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Wrong.
You can argue that untill the cows come home, but that's not "pay" legally. Unless you are arguing that by going to work for a software development company, they are paying me by giving me access to resources I need to develop code for them? Same thing, Threshold. Those are just requirements to do the job - those are not pay.
Volunteers are required to sign a legal document if they want to donate their time. Doesn't matter if it was implied when they sign up RL - law REQUIRES their signature RL, kiddo. I'll repeat it again. REQUIRES their signature. Otherwise, be prepared to pay minimum wage.
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