This is a huge point and one that should have been made earlier.
The specious argument over whether the shares were 'bought' or 'acquired'is a waste of time and is irrelevant.
The inescapable fact is that the shares were issued by the company.
They weren't issued by Gendarme, they were issued by the company. They were legally issued by the company.
SEC did not have a problem with the shares, they did not have a problem with RCCH or with the sale of shares. Their issue was with the legal instructions provided by Gendarmes lawyers to the issuing agent.
2.1 billion shares were ISSUED. It doesn't really matter if they were bought, acquired, traded for, ransomed, or gifted. Regardless of the transactional details between Gendarme and Newton, 2.1 billion shares were issued by RCCH.
