Let me be clear. Hill + Knowlton does both. We are registered lobbyists, and we provide advice and counsel. I think with the way the act is currently defined, the focus on actual communication with the public office holder is fine. If you start going down the path to broaden the definition beyond that, I think you're going to capture so many people it'll be meaningless.
On February 16th, 2012. See this statement in context.