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HomeMy WebLinkAbout2-L, Unified Sportsmen of PennsylvaniaIn Re: Unified Sportsmen of Pennsylvania, : File Docket: 15 -001 L Respondent : X -ref: Order No. 2 -L Date Decided: 4/6/16 Date Mailed: 4/15/16 Before: Nicholas A. Colafella, Chair Mark R. Corrigan, Vice Chair Roger Nick Kathryn Streeter Lewis Maria Feeley Melanie DePalma This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding possible violation(s) of Pennsylvania's lobbying disclosure law ( "Lobbying Disclosure Law "), 65 Pa.C.S. § 13A01 et seq., by the above -named Respondent. At the commencement of its investigation, the Investigative Division served upon Respondent written notice of the specific allegations. Upon completion of its investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an "Investigative Complaint." A Stipulation of Findings and a Consent Agreement were subsequently submitted by the parties to the Commission for consideration. The Stipulated Findings are set forth as the Findings in this Order. The Consent Agreement has been approved. I. ALLEGATION: That Unified Sportsmen of Pennsylvania, a lobbyist/principal, violated [Section 13A04 of the Lobbying Disclosure Law, 65 Pa.C.S. § 13A04], when it engaged in lobbying activities before the Pennsylvania General Assembly and /or the Pennsylvania Game Commission, and subsequently failed to register with the Pennsylvania Department of State as a lobbyist and /or principal within ten (10) days of acting in any capacity as a lobbyist and /or principal, and was otherwise not exempt from registration. II. FINDINGS: Unified Sportsmen of Pennsylvania ( "USP ") was first established in or about 1984. 2. A Fictitious Name Registration was filed with the Corporation Bureau of the Pennsylvania Department of State by USP on or about January 6, 1984. a. The registered address for USP was originally identified as 715 Chester Pike, Prospect Park, Pennsylvania 19076. b. The identified nature of USP's business was to promote and advance hunting, fishing, shooting and recreation sports and activities. 3. Articles of Incorporation were filed with the Corporation Bureau of the Pennsylvania Department of State by USP on or around May 23, 1985. Unified Sportsmen of Pennsylvania, 15 -001 L Page 2 CI 5 C.1 rA 14 a. USP was established as a non - profit corporation. b. USP's address continued to be listed as 717 Chester Pike, Prospect Park, Pennsylvania 19076. C. The business purpose of USP was identified as promoting the conservation and preservation of land and natural resources through education and activities by sportsmen. As a non - profit corporation, USP annually filed Internal Revenue Service Form 990. a. Form 990 is an annual reporting return that certain federally tax - exempt organizations must file with the IRS. It provides information on the filing organization's mission, programs, and finances. b. The 990 Forms filed by USP were annually prepared by the Certified Public Accounting ( "CPA ") Firm, Emert & Associates PC. USP's address, as identified on annually filed Form 990, was listed as follows: PO Box 103 Bainbridge, PA 17502 a. The listed principal officer is /was Stephen Mohr. Consistentwith the filed Articles of Incorporation, USP's identified mission, ormost significant activity, as identified on the Form 990 is /was as follows: To provide education and awareness regarding hunting, trapping and fishing, along with other current issues, affecting sportsmen in Pennsylvania and to promote environmental awareness, wildlife conservation and firearm rights. Membership in USP consists of the following membership types: a Membership e nua ee Individual Membership 20.00 Club Membership 100.00 Business Membership 50.00 Life Membership 250.00* Hunting Camp Club Membership 25.00 Junior Membership 5.00 *one -time fee Membership is open to any individual who is a citizen of the United States, who is and remains of good repute. An individual mayjoin USP by applying and paying the annual dues established by the Board of Directors. USP's Officers and Directors, as reflected on its most recent Form 990 dated November 6, 2014, were as follows: Name Title Ronald Cramer Director Mike Frazier Director Phil Wagner Director Mike Strickhouser Director Charles Boligiano Director Unified Sportsmen of Pennsylvania, 15 -001 L Page 3 Ralph Saggiomo Jim Wagner Wayne Bush Ron Benjamin Lon Strayer Fred Bratchie Randy Santucci Wayne Haas Pete Kingsley Stephen Mohr Blaine Toy Director Director Director Director Director Director President Vice - President Treasurer Chairman Secretary 9. USP maintains a publicly accessible internet website at .w ..w r..:..ui.n..u.fU e d _ spggaq2g11pg.M. 10. Contained within the website of USP is the following information for those considering joining the organization: USP is a thriving organization looking to expand our membership as we seek to represent what we perceive to be the voice of Pennsylvania's sportsmen. We welcome members as well as influential people from around the state to attend our semi - annual meetings, and offer their input on current issues. We publish a bi- monthly newspaper, Pennsylvania Woods & Waters, which is mailed to members, Legislators and Government agencies to keep the public abreast of sportsmen's issues. We also maintain a lobbyist in Harrisburg to take issues to our legislature when warranted. 