Earlier quoted context omitted.
the 3 points are an OR, not an AND. you misinterpreted it. altho the legislation as proposed is not final, it was clearly drafted and stated with each of the 3 potential rqmts being sufficient on their own, not together.
It costs less than $100k per year to keep 5 "full-time" workers on staff. Just pay them minimum wage. This seems well-thought-out to you?
i think you lose your side of the argument by arguing for any arbitrary amount. i'm happy to argue the merits of what the correct # is, but regardless i think we're just splitting hairs at that point... i've won the discussion.
besides, it's a rather ridiculous amount of hassle in both time & money to raise capital from experienced investors in exchange for hatching some supposedly nefarious scheme to -- wait for it -- hire some low-wage workers.
really, while i fully admit there may be gaming of the system attempted, this supposed workaround is quite a stretch -- it requires the participation of sophisticated investors willing to risk substantial amounts of capital, reputation, effort, and criminal penalty in order to execute.
this doesn't appear to be a rational point worth arguing, you're just being contrarian for the hell of it.