I've read the statutes in question and I'm not 100% sure this is an accurate conclusion, but hopefully Pence will step up to the plate regardless
Another anon posted a couple detailed comments on this from a knowledgeable perspective, check the comments under this post. He agrees with your intuition.
I wrote a book that the statutes in question are a major part of and can assure you this letter is 100% false in its conclusions. See my post in this thread.
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