11. Within USP's website, notation is made that USP has served the grassroots sportsmen of Pennsylvania by representing tens of thousands of sportsmen for regulatory relief and legislative help. 12. Specifically, USP is leading the opposition to the white - tailed deer Management Plan of the Pennsylvania Game Commission ( "PGC "). a. Managing white - tailed deer falls under the Jurisdiction of the PGC as provided by Pennsylvania's Constitution and Game and Wildlife Code. b. USP generally opposes the PGC deer management program and management goals promulgated by the PGC for the 2009 to 2018 calendar years. 13. In an effort to oppose not only the PGC's white - tailed deer Management Plan but other acts of legislation affecting sportsmen of Pennsylvania, since at least 2013, Members of the Pennsylvania General Assembly and members /employees of the PGC were occasionally contacted and met with representatives of USP regarding pending legislation. a. USP officials who met with members of the General Assembly and PGC included, but were not limited to, Randy Santucci, Wayne Haas, and Stephen Mohr. b. Meetings occurred normally only one (1) or two (2) times a year, and lasted approximately ten (10) to fifteen (15) minutes in duration. C. The meetings were often not prearranged; however, they would usually coincide with the dates on which USP officials would later be providing Unified Sportsmen of Pennsylvania, 15 -001 L Page 4 testimony before Legislative Game and Fisheries Committee meetings /hearings. 14. On November 1, 2006, Act No. 134 -2006, the Pennsylvania Lobbying Disclosure Law, was signed into law. a. Under the Lobbying Disclosure Law, 65 Pa.C.S. § 13A01 et seq., the State Ethics Commission's responsibilities include enforcement, issuing advisories, and participating on the Lobbying Disclosure Regulatory Committee through the Commission Chair or his designee. 1. Responsibility for the administration of the registration and reporting requirements is vested in the Pennsylvania Department of State. b. The substantive provisions of the new Lobbying Disclosure Law took effect January 1, 2007. 15. Under the Lobbying Disclosure Law, 65 Pa. C.S. § 13A03, "lobbying" is defined as follows- a. Lobbying: An effort to influence legislative action or administrative action in this Commonwealth. The term includes: (1) direct or indirect communication; (2) office expenses; and (3) providing any gift, hospitality, transportation or lodging to a State official or employee for the purpose of advancing the interest of the lobbyist or principal. b. Furthermore, the Lobbying Disclosure Law, 65 Pa. C.S. § 13A03, defines "indirect communication" as: An effort, whether written, oral or by any other medium, to encourage others, including the general public, to take action, the purpose or foreseeable effect of which is to directly influence legislative action or administrative action. (1) The term includes letter- writing campaigns, mailings, telephone banks, print and electronic media advertising, billboards, publications and educational campaigns on public issues. (2) The term does not include regularly published periodic newsletters primarily designed for and distributed to members of a bona fide association or charitable or fraternal nonprofit corporation. (3) The term may include personnel expenses and office expenses. C. "Personnel expense" is defined as: An expenditure for salaries or other forms of compensation, benefits, vehicle allowances, bonuses and reimbursable expenses paid to lobbyists, lobbying staff, research and Unified Sportsmen of Pennsylvania, 15 -001 L Page 5 monitoring staff, consultants, publications and public relations staff, technical staff, clerical and administrative support staff and includes individuals who engage in lobbying but are exempt from reporting under section 13A06 (relating to exemption from registration and reporting). For an individual for whom lobbying is incidental to regular employment, the term means a good faith prorated estimate based on the value of the time devoted to lobbying. 65 Pa. C.S. § 13A03. 