The same principle applies here. In view of the lobby law's existing sanctions against secretive or fraudulent conduct by lobbyists, defendants have not established that a blanket prohibition against volunteering personal services to campaigns is a necessary corollary to the law's other provisions. For example, Wisconsin's lobby law requires lobbyists to obtain licenses,
Wis.Stat. § 13.63(1); to be registered with the secretary of state,
Wis.Stat. § 13.64; to report their lobby-related activities and expenditures,
Wis.Stat. § 13.68; and to observe specific restrictions on their comportment as lobbyists, including restrictions on monetary contributions to campaigns,
Wis.Stat. § 13.625. Defendants' major concern appears to be that, in the absence of a direct prohibition, lobbyists will use volunteered personal services as a way to circumvent these other provisions. It seems apparent that the lobby law protects against lobbyists' operating in secret through disclosure requirements that insure that the identity of lobbyists is a matter of public record. It also seems apparent that, if the legislature perceived a specific threat from lobbyists engaging in volunteering as a way to circumvent limitations on campaign monetary contributions, the legislature could expand its requirements to include the disclosure of such volunteer activities. It goes without saying that, if lobbyists were volunteering “personal” services to an elective official's campaign in their capacities as paid lobbyists, such disguised volunteering would be a reportable activity under the existing provisions in the lobbying act and that, if lobbyists were paid by a principal or paid others to donate personal services to a campaign, such a donation would be reportable under
Wis.Stat. §§ 13.625(1)(b) and
11.01(6)(a) as an in-kind contribution of a “thing of merchantable value” subject to contribution limitations, which are enforced with civil and criminal penalties.
See Wis.Stat. §§ 11.60 and
11.61.