I disagree.
http://www.pinksheets.com/about/pr_042407.jsp

Pink Sheets to Begin Rollout of Disclosure Categorization Starting May 2007

New York, NY - April 24, 2007 - Pink Sheets, LLC announced today that in May 2007 it will begin the process of categorizing issuers quoted on Pink Sheets based on a company's willingness to provide adequate public disclosure to the marketplace. Initially, each company will be assigned a proposed category, which will be indicated on their Company Info page in the Quotes & News section of www.pinksheets.com. Beginning August 1, 2007, all companies will be assigned a final category and a corresponding icon which will be displayed next to the company's symbol everywhere it appears on pinksheets.com.

All Pink Sheets companies will be placed in either the OTCQX premium tiers (companies must apply to be included) or will be assigned a disclosure category by Pink Sheets, as follows:
OTCQX Premium tiers
PremierQX - The highest tier for U.S. companies. Must meet the continuing financial requirements of Nasdaq Capital Market, provide credible disclosure to the marketplace, and nominate a Designated Advisor for Disclosure (DAD).
PrimeQX - Must have ongoing business operations, a $.25 (cents) initial bid price, provide credible disclosure to the marketplace, and nominate a DAD.

International OTCQX Premium Tiers
International PremierQX - The highest tier for international companies. Must meet the financial requirements of the NYSE's Worldwide Listing standards, be listed on a qualified international stock exchange, provide home country disclosure to U.S. investors in English, and nominate a Principle American Liaison (PAL).
International PrimeQX - Must be listed on a qualified international stock exchange, provide home country disclosure to U.S. investors in English, and nominate a PAL.

Disclosure Categories
Current Information (icon: Pink Checkmark) - Must either be registered with the SEC pursuant to 12(g) of the Exchange Act and current in all electronic filings posted on the SEC's EDGAR system, OR if not registered with the SEC, must meet Pink Sheets Guidelines for Providing Adequate Current Information, confirmed by a quarterly letter from an attorney, all of which must be posted on the Pink Sheets News Service and displayed on pinksheets.com (*- exceptions below). Disclosure is deemed to be current if it is posted within 120 days of the fiscal year ended (annual reports) and within 60 days of the quarter ended (quarterly reports) and interim material events should be disclosed on a timely basis.

*Banks and Financial Institutions - Companies that report to federal or state banking regulators or to insurance commissions will be placed in the Current Information category if they post onto Pink Sheets News Service the same information they supply to their regulator (for example, to the FDIC), in a timely manner. An attorney letter is not required.
*Foreign Private Issuers - Non-U.S. companies that do not furnish electronic reports on the SEC's EDGAR system that are listed on a qualified international stock exchange will be placed in the Current Information category if they post onto Pink Sheets News Service the same disclosure they supply to their home country exchange and to their shareholders, in a timely manner. The disclosure must be in English. No attorney letter is required.
Limited Information (icon: Yield Sign) - SEC registered companies must have posted some disclosure on the SEC's Edgar system within the last six months. Non-SEC reporting companies must have, at a minimum, quarterly financial reports prepared in accordance with GAAP, including financial notes, and certifications by the CEO and CFO and not less than six months old, posted either on Pink Sheets News Service.

No Information (icon: Stop Sign) - The company does not make disclosure publicly available, or its available disclosure is older than six months.

Caveat Emptor/Buyer Beware (icon: Skull & Crossbones) - There is a public interest concern associated with this company, which may include a stock spam campaign or other questions concerning the security or issuer. During a spam campaign, companies that have not, at a minimum, qualified for the Current Information category will also have their company's quotes blocked on pinksheets.com.

More information on the category rollout, including Pink Sheets Guidelines for Providing Adequate Current Information and Attorney Letter Guidelines verifying Current Information, is available on http://www.pinksheets.com/otcguide/categories.jsp.

About Pink Sheets, LLC
Pink Sheets, LLC is the leading provider of services, software and financial information for the over-the-counter (OTC) securities markets. Its electronic quotation, trading and disclosure services enhance the efficiency of OTC trading, provide better executions for OTC investors and improve the capital formation process for OTC issuers. For more information, visit the Pink Sheets website at www.pinksheets.com.

Actually, they are not disclosing to OTCQX. OTCQX is the 'premiere' tier. PBLS is 'disclosing' on the regular pinksheets.

PS... To even be eligible to submit for a listing on the OTCQX, the share price must close at or above $0.25 for 90 days prior to application for listing. Hopefully, we will get there MUCH sooner than I expect!

