The average Rhode Islander would probably say 38 Studios has been lobbying Rhode Island political leaders, in light of multiple confirmed meetings and the company’s success in getting a $75 million taxpayer-guaranteed loan.

Secretary of State A. Ralph Mollis, however, takes a different view. His office says the company is under no legal obligation to register as an organization with business before the government.

“State law defines lobbying as influencing action on legislation by the General Assembly or the governor or on policy-making by the executive branch,” Mollis spokesman Chris Barnett told WPRI.com. “We have received no evidence or allegations of any such activities by 38 Studios that would trigger the requirement to register.”

38 Studios apparently agrees. The company has never registered anyone to lobby at the Rhode Island State House, even though Carcieri and Chafee administration officials, as well as House Speaker Gordon Fox, have all acknowledged meeting with Curt Schilling and other company representatives to discuss its plans.

In 2010, R.I. Economic Development Corporation Executive Director Keith Stokes told WPRI.com Schilling’s company convinced lawmakers to expand the proposed Job Creation Guaranty Program, saying: “Because of 38 Studios, it has given us the ability to have not a $50 million program but a $125 million program.”

Michael Corso, the prominent local tax-credit broker who’s advised 38 Studios and met with Fox on the company’s behalf, isn’t a registered lobbyist either, according to the secretary of state’s office.

Common Cause Rhode Island’s John Marion expressed exasperation that Mollis and, apparently, 38 Studios don’t think the company is lobbying. ”It strains credulity to say that Curt Schilling hasn’t been, and isn’t currently, lobbying our government,” Marion told WPRI.com.

Marion suggested Mollis may be legally incorrect. ”My reading of Rhode Island’s lobbying laws suggest [Schilling] should be registered and regularly reporting,” he said. “If by some tortured interpretation of the lobbying law he is not considered to be a lobbyist, then it’s our belief the law needs to be promptly fixed.”

Marion speculated that one possible explanation for why 38 Studios isn’t considered to be technically lobbying is an exemption in the rules and regulations that covers “representation of one’s own, wholly owned business entity,” though it’s unclear whether all of 38 Studios’ activities would be covered by that.

38 Studios has never responded to requests for comment.

• Related: Schilling praises ‘pure motives’ of RI pols to Fox News’ Hannity (March 21)