I glanced at the link you posted. I saw Peacock's name and the hair on the back of my neck stood up. I remember that tool.
If this 3(a)(10) is a sham, it's because of Stephen Hicks and the naivety of some cheap ass attornies. The SEC is already onto Hicks.
FWIW, I contacted the CEO and inquired about Tarpon's involvement. He stated his attornies looked into Hicks and they didn't see any issues. I don't believe that, and I've hounded the CEO about it ever since. I even insinuated that his attornies are in bed with Hicks. I'm a nobody and I can see this deal is wrong, in so many ways.
IMO, I don't think it was a sham on the part of the company. It was Hicks' idea. I think he talked some amateur securities attorney into it.
Which setup his next move.
Thanks for the email.