Lobbying solely via indirect communications


Would a lobbyist who only engages in indirect communications broadly directed at policy issues and not targeted towards any particular member of Council fall within the scope of "any person who is seeking official action from that officer or employee" such that the gift restrictions of Code 20-604(1) would apply?  

Yes, if such lobbyists are currently making indirect communications related to legislative action. Their principals would also have to disclose such gifts on the relevant lobbying expense reports.

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