So I can read the DOJ sentence two ways, I first interpreted it as #1, but it sounds like you took it as #2?

1. "We mean people who at that time qualify as agents under laws like the Foreign Agents Registration Act, we said "acting as" because it indicates a temporary employment status rather than an innate human characteristic."

2. "We are weasel-wording to target all people with similar acts to how agents would act, but who would not qualify under the law we want you to think we'd be drawing authority from."