Comcast is going to war in its pursuit to merge with Time Warner Cable. The telecom giant has reportedly bought up lobbyists at 40 different firms around Washington.

There’s a simple way you could describe Comcast’s strategy: have an unlimited budget and then exceed it. The Sunlight Foundation’s Bill Allison says the nation’s capital eats it up.

“You know Washington is the kind of girl that always falls for the dozen of flowers sent three or four times a day,” he says.

By the looks of it, Comcast’s got all the florists on speed-dial. According to the Center for Responsive Politics, the company spent nearly $20 million dollars lobbying the federal government last year, putting it in the top 10, and it is on track to be there again this year.

Former FCC chief of staff Blair Levin says this is less about influencing Congress than convincing regulators and Comcast competitors this is a done deal.

“Because if you have the impression this deal is going to go through and everybody is going to rearrange their lives, it’s much harder for a government to act in a way that upsets those expectations,” he says.

Levin says there is something of a firewall. He says regulators at the Department of Justice – key decision-makers in telecom mergers – are historically immune to lobbying campaigns, regardless of size.