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Perrin Cooke

Perrin Cooke is special counsel in the firm’s Washington, DC office and a member of the White Collar Defense and Investigations, Election and Political Law, and Public Policy Practice Groups, with a focus on assisting clients responding to high-profile congressional investigations.

Drawing on his experience in government, most recently as Deputy General Counsel at the U.S. Department of Health and Human Services, Perrin advises clients on matters presenting significant legal, political, and reputational risks. During the Biden Administration, Perrin served as the lead attorney on oversight matters across two federal agencies. In this capacity, he guided the development of strategic responses to congressional requests and subpoenas touching on a range of topics. Through his work in both government and private practice, Perrin has extensive experience preparing witnesses – including numerous corporate executives, cabinet secretaries, and other senior government officials – appearing in briefings, transcribed interviews, and hearings before congressional oversight committees.

In addition to his investigations practice, Perrin advises clients – including political campaigns, advocacy organizations, trade associations, and corporations – on a wide variety of election and political law compliance matters.

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Late this afternoon, the U.S. Supreme Court granted a stay of the Fourth Circuit’s decision setting aside the FCC Media Bureau’s guidance on entitlement to the lowest unit charge (“LUC”) for certain political ads placed on broadcast TV and radio.  See our prior post about this issue here.  Notably, the 60-day political window for the November midterms begins today, so broadcasters’ obligation to afford qualifying buys the LUC is now in effect.

As a result of today’s decision, the FCC Media Bureau’s guidance is back in effect.  That guidance found that two types of broadcast political ads were entitled to the LUC: ads paid for as “party coordinated expenditures” (meaning ads paid for by a party in coordination with a federal candidate), and ads placed by joint fundraising committees involving a federal candidate.

Continue Reading Supreme Court Action Revives FCC Media Bureau’s Political Ad Guidance

On August 25, 2026, a divided panel of the U.S. Court of Appeals for the Fourth Circuit set aside guidance by the FCC’s Media Bureau stating that two types of political advertising were entitled to the favorable “lowest unit charge” (“LUC”) rate: ads paid for as “party coordinated expenditures,” meaning ads paid for by a party in coordination with a federal candidate, and ads placed by joint fundraising committees involving a federal candidate. This question had become particularly salient after the Supreme Court’s decision in June that struck down limits on party coordinated expenditures, allowing unlimited party spending in coordination with candidates, as we explained here. The Fourth Circuit’s ruling was in response to a challenge to the Media Bureau’s Public Notice by four Democratic candidates for federal office. The ongoing litigation has a direct and immediate impact on broadcasters and political advertisers, but its broader significance may lie in what the Fourth Circuit said about judicial review of bureau-level FCC actions.

Continue Reading Fourth Circuit Sets Aside FCC Media Bureau Guidance on Lowest Unit Charge; FCC Asks the Supreme Court to Step In