504s are all about selling shares to Investors These 504s under 504 b 1 iii are exceptionally bad The company can sell shares any time it increases the Float
As a matter of fact our "1" Investor could have started selling 15 days prior to the Date submitted
A Compliance Guide for Small Entities and Others* Form D is a form to be used to file a notice of an exempt offering of securities with the Securities and Exchange Commission. Commission rules require the notice to be filed by companies and funds that have sold securities without registration under the Securities Act of 1933 in an offering based on a claim of exemption under Rule 504, 505 or 506 of Regulation D or Section 4(6) of that statute. Commission rules further require the notice to be filed within 15 days after the first sale of securities in the offering. For this purpose, the date of first sale is the date on which the first investor is irrevocably contractually committed to invest. If the due date falls on a Saturday, Sunday or holiday, it is moved to the next business day. The SEC does not charge any filing fee for a Form D notice or amendment.
Market Data 
Markets 