16. Within Part IX (Statement of Functional Expenses) of the annually filed Form 990, USP consistently affirmed /verified that there were no expenses related to lobbyist or lobbying activities undertaken on behalf of USP. 17. USP representatives met with and attempted to influence Members of the Pennsylvania General Assembly and /or PGC regarding the PGC deer management program and other legislation or activities of the General Assembly which may have affected Pennsylvania sportsmen and /or were of interest to USP membership. a. These contacts constitute lobbying, and as such, USP would be a "principal" as that term is defined under the Lobbying Disclosure Law. 18. Section 13A04 of the Lobbying Disclosure Law requires a lobbyist, lobbying firm or a principal to register with the Department of State within ten days of acting in any capacity as a lobbyist, lobbying firm or principal. 65 Pa.C.S. § 13A04(a). a. Registration is biennial and began January 1, 2007. b. [Section 13A06 of the Lobbying Disclosure Law sets forth exemptions to registration and reporting, which include, inter alia, the following]: The following persons and activities shall be exempt from registration under section 13A04 (relating to registration) and reporting under section 13A05 (relating to reporting): (1) An individual who limits lobbying to preparing testimony and testifying before a committee of the General Assembly or participating in an administrative proceeding of an agency. (2) An individual who is an employee of an entity engaged in the business of publishing or broadcasting while engaged in the gathering and dissemination of news and comment on the news to the general public in the ordinary course of business. (3) An individual who does not receive economic consideration for lobbying. (4) An individual whose economic consideration for lobbying, from all principals represented, does not exceed $2,500 in the aggregate during any reporting period. Unified Sportsmen of Pennsylvania, 15 -001 L Page 6 (5) An individual who engages in lobbying on behalf of the individual's employer if the lobbying represents less than 20 hours during any reporting period. (6) Except as required under section 13A05(d), a principal whose total expenses for lobbying purposes do not exceed $2,500 during any reporting period. 65 Pa.C.S. § 13A06. 19. At no time relevant to the foregoing has USP maintained a filing with the Pennsylvania Department of State as a registered principal, lobbyist, or lobbying firm, as those terms are defined by the Lobbying Disclosure Law. 20. On a quarterly basis, USP prepared and issued a quarterly magazine /newsletter that was titled "Pennsylvania Woods and Waters." a. All dues - paying members of USP receive the four (4) quarterly issues of the quarterly newsletter "Pennsylvania Woods and Waters." 21. In addition to USP members, Pennsylvania Woods and Waters is regularly distributed to legislators and other government officials by USP. 22. The mailing and printing costs of Pennsylvania Woods and Waters was administered through Rowe Print Shop, LLC in Carlisle, Pennsylvania. a. [Rowe Print Shop, LLC charged fees for printing the newsletterand postage, which fees were paid by USP]. 23. Some, but not all, of the Pennsylvania Woods and Waters newsletters which were published by USP were also published on the website USP maintained. a. When newsletters /magazines were published by USP on its website, it did not restrict access to members only, and the general public had access to such publications. 24. On no less than five (5) occasions, within the Pennsylvania Woods and Waters newsletters, information was present directing readers to contact their state legislator(s) concerning pending legislation affecting Pennsylvania sportsmen, game, recreational land, forest and waterways. a. The direction for individuals to contact their state legislators is indirect communication as defined by the Lobbying Disclosure Law. 25. Of those publications containing indirect communication, all five (5) were publicly accessible through the web site maintained by USP. 26. The following chart reflects the cost of the Pennsylvania Woods and Waters newsletters from 2010 through 2015, whether the newsletter was accessible to the general public through the USP website, and whether the newsletter /publication contained any indirect communication, as that term is defined by the Lobbying Disclosure Act- Quarter/Year Printing Postage Group Indirect Publica- Total Of Newsletter Cost Mail Fee Commu- Lion Costs nication Available Indirect Unified Sportsmen of Pennsylvania, 15 -001 L Page 7 a. The only Pennsylvania Woods and Waters newsletter that was available on USP's website and exceeded a total cost of $2,500.00 was the Summer 2012 issue. This newsletter (Summer 2012) contained no direct or indirect communication as that term is defined by the Lobbying Disclosure Law pertaining to pending legislation of importance to USP. 27. On June 30, 2015, the President of USP, Randy Santucci, forwarded an email to the Investigative Division of the State Ethics