People are very imaginative.
I think the one thing the commissioner mentioned was that any staff in a minister's office or any member of Parliament's office is a public office holder under the Lobbying Act. A communication with them would be a registerable activity.
It's only the exempt staff, who are appointed under subsection 128(1) of the PSEA, who, as the act states, are designated public office holders. So in any minister's office or minister of state's office, there will be a number of people who are also designated public office holders.