Restricted stockowners need permission of the SEC to sell.
Whoops...WRONG. The restricted shares could be transferred to a PIPE funder who could have them cleared easily without contacting the SEC. In fact I believe the transfer agent can clear the transactions. SEC never needs to "give permission" that i am aware of. If they did, then the filings Form 3s (Brown, Harrs) and Form 4s (Southern Candle, etc) would appear on the EDGAR site as public record...which they (obviously) do NOT. You vastly under estimate Brown and Harrs' (or at least their attorneys and accountants) sophistication in running their scam. Vastly under estimate...IMHO.