Do I need to apply for Adobe Reader Integration Key License (RIKLA) Program?

I want to develop a commercial plugin for Adobe Reader that invokes some action through new items on right-click context menu.
I need to apply for RIKLA for that?
Reading the FAQ I notice this:
What are the restrictions for Adobe Reader plug-in development?
Modify the appearance of Adobe Reader
I don't know if adding an item to context menu could be considered as "Modify appearance", besides this seems that RIKLA only applies for vary specific types of plugins and closed to very few people... I don't know if I need to worry about this or not because of being a commercial plugin.
Thank you so much

It's not just a licensing requirement. Without the RIKLA you cannot make Reader plug-ins at all. Adobe will vet your proposal and decide if they will permit it, and what license fee you will pay.

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