Jimbo, The REGDEX is, as you know, old news. We were discussing it back in March and we all thought that was the reason the stock was trading at .002-.003.
But I think you are right. I don't think you have to file it if the stock is not registered pursuant to section 12(b) or (g) of the '34 Act. Maybe they were told they could use the intrastate exemption, all sold in one state. I've found that even lawyers who deal with this stuff are confused. In pinkyland, they tend to just go ahead and do stuff and don't worry about the niceties. My friends in the SEC give me conflicting answers when I ask them this type of question as we have discused before. I believe you've had similar conflicts in your travels.
As you know, pinkie world is the wild west and CEO's have promoters and IR guys hitting them every day when they are in formation, with wild promises. The reality is that most of the IR and financing turns out to be toxic, sometimes with the help of MM's and abusive short selling. Yes, I know we disagree there.
I suspect this is what happened back when the stock came down from .30-.40. I don't think there is any 504 stock being sold now. It's not trading that way.
If ever there was a day that a stock could get clobbered after a huge runup, today was the day. The strong finish tells me that people don't want to be out when the audited financials are published.
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