Friday, October 02, 2020 1:02:09 PM
They do not met the 144 exemption.
The first question to ask is: Is the company a reporting company to the SEC. Answer: No the company is not a reporting company to the SEC. This cannot even be argued any other way with the 15-12G filed in 2018.
2nd Question: Since the Company is not a reporting company to the SEC was it ever a shell at any point. Answer: Yes it was.
As a result, Rule 144 is not applicable to the Company.
It does matter if they ceased to be a reporting company since the Company is not a reporting company to the SEC.
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