You keep quoting most of that sentence while leaving out the key part that comes at the end ""...Tesla was acting as a dealer, Steier said." It does not matter how many times nor in how many articles the opinion of Paul Steier is quoted, it does not change the fact that the law does not actually say that. You appear to be basing your argument on, "They published it in the newspaper. It must be true."
I will try one more time. The article links to the relevant law. You can read that law for yourself. I did. The relevant law says that in order to sell automobiles at retail in Iowa someone must be a licensed dealer. It does not say that in order to "act as a dealer" one must be licensed. It says that in order to sell one must be licensed. So, the wording of the law does not say that someone must be licensed as a dealer in order to conduct test drives anymore than someone must be licensed as a dealer to make repairs on a car. Dealers do that as well, so that you could say "State law requires auto dealers to be licensed, and by offering to repair cars, the local mechanic was acting as a dealer." It still would not mean there was a legal requirement to be licensed as an auto dealer in order to repair cars, no matter how many times someone from the DOT said it. Read the law, it does not say what the DOT spokesman said.