See that's the problem. They probably should be, and if they are it would add great credibility to the company. If they aren't, then they are converting based on preferreds or some convertible note or using some third party that they claim is not an affiliate. But if they're going to seek real investments and they're going to do it by the book, then they'll issue 144s. If that's the case, then they'd ungag the transfer agent. If they have something to hide, the transfer agent will be gagged.