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WASHINGTON - Massachusetts Gov. Mitt Romney may not be officially running for president in 2008, but he appears to be laying all the groundwork.

Romney, who led the successful 2002 Winter Olympics in Salt Lake City, has set up political action committees (PACs) across America in states where early presidential primaries are historically held.

"The acronym is PAC, which might as well stand for presidential aspiration committee," says Massie Ritsch, a spokesman for the Washington-based Center for Responsive Politics. "Why else would a governor of Massachusetts feel a need to be active in politics in Iowa, New Hampshire and South Carolina?"

Traditionally, at least since President Reagan, potential candidates who want to draw support have set up campaign headquarters or operations in states that cast the first votes in presidential primaries, says Jan Baran, a Washington lawyer who was general counsel to President George H.W. Bush's 1988 presidential race.

Having a PAC in those states allows a candidate to throw money at local candidates, pay consultants or buy a few dinners for the well-connected.

In addition to his federal PAC, Romney set up committees in Iowa, New Hampshire, South Carolina and Michigan - all states that hold early primary contests in 2008. He also has a PAC in Arizona, which is battling to be one of the first states holding primaries.

Romney doesn't have a PAC in Utah.

Candidates use these PACs to "test the political waters" and engage in preliminary organizations, Baran says.

"The early primary states are the so-called retail states, they are the jurisdictions where caucusgoers pride themselves in knowing all the candidates," Baran says. "Individuals who are going to run for president are going to have to spend time in those states."

Other candidates are setting up their own network of PACs as well. Former Virginia Democratic Gov. Mark Warner, for example, has a PAC, Forward Together, in New Hampshire. Potential hopefuls who are still in federal office - say, Sens. Hillary Clinton and John McCain - cannot set up state PACs because of federal laws.

Romney's PAC spokeswoman Julie Teer says the PACs were set up by friends who "were excited about the success in Massachusetts," and the goal is help elect Republicans "up and down the ticket around the country."

The states were chosen, she says, with consultation of national, state and county party leaders to target "important races."

Romney has not said unequivocally that he's in the race. But he has announced he won't seek a second term as governor. And he said on Fox News recently that "there are probably 10 Republicans who are looking at the race and will keep their options open. I'm one of those."

Romney - whose father, former Michigan Gov. George Romney, ran unsuccessfully for president in 1968 - has been traveling extensively to the early primary states to meet and greet the conservative power structures. And he's also made several swings through Utah and the West to raise cash.

Romney's cash on hand

* Arizona: $2,225

* Michigan: $88,234

* South Carolina: $60,188

* Iowa: $94,851

* New Hampshire: No report


* Federal PAC: $215,521

Source: Most recent campaign disclosures