He understands perfectly well. What's relevant is whether the response is a property of the individual or the organization, and it's arguable, and controversi

He understands perfectly well. What's relevant is whether the response is a property of the individual or the organization, and it's arguable, and controversial, but you'll find a lot of studies performed using this technique that were not considered human subjects research. As to whether it's deceptive and threatening (the latter of which I find pretty hyperbolic, this is a pretty boilerplate request), that has no relevance as to whether it's human subjects research. Maybe they should have limited the scope to larger organizations.