Commission, which stated, in part, the following information in response to a request to identify the name(s) and activities performed by lobbyists on behalf of USP. a. USP retains no professional services from any lobbyist or lobbying firm. Our statewide membership organization works for the betterment of hunting, fishing, trapping and 2nd amendment gun rights within the commonwealth. Our position, (as it speaks for our membership scattered around the state), is often solicited by legislators and media sources relative to current topics from activities mentioned earlier. Occasionally a few of our board members meet with legislators to express certain positions, and at times to support or suggest legislative relief related to problems. This activity is perhaps only a few times a year from one or two members of our board, primarily Wayne Haas our VP. In the last two years, I personally testified on 3 occasions in front of House Game and Fisheries Committees at their invite, regarding deer management and semi -auto rifles for hunting. Additionally I was a recent member of former Governor Tom Corbett's Advisory Council for Hunting Fishing and Conservation that saw me involved in discussing legislation in that body. b. Financially USP does not fund any lobbying activity. The only financial reimbursement that is done is occasionally we reimburse board members Online Communi- cation Spring of 2015 $1,368.45 754.91 8.40 N/A No N/A Winter of 2015 $1,336.00 642.26 19.79 No Yes N/A Fall of 2014 1,230.00 750.41 12.00 No Yes N/A Summer of 2014 1,386.00 639.05 112.04 No Yes N/A Spring of 2014 $1,693.00 643.80 63.00 Yes Yes $2,399.80 Winter of 2014 1,658.00 $596.31 $14.55 Yes Yes $2,268.86 Fall of 2013 $1,724.00 $599.218 65.28 Yes Yes 2,388.76 Summer of 2013 1,338.00 616.06 10.50 Yes Yes $1,964.56 Winter of 2013 $1,696.00 642.87 61.10 Yes Yes $2,399.97 Fall of 2012 $1,553.00 573.01 47.50 No Yes N/A Summer of 2012 $1,900.00 $578.66 68.10 No Yes N/A Spring of 2012 $1,436.00 693.55 $14.44 N/A No N/A Winter of 2012 $17704.00 $687.05 14.00 N/A No N/A Fall of 2011 1,826.00 654.27 19.48 N/A No N/A Summer of 2011 1,302.00 657.35 8.71 N/A No N/A Spring of 2011 $17338.00 717.01 12.45 N/A No N/A Winter of 2011 17461.00 $706.71 $153.18 N/A No N/A Fall of 2010 $17517.00 $892.1-7 $134.91 N/A No N/A Summer of 2010 1,875.00 0 83.04 N/A No N/A Spring of 2010 $27320.00 730.77 47.74 N/A No N/A Fall of 2009 & Winter of 2010 $27950.00 0 0 N/A No N/A a. The only Pennsylvania Woods and Waters newsletter that was available on USP's website and exceeded a total cost of $2,500.00 was the Summer 2012 issue. This newsletter (Summer 2012) contained no direct or indirect communication as that term is defined by the Lobbying Disclosure Law pertaining to pending legislation of importance to USP. 27. On June 30, 2015, the President of USP, Randy Santucci, forwarded an email to the Investigative Division of the State Ethics Commission, which stated, in part, the following information in response to a request to identify the name(s) and activities performed by lobbyists on behalf of USP. a. USP retains no professional services from any lobbyist or lobbying firm. Our statewide membership organization works for the betterment of hunting, fishing, trapping and 2nd amendment gun rights within the commonwealth. Our position, (as it speaks for our membership scattered around the state), is often solicited by legislators and media sources relative to current topics from activities mentioned earlier. Occasionally a few of our board members meet with legislators to express certain positions, and at times to support or suggest legislative relief related to problems. This activity is perhaps only a few times a year from one or two members of our board, primarily Wayne Haas our VP. In the last two years, I personally testified on 3 occasions in front of House Game and Fisheries Committees at their invite, regarding deer management and semi -auto rifles for hunting. Additionally I was a recent member of former Governor Tom Corbett's Advisory Council for Hunting Fishing and Conservation that saw me involved in discussing legislation in that body. b. Financially USP does not fund any lobbying activity. The only financial reimbursement that is done is occasionally we reimburse board members Unified Sportsmen of Pennsylvania, 15 -001 L Page 8 traveling to work our booths, or if they have repeated trips to Harrisburg which is rarely. We have had conflicts with the Pennsylvania Game Commission and their deer management program which has fostered some of these trips to meet with legislators to discuss pieces of legislation which were pertinent. 