American Scientific Resources (ASFX)

[makeamint2]

in my years of experience in running a public company (NASDAQ large cap)including the pre ipo work, as well as other involvements with publicly traded companies, i have never seen insiders / shareholders (particularly promoters and affiliates)restrict there shares without outside pressure to do so.

its simple enough to look at the comments from the SEC,( both the legal and accounting side) if the company is inclined to share. that will show any pressure from the SEC to impose the restrictions. I will say that i doubt that was the case. SEC rarely takes such an agressively prejudicial posture. more likely a result of pressure from lenders, creditors or quasi committed future capital sources.

By the way there may be a least 3 rounds of comments by now since the original S-1 filing date. I ma not sure of the current lead times but as recently as 2 years ago it was about 45 days from submission to comments. And again they are just that "COMMENTS" they rarely say "Do X Y & Z". Instead it is indirect comments to issues.

And just because round 1 of comments did not raise a specific issue, I can tell you from direct personal experience that round 2 comments etc., can and usually do include items that were not commented in prior rounds.

Personally I am convinced that it was the latter. Not some draconian SEC edict. And absolutely do not believe it was any kind of heartfelt "Gee this is the right thing to do" on the part of those impacted by this.

an afterthought........ maybe the NASD, had a voice in this issue.