Rule 12g-4 -- Certifications of Termination of Registration Under Section 12(g) 2. Such class of securities of a foreign private issuer, as defined in Rule 3b-4, is held of record by: i. Less than 300 persons resident in the United States or ii. Less than 500 persons resident in the United States where the total assets of the issuer have not exceeded $10 million on the last day of each of the issuer's most recent three fiscal years. http://www.law.uc.edu/CCL/34ActRls/rule12g-4.html
Rule 12h-3 -- Suspension of Duty to File Reports under Section 15(d) b. The classes of securities eligible for the suspension provided in paragraph (a) of this section are: 1. Any class of securities held of record by: i. Less than 300 persons http://www.law.uc.edu/CCL/34ActRls/rule12h-3.html
And NDOL claims "Approximate number of holders of record as of the certification or notice date: 232"