28. USP had no reporting requirements under the Lobbying Disclosure Law as to providing travel, hospitality, lodging and /or gifts for any registration period. a. At no time did any Member of the General Assembly request or accept any travel, hospitality, lodging, or gift from officials and /or representatives of USP. Officials and /or representatives of USP did not offerto any Memberof the General Assembly any travel, hospitality, lodging, or gift. b. At no time did any Member of the PGC request or accept any travel, hospitality, lodging, or gift from officials and /or representatives of USP. Officials and /or representatives of USP did not offerto any Memberof the PGC any travel, hospitality, lodging, or gift. 29. USP had no reporting requirements as to office expenses for any aspects of the Lobbying Disclosure Law. a. USP representatives are not compensated, nor do they receive any travel, meal or mileage reimbursement. b. All representatives of USP are volunteers. 30. Contrary to its website, USP did not maintain /employ a paid lobbyist, and therefore did not have a requirement to register /report same. 31. Pennsylvania Woods and Waters was a regularly published periodic newsletter primarily designed for and distributed to members of USP, and as such was [excluded] from the definition of indirect communication. a. To the extent that indirect communication was published to individuals outside the membership of USP, [there is insufficient evidence] to establish that the costs of distribution to these individuals exceeded reporting thresholds, and /or that total costs /time to produce same exceeded reporting thresholds, such that USP [would have been] required to register and /or report its lobbying activities pursuant to the Pennsylvania Lobbying Disclosure Law. 32. USP did not register under the Pennsylvania Lobbying Disclosure Law in relation to its efforts to advance indirect communication, in that: a. Pennsylvania Woods and Waters was a regularly published periodic newsletter primarily designed for and distributed to members of a bona fide association or charitable or fraternal nonprofit corporation, and as such is not considered indirect communication per the definition of that term within the Lobbying Disclosure Law. USP incurred no personnel expenses and office expenses regarding the publication of the Pennsylvania Woods and Waters newsletter. Unified Sportsmen of Pennsylvania, 15 -001 L Page 9 b. To the extent that indirect communication was undertaken outside of the publication of the Pennsylvania Woods and Waters newsletter, namely publication of the indirect communication as contained within the Pennsylvania Woods and Waters newsletter on USP's website, same did not exceed any reporting thresholds. 33. USP did not register as a principal, lobbyist and /or lobbying firm under the Pennsylvania Lobbying Disclosure Law. a. USP representatives' actions were in relation to testimony and /or testifying before a committee of the General Assembly or participating in an administrative proceeding of an agency. b. USP representatives engaged in lobbying activities did not receive economic consideration for lobbying. C. USP representatives engaged in lobbying activities did not exceed $2,500 in the aggregate during any reporting period. d. USP representatives engaged in lobbying activities engaged in less than 20 hours of lobbying activity during any reporting period. e. Total expenses for lobbying purposes, including direct and indirect communication undertaken by USP did not exceed $2,500.00 during any reporting period. III. DISCUSSION: The allegation is that Unified Sportsmen of Pennsylvania ( "USP "), a lobbyist/principal, violated Section 13A04 of Pennsylvania's lobbying disclosure law ( "the Lobbying Disclosure Law "), 65 Pa.C.S. § 13A04, when it engaged in lobbying activities before the Pennsylvania General Assembly and /or the Pennsylvania Game Commission ( "PGC ") and subsequently failed to register with the Pennsylvania Department of State as a lobbyist and /or principal within ten days of acting in any capacity as a lobbyist and /or principal, and was otherwise not exempt from registration. Section 13A04(a) of the Lobbying Disclosure Law, pertaining to registration by lobbyists, lobbying firms and principals, provides as follows: § 13A04. Registration. (a) General rule. -- Unless excluded under section 13A06 (relating to exemption from registration and reporting), a lobbyist, lobbying firm or a principal must register with the department within ten days of acting in any capacity as a lobbyist, lobbying firm or principal. Registration shall be biennial and shall begin January 1, 2007. 