In DiQuisto v. County of Santa Clara (2010) 181 Cal.App.4th 236, in collective bargaining negotiations between a county and several public employee unions, the county bargained for union agreement not to support a union-sponsored ballot measure to mandate binding arbitration with the county. Plaintiffs, who were basically allied with the unions, then sued the county for the waste of public resources in "discussing the unions' nonsupport of the proposed ballot initiative." (DiQuisto, supra, 181 Cal.App.4th at p. 264.) Importantly, the court recognized that the county's communications could not claim impartiality--after all, the county really did oppose the ballot measure. (See id. at p. 265.) Even so, the proposals were part of contract negotiations, no election campaign was as yet "underway," and the audience was not the " 'electorate per se, but only potentially interested private citizens' " (indeed, the union negotiators themselves!) and there was " 'no attempt to persuade or influence any vote.' " (Id. at pp. 265-268.) Thus the DiQuisto court readily held that the "activity" (really simply using time in negotiations to recognize county opposition to the ballot measure) was not illegitimate campaign activity. The DiQuisto case also involved an e-mail sent by a county supervisor to about 1,500 individuals, encouraging them to "educate themselves" about the ballot measure and attaching a copy of a newspaper editorial that urged a "no" vote on it, an issue which prompted the court to look at section 8314, mentioned above. Section 8314 precludes use of public resources for "a campaign activity," though it defines campaign activity to not include "the incidental and minimal use of public resources, such as equipment or office space, for campaign purposes." (Id., subds. (a), (b)(2).) The union-allied plaintiffs argued that the e-mail, complete with its attachment directly urging a "no" vote on the union-supported measure, constituted express advocacy in violation of the statute. (DiQuisto, supra, 181 Cal.App.4th at p. 271.) Not so, said the appellate court. The e-mail itself merely suggested voters educate themselves about the initiative, it was " 'moderate in tone' " and not exhortatory, and, even though sent out less than a month before the election, its style and tenor still made it essentially informational. (DiQuisto, supra, 181 Cal.App.4th at p. 272.) As for the editorial attached to the e-mail, well, it obviously did constitute express advocacy. After all, the editorial explicitly said "vote no" on the union-sponsored ballot measure. (See DiQuisto, supra, 181 Cal.App.4th at pp. 273-274.) However, given the "minimal costs" involved and the supervisor's general intent to inform the recipients of the e-mail on the differences between the union-sponsored measure and two competing county-sponsored measures, the attachment fell within section 8314's definitional exemption for minimal and incidental activities: The court noted testimony from the supervisor's chief of staff that there was "voter confusion" and the editorial "contained a good explanation" of the competing ballot measures. (181 Cal.App.4th at p. 274.) And any expenditure was clearly de minimis, using equipment already in place. (Id. at p. 275.)