Justice Rutledge also issued a concurring opinion, in which Justices Black, Douglas and Murphy joined. Rutledge argued that a close reading of the legislative history finds "a veritable fog of contradictions relating to specific possible applications" of Section 304. With no clear legislative guidance, Rutledge argued for a plain reading of the term "expenditure." A dictionary definition of the term shows that it does not matter whether a union publication is supported by general union dues or by advertising and/or subscription; an expenditure is an expenditure, which is prohibited by the Act.