Bots Inc (BTZI)

[lesgetrich]

I've effectively proven the excuse with Rule 6490 was nothing more than fiction -- the SEC and an OTC attorney says otherwise.

They also need to file their contracts on an 8-k, which they haven't filed a single one since GLF...sure,

My argument didn't rely solely on Rule 6490. I quoted directly from the SEC regs...

17 CFR Parts 228, 229, et al. Additional Form 8–K Disclosure Requirements and Acceleration of Filing Date; Final Rule

No attorney will tell you not to do something when it's safer to do it. They err on the side of caution. As for the SEC rule regarding material information, see the following statement from the same regs...

Item 1.01 Entry Into a Material
Definitive Agreement
New Item 1.01 requires the disclosure
of material definitive agreements
entered into by a company that are not
made in the ordinary course of business.
The item parallels Items 601(b)(10) of
Regulation S–K 33 with regard to the
types of agreements that are material to
a company, a standard already familiar
to reporting companies.34

It can very easily be argued that construction contracts, such as GLF, are part of the ordinary course of business of Grow Contractors. Do you know of any construction company that puts out an 8-K for every contract they sign. Each of mCig's construction contract (we know of at least four) were large commercial projects worth millions. Are you arguing that none of them were made in the ordinary course of their business?

Moreover, the company recognizes that its disclosure controls aren't perfect and expects to make improvements as funds become available. This was disclosed on the last 10-Q...

Item 4. Controls and Procedures

Evaluation of Disclosure Controls and Procedures

Disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act) are designed to ensure that information required to be disclosed in reports filed or submitted under the Exchange Act is recorded, processed, summarized and reported within the time periods specified in SEC rules and forms. Disclosure controls and procedures are also designed to ensure that such information is accumulated and communicated to management, including the principal executive officer and principal financial officer, to allow timely decisions regarding required disclosures.

We carried out an evaluation, under the supervision and with the participation of management, including our principal executive officer and principal financial officer, of the effectiveness of the design and operation of our disclosure controls and procedures as of July 31, 2016. In designing and evaluating the disclosure controls and procedures, management recognizes that there are inherent limitations to the effectiveness of any system of disclosure controls and procedures, including the possibility of human error and the circumvention or overriding of the controls and procedures.

Accordingly, even effective disclosure controls and procedures can only provide reasonable assurance of achieving their desired control objectives. Additionally, in evaluating and implementing possible controls and procedures, management is required to apply its reasonable judgment. Based on the evaluation described above, our principal executive officer and principal financial officer concluded that our disclosure controls and procedures were not effective as of the end of the period covered by this report because we did not document our Sarbanes-Oxley Act Section 404 internal controls and procedures.

As funds become available to us, we expect to implement additional measures to improve disclosure controls and procedures such as implementing and documenting our internal controls procedures.

In any event, all major contracts have been disclosed in PR's. If you have a complaint, take it up with the SEC.