Sorry, but this case is the definition of "black and white".
NEWC has a legal obligation to file forms 10-Q and 10-K with the SEC. NEWC did NOT file the legally required documents. That makes them guilty. Period. No exceptions.
There is no defense for this - they did not do what they were legally required to do. That led to the suspension and the coming revocation.
No one is to blame for this failure but NEWC's management. Period. The SEC did their job - Campo did not.
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