Yes, it's very well possible that they have a strong legal case - I haven't looked into the precedent they cited. The problem I'm alluding to the administrativ

Yes, it's very well possible that they have a strong legal case - I haven't looked into the precedent they cited. The problem I'm alluding to the administrative order's definition of a 'sale' - whether that definition stems from statute or precedent, or one they constructed just for this case - which doesn't conform to the common definition of the term, leading to a situation where the public is given a naive impression of the scope of the law that is not in accordance with its real scope. This mis-impression is the Orwellian aspect of it.