You mentioned you're familiar with the Federal Accountability Act and the specific provisions contained within it on lobbying. As you know, there are two different types of lobbyists. One is consultant lobbying, where one charges to advise clients. You have stated that you have never charged for advice you've given to others on how to deal with government. The other type, of course, is the in-house lobbyist. One of the determinants of that definition is if an official of a company who is given the responsibility of contacting, communicating, and working with governments spends in excess of 20% of their work day communicating with and dealing with governments. Then they are considered to be a lobbyist who needs to be registered.
Did you at any time in your communications with the federal government, whenever they might have happened, consider yourself to be spending more than 20% of your time, either individually or combined, on discussing with government about information, government programs, etc.?