In Buckley v. Valeo, 424 U.S. 1 (1976), the Supreme Court explained that campaign expenditures operate in an area of the most fundamental First Amendment activities. See id. Discussion of public issues and debate on the qualifications of candidates are integral to the operation of the system of government established by our Constitution. Thus, a limitation on this core First Amendment speech will be constitutional only if the limitation passes exacting scrutiny as articulated in Buckley. In other words, the limitation must bear a sufficient relationship to a substantial state interest. See Buckley, 424 U.S. at 80. Buckley recognized three substantial governmental interests in requiring disclosure of campaign expenditures. See id. at 66-67, 76, 81. The United States Supreme Court explained that expenditure limitations "operate in an area of the most fundamental First Amendment activities. Discussion of public issues and debate on the qualifications of candidates are integral to the operation of the system of government established by our Constitution." Buckley, 424 U.S. at 14. In Buckley, the United States Supreme Court narrowed the definition of "expenditures" that the federal election laws required to be reported. The federal statute defined "expenditure" as the use of money or other valuable assets "for the purpose of . . . influencing" the nomination or election of candidates for federal office. Id. at 77. The Court worried that the phrase had the potential to encompass the general discussion of issues in addition to advocacy of a particular political result. Id. at 79. If a communication only discusses issues, and is funded by individuals or groups that are "not candidates or political committees," the Court was concerned that the "relation of the information sought to the purposes of the Act may be too remote." Id. at 80. To insure that the federal reporting requirements' scope was not unconstitutionally broad or vague, the Supreme Court construed an expenditure by an individual "for the purpose of influencing" a candidate nomination or election to include "only funds used for communications that expressly advocate the election or defeat of a clearly identified candidate." Id. Responding to similar concerns, Buckley also construed another provision that used the words "relative to" a candidate to mean "in express terms advocate the election or defeat of" a candidate. Id. at 44. The United States Supreme Court reviewed the constitutionality of the Federal Election Campaign Act, declaring in pertinent part the constitutionality of the compulsory disclosure requirements regarding campaign contributions and expenditures. T he court's conclusion rested upon the determination that the infringement upon the First Amendment freedoms of expression and association due to compulsory disclosure was outweighed by three specific compelling governmental interests furthered by the disclosure requirements. These interests included: (1) providing the electorate with information to aid them in evaluating candidates, (2) deterring "actual corruption and avoiding the appearance of corruption by exposing large contributions and expenditures to the light of publicity," and (3) "gathering the data necessary to detect violations of the contribution limitations" of the act. ( Id., at pp. 67-68 46 L.Ed.2d at p. 715.) The Court decided numerous challenges to the constitutionality of the Federal Election Campaign Act of 1971 (FECA) and, in particular, 1974 amendments to FECA. Major provisions of FECA prohibited individuals from contributing more than $ 25,000 in a single year or more than $ 1,000 to any single candidate for an election campaign, and generally prohibited expenditures by individuals and groups in excess of $ 1,000 a year "'relative to a clearly identified candidate.'" Buckley, 424 U.S. at 13. Other provisions limited a candidate's use of family and personal resources, as well as a candidate's overall expenditures in campaigns. Id. The Court began its analysis by reaffirming First Amendment principles. It then observed that limitations on the amount of money individuals and groups are permitted to spend on political speech during an election campaign necessarily reduce the quantity of expression by restricting the number of issues discussed, the depth of their exploration, and the size of the audience reached. This is because virtually every means of communicating ideas in today's mass society requires the expenditure of money. The distribution of the humblest handbill or leaflet entails printing, paper, and circulation costs. Speeches and rallies generally necessitate hiring a hall and publicizing the event. The electorate's increasing dependence on television, radio, and other mass media for news and information has made these expensive modes of communication indispensable instruments of effective political speech. Buckley, 424 U.S. at 19. The Court in Buckley drew a distinction between contributions and expenditures, based upon a "fundamental constitutional difference between money spent to advertise one's views independently of the candidate's campaign and money contributed to the candidate to be spent on his or her campaign." Federal Election Comm'n v. National Conservative Political Action Comm., 470 U.S. 480, 497, 105 S. Ct. 1459, 84 L. Ed. 2d 455 (1985). First, the Court addressed the contribution/expenditure distinction in light of freedom of political speech. Viewing the expenditure limitations as substantial rather than merely theoretical restraints on the quantity and diversity of political speech, the Court noted that limitations on expenditures by individuals, groups, campaign organizations and political parties operate to hinder campaigning. Buckley, 424 U.S. at 19-21. The Court stated that "it is clear that a primary effect of the expenditure limitations in FECA is to restrict the quantity of campaign speech by individuals, groups, and candidates. The restrictions, while neutral as to the ideas expressed, limit political expression 'at the core of our electoral process and of the First Amendment freedoms.'" Id. at 39.