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Re: None

Tuesday, 02/24/2015 10:00:19 AM

Tuesday, February 24, 2015 10:00:19 AM

Post# of 403584
Based on two conversations that I have had yesterday and today with Nasdaq Listing officials, during which no specific companies were identified, it was made clear to me that my interpretation of their listing rules was more conservative (their term) than their own.
Specifically, the term "operating history" is not strictly defined to refer to companies with revenues although both gentlemen I spoke to could not provide a strict definition, suggesting that it was broadly defined for listing purposes and that the issue of whether an applicant actually had an operating history was one that came up regularly. Furthermore, in spite of the rules clearly stating that "For purposes of this paragraph (B), net tangible assets or average revenues must be demonstrated on the Company's most recently filed audited financial statements.....", Nasdaq will look to a company's most recent 10-Q for asset values despite that fact that they are not audited.

Based on those conversations (which went more smoothly than most of my conversations :o) ) it appears that there is indeed some wiggle room in at least some of the Nasdaq listing rules that wasn't apparent to me from the way they actually appeared on the page. Hence I won't be quoting them any longer.

GL!

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