The legal definition of a shell is the SEC definition, believe it or not. It doesn't matter if OTCM gives it a shell designation, it is still a shell both legally and in any SEC enforcement. I really don't understand what is hard about this concept. https://investorshub.advfn.com/uimage/uploads/2022/10/21/bfnunScreenshot_20221021-025047_PDF_Viewer_&_Book_Reader.jpg