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What is the nature of philanthropic policy advocacy in global health? A rise in private philanthropic engagement during the COVID-19 pandemic, facilitated by isolationist behavior from powerful states, offers an opportunity to address this question. Between January and November of 2020, private donors gave $15 billion to the response in the form of more than 5,400 grants from more than 860 funders toward the COVID-19 response. By comparison, over the 18 years prior, this group contributed just $5.2 billion in response to other global health emergencies. Philanthropic power in global health governance transcends monetary donations—including voting power through public-private partnerships, ideational power, and power through repeated interaction within epistemic networks. Yet prior to the 2014 Ebola outbreak, private donors rarely gave directly toward global health crises—and despite constituting twenty percent of development assistance for health, philanthropy remains underexplored as an actor in international relations. This paper presents statistical analysis of an original dataset documenting foundation engagement in policy advocacy activities over the first eleven months of the COVID-19 pandemic (January through November 2020), including financial data from Candid, a non-profit whose mission is philanthropic advising. Controlling for social, political, and public health context, I regress an original scale designed to measure foundation policy advocacy on key foundation attributes including size, location, type, and leadership. Findings build on my ongoing study of foundation policy advocacy before, during, and in response to global health crises between 2002 and 2019, deepening understandings of foundations as non-state actors in global governance.