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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | P.O. Box 11201 |
Address2 |
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| City | Pueblo |
State | CO |
Zip Code | 81001 |
Country | USA |
3. Principal place of business (if different than line 2)
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Zip Code |
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5. Senate ID# 400962773-12
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6. House ID# 421050000
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| TYPE OF REPORT | 8. Year | 2025 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
| 10. Check if this is a Termination Report | Termination Date | 11/30/2025 |
11. No Lobbying Issue Activity |
| INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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| 12. Lobbying | 13. Organizations | ||||||||
| INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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| Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
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Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
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| Signature | Digitally Signed By: David W. Devendorf |
Date | 1/20/2026 11:41:54 AM |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code CON
16. Specific lobbying issues
Continuing educational efforts toward members and staff regarding Tribal Sovereignty and Government-to-Government relationships the United States and Tribal governments.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Ben Nighthorse |
Campbell |
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Former U.S. Senator |
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David |
Devendorf |
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Former Senate Staff |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code GAM
16. Specific lobbying issues
Continuing educational efforts toward members and staff regarding Tribal Gaming. Expressed concern to Senate Agriculture Committee members regarding entities, such as Kalshi and Polymarket, using the Commodity Futures Trading Markets to bet on sporting events and the deleterious effects on the gaming industry. Also, expressing concern that the nomination to the CFTC of Mr. Brian Quintenz, a Kalshi Board member, be delayeduntil he articulates his position on this activity.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Ben Nighthorse |
Campbell |
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Former U.S. Senator |
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David |
Devendorf |
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Former Senate Staff |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code GOV
16. Specific lobbying issues
Continuing educational efforts toward members and staff regarding Tribal Government issues that, while similar to many state and local government issues, are unique due to the lack of taxation authority to address these issues.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Ben Nighthorse |
Campbell |
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Former U.S. Senator |
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David |
Devendorf |
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Former Senate Staff |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code IND
16. Specific lobbying issues
Continuing educational efforts toward members and staff, many of which have had very little contact with American Indian Tribes. We provide historical context regarding Tribes and Tribal Government structure and constraints, then work cooperatively to identify solutions.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Ben Nighthorse |
Campbell |
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Former U.S. Senator |
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David |
Devendorf |
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Former Senate Staff |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code ECN
16. Specific lobbying issues
American Indian and Alaska Native Tribes and Villages have among them, many of the poorest counties in America. Economic Development is of great importance and although Tribal Gaming has been successful in many areas, it does not work for many Tribes. Therefore, we work cooperatively with the federal legislative branch to identify resources that can be brought to bear to advance economic development in Indian Country.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Ben Nighthorse |
Campbell |
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Former U.S. Senator |
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David |
Devendorf |
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Former Senate Staff |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TAX
16. Specific lobbying issues
We work with senate staff to identify any potential legislation that may affect Tribal taxation. Weighed in with Senate Finance Committee, Chairman Crapo and the membership, for inclusion of the Tribal Tax Parity Act into the "One Big Beautiful Bill Act"
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Ben Nighthorse |
Campbell |
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Former U.S. Senator |
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David |
Devendorf |
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Former Senate Staff |
19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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21. Client new principal place of business (if different than line 20)
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
| Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
| 1 | 2 | 3 |
FOREIGN ENTITIES
27. Add the following foreign entities:
| Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
| 1 | 3 | 5 |
| 2 | 4 | 6 |
CONVICTIONS DISCLOSURE
29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery,
extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
| Lobbyist Name | Description of Offense(s) |