Spongetech Delivery Systems, Inc. (fka SPNGQ)

[loanranger]

Mike,
I'm sure that you've read part (iv) of Section 5. Holdings To Be Reported of the instructions, wherein it indicates that the filer can report either their own proportionate share or the entities total share, without requiring them to indicate which option that they are selecting (Brilliant!). The instructions also suggest looking at certain sections of Rule 16, which I've reproduced at the end of this post (hint: useless).

I can't help offering an opinion:
If they're reporting their proportionate share that would indicate that 1)they have equal ownership positions in RME and 2)no one else and no other entity has an ownership position in RME.

Just based on that I think that they are each reporting the total RME position. I'm pretty sure that the 3 people involved have never reported equal ownership of anything else and there's a history of lots of peripheral parties........especially going back to the days prior to SPNG.

Just going with the odds.

Useless:
http://www.law.uc.edu/CCL/34ActRls/rule16a-1.html
B. A general partner's proportionate interest in the portfolio securities held by a general or limited partnership. The general partner's proportionate interest, as evidenced by the partnership agreement in effect at the time of the transaction and the partnership's most recent financial statements, shall be the greater of:

The general partner's share of the partnership's profits, including profits attributed to any limited partnership interests held by the general partner and any other interests in profits that arise from the purchase and sale of the partnership's portfolio securities; or

The general partner's share of the partnership capital account, including the share attributable to any limited partnership interest held by the general partner.

XXXXXXXXXXXXXXXX

(iii) A shareholder shall not be deemed to have a pecuniary interest in the portfolio securities held by a corporation or similar entity in which the person owns securities if the shareholder is not a controlling shareholder of the entity and does not have or share investment control over the entity's portfolio.