it was very New York, New Jersey-centric today. Sorry about that.

Charles Ricciardelli (25:26):
All right, well, thank you.

Tyler Rosen (25:27):
Goodbye.

Voiceover (25:29):
Thank you for joining us for today’s episode of The Lobby Bar, a political law podcast. If you like what you’re hearing, be sure to subscribe in your favorite podcast app so you don’t miss any future conversations. Additional information about Skadden can be found at Skadden.com.