The attorney letter is old information and also does not look at derivative securities or current share structure.
The number of outstanding shares may now have doubled?
This is the "unaudited" information the attorney relied on:
Information and Disclosure Statement for year ending December 3l, 201 4 (including Financial Statements for the year ended December 31, 2014)
Also note this little tidbit from the letter.... ....except that no opinion is given with respect to to Rule l5c2-l l(a)(5)(xiv), (xv) and (xvi) under the Securities Exchange Act of 1934 (the "Exchange Act"):