IMO the 180 days will start by the first trading day. First a market maker makes a market for the new IPO
This is from the S1 To be quoted on the OTCBB, a market maker must file an application on our behalf in order to make a market for our common stock. We have engaged in preliminary discussions with an NASD Market Maker to file our application on Form 211 with the NASD, but as of the date of this prospectus, no filing has been made
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