The company also works for the Republican Party, prominent Republican House and Senate candidates, and interest groups active in congressional races, including the American Action Network, Americans for Prosperity and Crossroads GPS, which is affiliated with American Crossroads.
Targeted Victory uses Internet video ads to persuade people to oppose Obama and vote for Romney. It also uses a stockpile of data it has collected on Web users to reach them with ads for both Romney and Crossroads.
Separately, Targeted Victory keeps a record of those who have visited the Romney campaign Web site or the Crossroads site, and stores that information in the same location.
Romney campaign spokeswoman Andrea Saul said the campaign’s vendors “understand the law and follow it.”
Targeted Victory’s chief executive, Michael Beach, said in an e-mailed statement that the company has separate teams of strategists for the two clients, crafting ad messages and finding potential voters online. Those teams work on opposite sides of a “firewall” described in FEC regulations, he said.
“Targeted Victory takes its compliance responsibilities seriously and continually reviews its operations to ensure compliance with the FEC rules,” Beach wrote.
He said the rules allow some employees to work for both Romney and Crossroads, including “personnel who merely forward the Internet ad buys to placement firms.”
FEC regulations specifically point to those working on “the selection or purchasing of advertising slots” as employees with the potential to share inside information that could be used for coordination.
A look at the same custom-built software running on the Romney and Crossroads Web sites shows the tight links between the organizations. When people visit the Romney or Crossroads site, their browsers download software written by Targeted Victory.
The code creates a trigger so that when users press a “donate” button, for example, their browsers report that information, which is kept in a database that commingles Romney and Crossroads users.
When users move on to a site with ads, that starts another chain reaction of code, transmitting the Romney and Crossroads information to ad networks, which may then display Romney or Crossroads ads.
Storing data together and using the same employees to represent Romney and Crossroads is not coordination under the law. To break the rule, an interest group would have to use inside information on the candidate’s needs or wishes to shape its own ad campaign.
Geoff Garin, a Democratic pollster who works for prominent liberal super PACs, said he uses a password-protected computer system to keep sensitive materials from his colleagues who might work directly for candidates or the official party committees. He praised the value of the rules as one of the only defenses keeping the work of candidates and well-funded interest groups separate.
“It seems we have a Swiss-cheese system here,” Garin said. “No offense to Swiss cheese.”
Dan Eggen contributed to this report.