EAO 043

A person who does not communicate with a member of the legislative or executive branch is not required to register as a lobbyist, even if that person is compensated to perform work for someone else who communicates with members of the legislative or executive branch to influence legislation or administrative action. If a person communicates directly with a member of the legislative or executive branch to influence legislation or administrative action, however, the time that person spends on activities such as conducting research to prepare for the communication is included in calculating whether the registration threshold has been met and in calculating the amount of compensation that must be reported.