This generalization has the virtue of allowing mental activity to evolve with biological complexity from the very beginning of life. Next, in the discussion of how living systems can be distinguished from inanimate ones. As an alternative, I suggest that the distinction should be between mechanical and meta-mechanical processes. Adding an interacting environment spoils this isolation, so an organism-environment process must transcend the mechanical constraint. This point can be amplified on by commenting on the treatment of the term 'action'.
Action has a mechanical context.
It applies to inanimate systems. It has a technical definition that characterizes the path taken by a mechanical system in phase space. Hamilton's variational principle describes minimizing action to determine the dynamical path taken by a mechanical system. In the context of organism-environment processes, I would substitute the term 'behavior' for action. This is a nice definition of the meta-mechanical open system.