Instead of Blueman and John Wodele flinging poo back and forth, we decided to rely on the experts.
Craig Holman, PhD. Public Citizen
The evidence presented here strongly suggests that Tinklenberg has met the threshold of a federal lobbyist:
(1) Receives compensation of $5,000 or more per six months
(2) makes expenditures of $20,000 or more per six months
(3) Spends at least 20% of his time on behalf of any single client conducting lobbying activity.
(4) Made more than one lobbying contact with a "covered official" (member of Congress).
Since there is some evidence that the threshold has been met, it is appropriate to file a complaint with the Secretary of the Senate and the Clerk of the House, requesting that they investigate the matter. You may also want to copy directly to Tinklenberg for faster action. You will probably see him scramble to register and disclose.
Glad you guys are on this.
We just caught ADM (also in Minnesota) not registering, and ADM is now in compliance with the law.
Greg Gasiewski: Lobbying Researcher for the Center for Responsive Politics
The Lobbying Disclosure Act of 1995's definition of a lobbyist:
LOBBYIST.—The term ”lobbyist” means any individual who is employed or retained by a client for financial or other compensation for services that include more than one lobbying contact, other than an individual whose lobbying activities constitute less than 20 percent of the time engaged in the services provided by such individual to that client over a 3-month period.
Certainly sounds like it to me.