65 Pa.C.S. § 13A04 (a). The terms "lobbying" and "principal" are defined in the Lobbying Disclosure Law as fol lows: § 13A03. Definitions. Unified Sportsmen of Pennsylvania, 15 -001 L Page 10 "Lobbying." An effort to influence legislative action or administrative action in this Commonwealth. The term includes: (1) direct or indirect communication; (2) office expenses; and (3) providing any gift, hospitality, transportation or lodging to a State official or employee for the purpose of advancing the interest of the lobbyist or principal. "Principal." An individual, association, corporation, partnership, business trust or other entity: (1) on whose behalf a lobbying firm or lobbyist engages in lobbying; or (2) that engages in lobbying on the principal's own behalf 65 Pa.C.S. § 13A03. As noted above, the parties have submitted a Consent Agreement and Stipulation of Findings. The parties' Stipulated Findings are set forth above as the Findings of this Commission. We shall now summarize the relevant facts as contained therein. Respondent USP is a non - profit corporation with a stated business purpose of promoting the conservation and preservation of land and natural resources through education and activities by sportsmen. Membership in USP is open to any individual who is a citizen of the United States and who is and remains of good repute. An individual may join USP by applying and paying the annual dues established by the Board of Directors. During the time period relevant to this matter, USP engaged in lobbying as a principal but did not register with the Pennsylvania Department of State. Based upon the Stipulated Findings and Consent Agreement, USP was not required to register because its total expenses for lobbying purposes did not exceed $2,500.00 during any reporting period (Fact Finding 31 e), and therefore, pursuant to Section 13A06(6) of the Lobbying Disclosure Law, 65 Pa.C.S. § 13A06(6), USP was exempt from registration and reporting. The parties' Consent Agreement sets forth a proposed resolution of the allegations as follows: 3. The Investigative Division will recommend the following in relation to the above allegations: a. That no violation of Section 13A04 of the Lobbying Disclosure Law (65 Pa.C.S. § 13A04) occurred in relation to Unified Sportsmen of Pennsylvania engaged in lobbying activities before the Pennsylvania General Assembly and /or the Pennsylvania Game Commission, in that Unified Sportsmen of Pennsylvania did not exceed reporting thresholds and /or was otherwise exempt from the registration and reporting requirements of the Pennsylvania Lobbying Disclosure Law (65 Pa.C.S. § 13A01 et seq. ) Unified Sportsmen of Pennsylvania, 15 -001 L Page 11 The Investigative Division will recommend that the State Ethics Commission take no further action in this matter; and make no specific recommendations to any law enforcement or other authority to take action in this matter. Such, however, does not prohibit the Commission from initiating appropriate action, including issuance of civil penalty and /or initiation of investigatory proceedings, in the event Respondent is alleged to have and /or actually found in violation of the Pennsylvania Lobbying Disclosure Law (65 Pa.C.S. § 13A01 et seq.), otherwise not the subject of the instant proceeding. Consent Agreement, at 1 -2 We determine that the Consent Agreement submitted by the parties sets forth a proper disposition for this case, based upon our review of the Stipulated Findings as reflected in the above analysis. We hold that no violation of Section 13A04 of the Lobbying Disclosure Law, 65 Pa.C.S. § 13A04, occurred when Unified Sportsmen of Pennsylvania engaged in lobbying activities before the Pennsylvania General Assembly and /or the Pennsylvania Game Commission as a principal but did not register with the Pennsylvania Department of State where, during the time period under review, Unified Sportsmen of Pennsylvania was exempt from the registration and reporting requirements of the Lobbying Disclosure Law. IV. CONCLUSIONS OF LAW: No violation of Section 13A04 of the Lobbying Disclosure Law, 65 Pa.C.S. § 13A04, occurred when Unified Sportsmen of Pennsylvania engaged in lobbying activities before the Pennsylvania General Assembly and /or the Pennsylvania Game Commission as a principal but did not registerwith the Pennsylvania Department of State where, during the time period under review, Unified Sportsmen of Pennsylvania was exempt from the registration and reporting requirements of the Lobbying Disclosure Law. In Re: Unified Sportsmen of Pennsylvania, File Docket: 15 -001 L Respondent Date Decided: 4/6/16 Date Mailed: 4/15/16 ORDER NO. 2 -L No violation of Section 13A04 of Pennsylvania's lobbying disclosure law ( "the Lobbying Disclosure Law "), 65 Pa.C.S. § 13A04, occurred when Unified Sportsmen of Pennsylvania engaged in lobbying activities before the Pennsylvania General Assembly and /or the Pennsylvania Game Commission as a principal but did not register with the Pennsylvania Department of State where, during the time period under review, Unified Sportsmen of Pennsylvania was exempt from the registration and reporting requirements of the Lobbying Disclosure Law. BY THE COMMISSION, Nicholas A. Colafella, Chair