Part 91 compensated, not a lot of block time.

117.23 gives limitations, but says:

"The limitations of this section include all flying by flightcrew members on behalf of any certificate holder or 91K Program Manager during the applicable periods."

I realize that flying for pay is "commercial flying", but part 117 doesn't use that phrase anywhere. So does 117 only limit flying for carriers subject to part 117?

Time to break out the legal interpretations, I'm sure there's something in there that clarifies.