Mayor Miller breaking election laws?

Matt from "A step to the right" as a great posting about the possibility that Mayor David Miller, the mayor of Toronto may have broken election financing laws with his "One cent" campaign.

It may be worse then Matt suggests.

A third party may spend up to a total of $150 000 nationally on election advertising. Of this amount, it may spend no more than $3 000 in any single electoral district. For by-elections, the maximum is $3 000 for each electoral district.

Based on my reading of that, the total spending limit for Mayor Miller would have only been 66,000 dollars, not 150,000 dollars. Big difference.

What I don't know, and perhaps when of the readers can let me know, what is the time span that the limit covers? Is it only from the day of the writ drop to the day of voting?

I want to say the entire costs would count, but they don't count for actual advertising for the federal parties so perhaps it doesn't.

Does anyone know?