I don’t want to hear any more news until after the release of financials!

In fact, I’ve contacted Ron in the past and suggested that they do not release news until after the release of financials. He was concerned that if they did that they would be susceptible to charges of withholding information in order to manipulate the stock price. My reply was that it is perfectly legal to perform due diligence and make sure that every ‘t’ is crossed and every ‘i’ is dotted. Besides, we all know what can happen when information is released prematurely (e.g., Best Jets). Why do I strongly feel that it makes much more sense to hold back on the release of news? Because I want the share price to be as high as possible and I want it to establish a new base at the highest possible level. So why will releasing news prior to the release of financials result in sub-optimal price changes? RISK/UNCERTAINTY! Investors (thus ‘markets’) loathe uncertainty and undue risk. Until the financials are released and digested by the investing community there is too much uncertainty and risk in the PBLS environment for optimal sustained momentum to occur. For example, let’s say they release a nice PR relating to an acquisition. Many investors will say, ‘So What, show me the financials first!” The bashers will say the same thing. The first and major psychological hurdle that must be overcome is for PBLS to actually release the financials and make ‘good’ on their word to do so. They could release an incredible PR and it would not have nearly as much impact as it could (or should) because the huge black cloud of ‘financials’ hangs overhead. The financials need to be released and digested by the investing community. PBLS has to remove the uncertainty that maybe they won’t release the financials on time or that the financials are ‘not good’. When they do this, they will have removed the most important hurdle to investor confidence and thus have removed the greatest brake to upward momentum. Then when they release news, it can be received in an environment that is conducive to positive upward pressure because the uncertainty regarding financials (which includes share structure) is no longer holding back upward price movement. Waiting to release news until after the release of the financials also allows time for the ‘buy the rumor, sell the news’ effect to have occurred and thus the base will be more stable. Releasing news prior to the financials most likely results in both events working at cross-purposes: While there will be some –diluted, due to the uncertainty regarding financials- upward pressure due to the release of news, there will also be some downward pressure that will occur due to ‘selling the news’ when the financials are released. It makes much more sense for the ‘news sellers’ to sell and for the financials to be digested for a few days which should result in a more stable price. THEN, news can be released into an environment that has been optimized for positive reactions to said news. Look at this another way: News is released now. The effect is definitely muted because the financials have still not been released. Let’s say the financials are not as good as most expected, then there will be downward price pressure. It’s much better to release positive news into an environment in which said positive news is the whole story and thus is the major driver of price change. It’s as simple as this: Consider the release of news to be like igniting a fire. If a flame is released into an environment in which there is a lack of oxygen, the flame will not burn as bright or as long. Releasing news before the release of financials is like lighting a match in an oxygen deprived environment with the chance of rain and high winds that might blow the flame out before the fire is started! It makes much more sense to make sure that there is plenty of oxygen, the wind has died down and there is ample dry fuel available. Even if any news that is released is fantastic, the effect will not be the same if investors have to hold off, wait for financials, digest said financials and then have to start momentum over again. It makes much more sense to release the news when it will have the most impact (i.e., will have the best chance to be received positively and in an environment in which investors feel comfortable immediately reacting to it).

So…. I actually misspoke. I do hope they release one more PR before the release of the financials. It would hopefully read something like this:
“PBLS is pleased to announce that we WILL release financials on the morning of June X. As part of the release, we will include future projections of revenue and earnings growth. Also, we look forward to providing additional exciting news in the coming days related to further acquisitions….”

That’s what I call “SETTING THE STAGE”

Dino

PS… Why potentially release financials on a Friday (June 15). If the numbers are good, why not release them on a Monday so that momentum is not retarded by the weekend?

There has been much discussion in the investment community (and by elected officials) for the need to RELAX Sarb-Ox rules for micro-caps. Thus, I don't forsee any immediate regulatory action regarding what Coulson is trying to do with the OTCQX. However, Pinksheets does have to make sure that the SEC doesn't consider the OTCQX to be a 'market' and thus fall under a different regulatory scheme.

