No, that’s not what I’m going to tell you. If the 20 headsets are owned by the aircraft owner and being carried for the purposes of trade, it’s no longer a private operation. That’s because the aircraft is no longer being flown for a purpose that falls within the scope of 2(7)(d).
(In the crazy world that is classification of operations, if the 20 headsets were instead owned by the sister of the aircraft owner, no problem! Private and no AOC required! The stark difference in risk caused by the difference in title to the headsets is obviously the justification for the different classification.)