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(Reality Check 753)  Reality Check has already shown how “Neutral” Conservative News Websites Breitbart and The Daily Wire are actually fronts for the Ted Cruz Campaign.  In our article “The $25 Million Dollar Trump Take Down” we clearly show that the owners of those sites donated over $25 Million Dollars to the Cruz Campaign and then use their websites to promote him.  But is Talk Radio also on the take?  Reality Check dug into Cruz FEC Filings and discovered the Cruz PACs paid a Talk Radio Insider over $8 Million Dollars, and the endorsements of Glenn Beck, Mark Levin and others quickly came in.
The FCC regulates the nation’s TV and Radio Stations because the signals they use are owned by the public.  This is why you cannot use certain words on the radio, stations must have licenses, keep a public records file and make it available, etc.
One FCC rule is 47 U.S. Code § 317 or the Payola Rule.  Simply put, Radio/TV Stations and their employees are not allowed to take money to put content in their programming, mention items, talk about candidates, etc. unless that sponsorship is disclosed.
In other words, if a Talk Show host like Glenn Beck, Mark Levin, Hugh Hewitt or others was paid money by a campaign to talk glowingly, defend or endorse a candidate, and not disclose that they were paid on-air to the audience, or the radio stations they are broadcast on, they’d be in violation of the law.  The station could lose it’s license and the host could be jailed and fined.
Politico published an article in December called, “Talk Radio Rallies Around Ted Cruz” highlighting Glenn Beck, Mark Levin and Erick Erickson, amongst others as hosts defending Cruz and bashing Donald Trump (to Cruz’s benefit).   If these hosts are doing it on their own, with no payment, it’s perfectly legal.  However, if money is flowing to them, and they are not disclosing it, they are violating Federal Law.
Cruz won a convincing primary in Wisconsin and as Mark Graul, a Wisconsin based GOP Strategist pointed out:
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The question is, are these talk show hosts becoming Pro-Cruz on their own volition?  Or are they being paid big money to sway the election in Cruz’s favor?
A look at Ted Cruz PAC filings (Keep The Promise I &  Keep The Promise PAC) turns up expenses totaling $8,467,466.00 to a company out of Plano Texas called Rigel Strategies LLC.  Below is a screenshot of just a small sample of the payments Keep The Promise I has paid to Rigel Strategies, LLC.
Rigel Strategies, LLC is owned by a man named Dennis Sternitzky.  Sternitzky is the only employee of Rigel Strategies, LLC from extensive research. Sternitzky is a former sales rep for Salem Communications (now known as Salem Media Group), which owns 117 radio stations across the United States.  Salem also owns the website Red State which puts on the “Red State Gathering” that is hosted by Erick Erickson.  The Red State Gathering notoriously banned Donald Trump from appearing at it’s latest get together in Denver Colorado.
When Sternitzky founded Rigell Strategies, LLC he began pushing a different kind of marketing he calls, “Embedded Marketing”.  Sternitzky quotes Michael Margolis, “If you want to learn about a culture, listen to the stories…if you want to change the culture, change the stories.”  In short, Sternitzky’s marketing plan is to pay hosts to promote brands, campaigns, etc. during their show which is perfectly legal, AS LONG AS IT’S DISCLOSED to the public.
Here is a youtube video of Sternitzky explaining his concept.


According to Sternitzky’s LinkedIn Profile, he was the National Account Manager for Salem Communications (syndicator for Mark Levin, Dennis Prager, Michael Medved, Bill Bennett, Mike Gallagher, Erick Erickson and Hugh Hewitt) from August 2005 to August 2011.  Before that Sternitzky worked for Premeire Radio Networks (syndicator for Glenn Beck, Rush Limbaugh, Sean Hannity, Meghan McCain).

In 2015, Ted Cruz’s PAC “Keep The Promise I” made 58 payments to Rigel Strategies, LLC. for a total of $1,094,268.00.  The PAC increased its spending with Rigel Strategies, LLC. dramatically in 2016 and in just January and February (the latest filings available), has paid Rigel $7,373,198.00.  The expenses are listed as “Media” and “Pac Radio Advertising”.  Below is a screenshot of all of the payments made by Cruz’s “Keep The Promise 1” and “Keep The Promise PAC” to Rigel Strategies, LLC.
It’s also been widely reported that, David Barton, the Director of Cruz’s “Keep The Promise PAC”, is also the Chairman of Glenn Beck’s Mercury One Charity.  Between January 18, 2016 and February 18, 2016, “Keep The Promise PAC” paid Rigel Strategies, LLC. $1,033,300.00.
Since Rigel Strategies, LLC. is not a public corporation, just what that $8,467,466.00 dollars in “Media” spending has been used for is not public record.  However, it’s not hard to connect the dots and see that a one man corporation, with connections to radio hosts and a marketing plan of “embedded marketing” may be using that money to purchase the loyalty of Talk Show Hosts around the nation to sway the election in Cruz’s favor.
Is Cruz’s “Keeping the Promise I” and “Keep The Promise PAC”, through Rigel Strategies, LLC. paying conservative talk show hosts and media pundits for their endorsements, their defense of Cruz and to attack his opponents?  If so, this would be a blatant violation of the FCC’s Payola and Plugola laws as the hosts mentioned have not disclosed on the air the payments made in exchange for their programming.
Further, this would be a violation of the FCC’s Equal Time Rule which was created because the FCC thought Radio and TV stations could easily manipulate the outcome of elections by presenting just one point of view, and excluding other candidates.