JMHO,
Dino

PS...I have to run, I'll try to come back later and flesh-out the section about not being considered a 'market' (e.g.,NASDAQ or the NYSE)

I don't see it that way. My understanding (which could be very wrong, of course) is that they wanted to get the float down. Also, if they wanted to raise cash they could just sell shares on the open market, either before or after the releases. Also, Ron and Paul know that in order for PBLS to make 'blockbuster' deals, they need to have a much higher share price. They also know that if they want to personally have holdings in the hundreds of millions- 1/2 billion dollar range, they need a much higher share price. They are also smart enough to know that they need more investors to increase demand which causes an increase in share price and they are smart enough to know that in order to do that, they need to be considered as a 'real' company that is transparent, dynamic and growing and not just another pinky trying to pull a fast one by selling shares behind the shareholders back. They are smart enough to realize that what might have been acceptable (or necessary) a few years ago is not acceptable for where they are now and WHERE THEY WANT TO BE IN THE FUTURE.

Just my humble opinion, of course, but I sure hope I'm right!

Short Selling and Naked Shorting of PBLS:

Who is doing the short selling? My guess is that most investors can't even short sell PBLS even if they have the shares as most -all?- of the brokerage houses won't allow you to short a penny stock like PBLS. Thus, all shorting of PBLS would have to be naked shorting. If that is the case, then the naked shorting must either be done by the MM' or with the tacit approval of the MM's. If it is being done with the tacit approval of the MM's, who do they allow to naked short? Outfits like Cornell Capital and other 'investment groups'?
Following is a link to a site that discusses Naked Shorting:
http://www.wall-street.com/nakedshorting.html

Here is an interesting excerpt from the site:
Below are extremely truncated excerpts from a very interesting conversation posted on a discussion board. An investor decided to experiment by trying to buy a shorted stock from 2 different sources. Here's what happened. Read the whole exchange for many more details.

Dennis Smith Posted: "I thought it might be interesting to prove a short position first hand by purchasing shares in (GLKC) a company that reportedly already had over 100% of it's shares sold (and "legally" documented).... Just after settlement date (three days later), I requested certificates from both brokers. The cert ordered through Ameritrade appeared in three weeks....

Getting the Wells Fargo cert however has become predictably (and almost amusingly) problematic....":

From Wells Fargo: ...We are researching your request and will contact you directly as soon as we have completed our investigation....

From Dennis Smith: ...It's been five days. What kind of "investigation" are you doing?

From Wells Fargo: ... We were awaiting full delivery of the shares from the transfer agent. Unfortunately, due to some unusual circumstances, this took longer than we expected.

From Dennis Smith: What exactly are the "unusual circumstances"?

From Wells Fargo: ...The broker/dealer from whom your shares were purchased is short 5,000,000 shares versus the street. A broker/dealer is allowed to sell shares which they do not own, which they will buy at a later date and deliver.

From Dennis Smith: Exactly how later is "later"? Is not a 5,000,000 short position cause for alarm? Who is the subject "broker/dealer" from whom you acquired my "shares" and what is that dealer telling you about his apparent failure to deliver? As I understand it, a shareholder is entitled to physical certificates in every event, assuming the buy was legitimate.

From Wells Fargo: ...The other broker/dealer who is short shares of your security is E*Trade. Though this type of activity makes it difficult to issue physical certificates, it is legal and within regulations. There is no definite date by which E*Trade would have to purchase the shares.... According to our trading desk, E*Trade was the only broker/dealer offering shares of GLKC yesterday. This has been the case since you originally requested your certificate.

From Dennis Smith: You stated there is no definite date by which E-Trade has to purchase the "short" shares that they sold you and that in turn you sold me. How can this be "legal"? What is to prevent them from continuing to sell what they don't own while subsequently refusing to buy the shares back if there are no time constraints?...

My bottom line is this. I demand the physical GLKC certificate(s) representing the shares I purchased.

From Wells Fargo: ...We have received your request for physical certificates. As soon as we are able to order a physical certificate for you, we will do so.


TIA and GLTA

You just made me take another look at my sell orders... now at .50 $1.00 and $5.00 LOL

Sure would be nice!

GLTA

PS... I don't expect those orders to be filled any time soon ;)

Just looking down the road a bit... The information regarding requirements for OTCQX Prime has not always been clearly stated. Below is a section from Part B – OTCQX Admission Requirements that deals with eligibility criteria. Note that the share price has to be at least $0.25 for 90 days prior to the application date and that AUDITED financials are required. Let's hope the share price requirement is the easier of the two!!!

