Looks like super crappy (and I mean crappy) due dilly was done in the first place.
If you review the documents submitted to otcmarkets.com, there's one by counsel of record (JK) post the Earth Surfaces' deal. Not going to spell it out but if you GOOG(le) him up, there's an old (and I mean OLD) NYTimes' story mentioning him (Diana Henriques) plus a fairly recent action by the USAO for Western District of NY.
In addition, there was a spam campaign by several promoters post the r/m including a website owened/controlled by RW (Dallas) who was already recently cited by the SEC in another action.