A Wyoming-based organization is testing Oklahoma law by attempting a cruise sweepstakes for people who contribute at least $50 to one of their preferred political candidates in the state’s 2026 election cycle.
MOGANetwork LLC, an acronym for Make Oklahoma Grassroots Again, filed as a limited liability company with the Wyoming Secretary of State’s office on March 4. The group states a mission of “identifying strong Godly leaders and equipping them to remain steadfast throughout their public service careers.” Its registered organizer is Andrew Pierce, an attorney who advertises private and anonymous business registration in the state for $99 plus filing fees.
The group claims status as a 501(c)(4) social welfare organization, which is allowed to raise and spend unlimited amounts of money and is not required under state or federal law to disclose its donors. These organizations are the primary source of so-called dark money in elections because of the lax reporting requirements.
In early May, MOGANetwork launched the Road to Victory 2026 website, which advertised a chance to win a cruise worth $1,500 for anyone who initiates a donation of at least $50 from their website. About four dozen candidates for a variety of legislative and statewide offices were listed.
The fine print on the website initially stated that no purchase was necessary, but elaborated that a minimum donation of $50 per entry was required to qualify, specifying its view that a donation and purchase are not synonymous.
On May 25, the website was updated to offer a free mail-in alternative for Oklahoma residents 18 and older. The organization’s listed address corresponds with a diner in Sheridan, Wyoming.
Starting around noon on May 27, the website displayed the following message: “This site is temporarily unavailable as we work out compliance issues with Oklahoma statutes. We’ll be back up as soon as we can!”
MOGANetwork LLC could face legal challenges over the sweepstakes, which must meet strict criteria to avoid being classified as an illegal lottery, according to Oklahoma attorney and historian Bob Burke. For instance, a sweepstakes operator must provide a no-purchase-necessary alternative method of entry at the onset of the contest.
Burke said another provision of the fine print, stating that the group can substitute a lesser prize worth $100 or more if the sweepstakes receives fewer than 100 entries, is questionable as well.
Leslie Berger, a spokesperson for the Oklahoma Attorney General’s Office, said the agency had not received any complaints about the website as of Friday afternoon.
Also lingering are questions about compliance with state campaign finance laws, including if the value of the cruise should be classified as an in-kind contribution to the campaigns of the organization’s preferred candidates. While Oklahoma Ethics Commission rules do not outright forbid political groups from conducting raffles, it states that organizers should “independently verify that state criminal law does not prohibit conducting a raffle prior to engaging in such activity.”
MOGANetwork LLC did not respond to Oklahoma Watch’s requests for a live interview, which provides an opportunity to verify a source’s identity and ask follow-up questions.
Marcie Everhart, a Republican candidate for Oklahoma’s 4th Congressional District challenging incumbent Tom Cole, posted on Facebook on May 11 lauding her inclusion on the sweepstakes page. In an interview, she said she was not contacted prior to her inclusion on the website but is vaguely familiar with who is behind the group.
Everhart said she was unaware that MOGANetwork LLC is headquartered in Wyoming, but nonetheless stands behind the group’s mission to support grassroots Republican candidates. She said the cruise giveaway is a positive incentive to increase individual support for candidates and thwart the influence of deep-pocketed political action committees.
“This is a group of patriots who are trying to change the dirty, uncompromised, corrupt way that campaigns run,” Everhart said. “It’s very unfortunate that anyone would try to attack that or pick that apart.”
James Davenport, a political science professor at Rose State College, said he does not recall a prior instance of an Oklahoma-focused group offering a sweepstakes entry in exchange for campaign donations. He said billionaire Elon Musk’s $1 million giveaway for voters in a 2025 Wisconsin Supreme Court election, which is being challenged in federal court, could have inspired the prize-based incentive effort.
Davenport said MOGANetwork LLC could have a worthy cause and motivation behind launching the sweepstakes, including encouraging voter participation in Oklahoma’s notoriously low turnout primary election cycle. But he said the Wyoming headquarters location and lack of public information on the individuals behind the organization raises questions.
“The way their organization is operating right now, it’s just going to encourage suspicion and distrust,” Davenport said. “We have enough of that in our politics right now. We don’t need these organizations creating more of that.”
Oklahoma’s primary election is set for June 16, followed by an August 25 runoff for races where no candidate receives a majority of votes.
If allowed to proceed in its sweepstakes, MOGANetwork LLC intends to draw a winner shortly after the Nov. 3 general election.
Oklahoma Watch, at oklahomawatch.org, is a nonprofit, nonpartisan news organization that covers public-policy issues facing the state.
