[wtallis]

> Do you have a source for this interpretation? It sounds like this is your interpretation, but not the federal one. Following your interpretation, surveys of companies (e.g. emailing [e-mail] to ask how many employees they have) would fall under the definition of human subjects.

Sure. Click through the NIH's Decision Tool [1], and you'll find that collecting information only through surveys or interviews leads to the tool saying "Your study is most likely considered exempt from the human subject's regulations, category 2 (Exemption 2)." That particular exemption requires that the research qualify under at least one of three further criteria. (I'll also note that for someone who complained about people not referring to primary sources, you seem to be citing more .edu sources than .gov sources.)

Furthermore, this particular research unquestionably went beyond mere surveys and interviews. Legal threats under false pretenses are way outside those bounds. So even if a mere survey about how many employees a company has doesn't qualify as human research (which I'm willing to concede), that doesn't help settle the question about this research.

[1] https://grants.nih.gov/policy/humansubjects/hs-decision.htm