I decided to parse what was given to them. Slightly restructured:<p>> A person shall not open, conduct, or do business as a private postsecondary educational institution (a private entity with a physical presence in this state that offers – advertise, publicize, solicit, or recruit – postsecondary education to the public for an institutional charge) in this state without obtaining an approval to operate under this chapter. The institution must be approved to operate, which means approved to establish, keep, or maintain any facility or location in this state where, or from which, or through which, postsecondary education programs are provided.<p>I think the key part is the determination of their location. Their California headquarters counts as a facility through which programs are provided. The fact that the classes are fully online is unrelated. They would have to argue that their headquarters don't have anything to do with providing postsecondary education programs.