It depends on the parameters and the situation in which the communication takes place. The Lobbying Act under subsection 5(1) and section 7.1 specifically outlines the parameters that need to be met in these situations.
It depends on the circumstances. We have to assess, for example, whether it's a situation related to one of the parameters set out in the act. If the communication complies, if the lobbyist is paid by a third party, then we can talk about lobbying.