GLTA


http://www.otcqx.com/otcqx/docs/OTCQX%20Rules.pdf

2.3 PrimeQX Eligibility Criteria
To be considered for admission to PrimeQX, the Company shall:
a) Have ongoing operations and shall not be a Shell Company, Blank-Check
Company, Special Purpose Acquisition Company or Development Stage
Company;
b) Not be subject to any Bankruptcy or reorganization proceedings;
c) Be duly organized, validly existing and in good standing under the laws of each
jurisdiction in which the Company is organized or does business;
d) Have at least 50 beneficial shareholders, each owning at least 100 shares of the Company’s common stock;
e) Have proprietary quotations published by a Market Maker in the Pink Sheets;
f) Have a minimum bid price of $0.25 per share for its common stock as of the close of business on each of the 90 business days immediately preceding the Company’s application for listing on OTCQX;
g) Have (i) audited balance sheets as of the end of each of the two most recent fiscal years, or as of a date within 135 days if the Company has been in existence for less than two fiscal years, and audited statements of income, cash
flows and changes in stockholders’ equity for each of the fiscal years immediately preceding the date of each such audited balance sheet (or such shorter period as
the Company has been in existence), with each such financial disclosure made in
accordance with U.S. GAAP and including all matters of which the Company is
aware that are relevant to the Company’s ability to continue as a going concern,
including, without limitation, significant conditions and events and the Company’s
plans to mitigate such conditions and events; and (ii) unaudited interim financial
reports, prepared in conformance with U.S. GAAP, including a balance sheet as
of the end of the Company’s most recent fiscal quarter, and income statements,
statements of changes in stockholders’ equity and statements of cash flows for
the interim period up to the date of such balance sheet and the comparable
period of the preceding fiscal year; and
h) Be included in a Recognized Securities Manual.

Don't you need a share price of $3 for the AMEX? There are ways to get the share price up, but I don't even want to say or type the words!

Thank you. As you know, my 'insights' are just my humble opinions. Also, please note that there are many more experienced investors than I who post.

Best wishes with your investments.

LOL... thanks for the advice... I usually don't post very often..in fact I often go weeks without even looking in unless there's a PR or some price movement...

However, given that we are so close to disclosure of financials I thought I should try to be a voice of reason. After all, it's my company too and I don't want my investment harmed without due cause!

I don't think setting those shares aside made any 'technical' difference. However, they might have had to jump through some hoops/make state filings to authorize a new class of preferreds. I'm not an expert on this by any means. Just a guess....

I'll ask Mike Mulshine when I call him if they carved out approximately 60 million extra to use for something else. If they want to set aside 60 million out of 250 million and give those shares voting rights and then use those shares for acquisitons, that's fine with me. Remember, those shares were already authorized. Granted, they weren't in the float, but if they are used to grow the company... and if they can be restricted if used as compensation for acquistions, what's wrong with that?

Well, all I know is that 250/4 = 62.5 I do know that is a fact.

We all know that they have used preferred shares in the past when acquiring companies. I have no problem with them doing so. It is an incentive for the owners of the preferred (i.e, the former owners of the company) to make sure that the share price of PBLS rises. Also, using preferred shares in this way means they don't need to take on debt or use existing cash.

Here's my best guess is to HOW it happened. They wanted to reduce the float to get the share price up. Why? Higher share price makes them a much more attractive partner (e.g., makes it easier to consumate deals using preferred shares) and makes them more attractive to investors. They were sitting around the conference table and decided to try to get the float down via the conversion of common shares into a new class of VOTING preferred shares that paid a dividend. Someone says, "well, let's allocate a quarter of the authorized preferred shares, that still leaves us plenty of non-voting preferred shares to use as needed." Someone else, says, "Sounds good". They divided 250million authorized preferred shares by 1/4 and came up with 62.5million. That's how they got the "odd" (according to posters) number of 62.5. They were hoping to get 400million of common shares converted. They never even thought about multiplying 62.5million x 167.

END OF STORY! MUCH ADO ABOUT NOTHING!!!

JMHO!

They didn't CREATE any additional shares! Those 62.5 million shares already existed.

They were not off by billions. They just didn't THINK about what they were putting out. They just said, "let's set aside a quarter of the authorized preferreds". They didn't need to set aside that much for the conversion. IMHO, it really was just a mistake. The 62.5million figure is irrelevant, it only means that if you take 1/4 of 250 you get 62.5!!!!!!

