No the offering is a POOL of 1.5m shares restricted, Securities, etc. no mention of 1.5 MILLION $$... There is no mention of any of this money being raised through the sale of the pool of shares that is set aside early on to do anything other than PAY THE BOARD AND OFFICERS as it says in # 16 of the form D.
Any other use of the money MUST BE TRANSPARENT in the form. The whole reason for the form D. See below
6. Use of Proceeds
Provide the amount of the gross proceeds of the offering that has been or is proposed to be used for payments to any of the persons required to be named as executive officers, directors or promoters in response to Item 3 above. If the amount is unknown, provide an estimate and check the box next to the amount.
$ 250000 USD x Estimate
10. Business Combination Transaction
Is this offering being made in connection with a business combination transaction, such as a merger, acquisition or exchange offer? o Yes x No