EAO 089

An entity may be required to register as a lobbyist under the expenditure threshold for lobby registration. An expenditure made directly from the funds of an engineering firm, in contrast to reimbursement paid by the firm to an individual registrant, is an expenditure by the firm for purposes of the lobby statute, not an expenditure made by the employee who acted on behalf of the firm. An employee of an engineering firm who is paid to communicate with an official of a regulatory agency to extol the merits of the firm is engaged in lobby activity if the purpose of doing so is to influence the agency official in regard to any matter that may be the subject of agency action. Similarly, expenditures for a hunting trip are not exempted from chapter 305 of the Government Code simply because no business is discussed on the trip.