I posted this earlier today. It sums up my feelings:

What do we need for a much higher share price down the road?
1. Good financials
2. Appropriate share structure given said financials
3. Investor confidence in PBLS
4. Investor confidence in the OTCQX

3 & 4 go hand-in-hand. As we all know, MOST investors won't touch a pinky. Hopefully Pinksheets will be successful in changing that. Sure, we can go much higher without 3&4, we see that all the time with POS pinkies. But those POS stocks don't STAY there. I believe PBLS will be a good enough stock to maintain a much higher share price and hope that many new investors will agree as time goes on. I do believe it will take time and I'm willing to wait.

GLTA

I think you and I agree that it was a mistake to have used the 62.5 million figure. Call that sloppy, not-thought-out, but I don't think it was a 'slip-up' based upon having 10.4billion shares outstanding. JMHO

Millions? Probably. Billions, I don't think so.

Again:
1. They thought they needed to get the OS down to around 815million to meet requirements for 12g registration with the SEC. That is how the 815million number came about. It was a target based upon meeting SEC requirements.

2. According to Mulshine, they wanted to reduce the float by approximately 1/2, theoretically doubling the value of the shares remaining in the float. Thus they offered the conversion in the HOPE that 400million common shares would be converted into the new class of preferred shares.

Was the OS count around 815 million when they announced the conversion program? I don't know. I asked Mulshine and he couldn't provide a definite answer. Do I believe it was in the billions? No.

I posted the explanation given to me by Mike Mulshine. I believe the explanation. Of course, it is pefectly fine for you to not believe it!

They were not trying to get the OS down to 815million via the conversion to preferred. They were trying to HALF the 815 million.

All I really know is that I wish had a lot more shares!

Actually, a very specific PR! lol They just said, "okay, let's make 25% available" without either doing the calculations to realize that it didn't make any sense OR just assuming that it was irrelevant.

Honestly, I have no idea. None whatsoever. The 'market' will determine that and if I could read/forecast pinky markets I'd be sitting on a beach right now!

That is not what they meant. Read my earlier post. They set aside a quarter of the authorized preferred. They should have just said they were hoping to convert approximately 2.5 million of preferred. Much ado about nothing, IMHO.

Theoretically available as there are not 10.4 billion certifiable common shares floating around.

Personally, it's nice to know that they were trying to get down to around 800million. Of course, what happened after they realized that they didn't need to is not known. However, we will know when the financials are released. I think the numbers will look good (or else they wouldn't be releasing them).

400million / 167 common shares = 2,359,209 preferred shares needed out of the 62.5million 'available'.

I just called Mike Mulshine. He said they set aside 25% of the 250 million authorized shares. The hope was to get 400million shares turned in, approximately half of the magical 800million that has been bandied about. Why the 800million share count number? He stated that at one time, PBLS thought it would be filing as a 12g company with the SEC and they believed they need to get the share count down in that range to meet requirements. As we know, they are not filing with the SEC at this time. I did not get to ask him about future SEC filings or moving to the OTCQX as he had to take a call from their SEC lawyer. I will try to call him later today.

10,437,500,000 that is correct. LOL... no one noticed that before? I know that I didn't... I just worked it from the other end using some of my shares as a starting point. Naw, they couldn't have had that many shares outstanding... could they? Did you ever contact PBLS or Mulshine?

Yes, that is my understanding also. They were approached by both 'professionals' and some shareholders.

Do you know when the first dividends were scheduled to be paid? Payments may not be scheduled to start until the 3rd quarter.

I just got back after 11:00 and just now checked the trading on PBLS. Down a few %. You have to admit that PINKY-LAND can try one's patience,lol.

I don't think they EXPECTED to have 62.5 million converted. I believe that was the LIMIT they felt comfortable with.

Something else that would help greatly (especially in bringing in 'non-pink' investors) would be for PBLS to be touted by a REPUTABLE 'stock picker' like Tobin Smith. To me, at a minimum, reputable means that the advisor is independent and does not charge the companies that he includes in his stock picks. I'm quite pleased that PBLS has not used pump-and-dump chumps!

My guess is that many of those are foreign stocks and/or known stocks that 'dropped' down to the pinks. Just a guess though. My main point is that it will be a heck of lot easier if Coulson/Pinksheets can be successful in changing perceptions.

My guess is that Paul is not a fool! Although he and other insiders may not hold 50.01% of voting shares, my guess is that they will still have enough shares to control the outcome of any vote. I can't envision a situation where a majority block could agree on a different course of action AND get enough proxies to effectuate a change. JMHO

PS... Besides transparency issues, it appears to me that Paul and Ron have done a fantastic job of growing PBLS from a sand-pit into a dynamic holding company. Of course, the proof is in the -financial- pudding.