It wouldn't have to say anything like that. The determination of practicing law without a law license isn't based on what the government body requires, but generally on rules about what is and isn't legal practice.
I assume they've looked at legal ethics decisions before they opened for business. But who knows, start ups sometimes cut legal corners.
Practicing law? This isn't a courthouse. Sure the SFMTA operates with the blessing of the government, but I do not believe "parking court" is in the same realm as the "courthouse" you're thing of.
Practicing law is more than just appearing in a court. I'm not totally sure where the line is, but writing a defense letter is definitely near the line.
They may just have supervising attorney's who double check all the work before it goes out the door. A lot of small firms have teams of paralegals who do paperwork and one attorney who signs off.
In CA it's defined as: 'As the term is generally understood, the practice of the law is the doing or performing services in
a court of justice, in any matter depending therein, throughout its various stages, and in
conformity to the adopted rules of procedure. But in a larger sense it includes legal advice and
counsel, and the preparation of legal instruments and contracts by which legal rights are secured
although such matter may or may not be depending in a court.'
I assume they've looked at legal ethics decisions before they opened for business. But who knows, start ups sometimes cut legal corners.