The Real DTCC Discussion

[BigBake1]

That is pure dilution, the "W" is a trade modifier submitted to FINRA that tells them it is a "Weighted Average Trade Transaction". An insider/financier/debt holder has a large Block Position of newly converted free trading shares. The broker sells to the market at market price in multiple transactions, the broker then buys from the Block Position at an averaged price sold to market less a Block Position fee of 1.5% and records that transaction to the tape in one transaction with the Trade Modifier.

There wasn't a Chill present, as to why they filed that attorney opinion letter, quite simply to say they can dump shares into the market using an exemption from registering shares. The SEC clearly states that shell companies cannot use exemption to SEC Rule 144. To be considered no longer a shell company, called curing a shell status, they must file one year of audited financials into EDGAR. They clearly have never done so, therefore that attorney opinion letter is quite meaningless.

You are correct they are using it to remove the restricted legend and dump shares.