This is going to seem outrageous at first, but it is just another way to structure the cost of marketing. He is essentially spending money to acquire email add

This is going to seem outrageous at first, but it is just another way to structure the cost of marketing. He is essentially spending money to acquire email addresses, which is something campaigns normally do. And he is buying his way into national exposure, which again is something campaigns normally do. The rules for participation in privately sponsored debate are completely made up and have no actual legal implications related to election law. They are essentially indexing on the size of an email list in this case. Who cares whether a campaign bought gift cards or Facebook ads to get the emails.