No, they didn't have to. It was only signed by "Davis" and then by "Davies". http://www.sec.gov/Archives/edgar/data/1303361/000114420411020327/v217647_15-12g.htm http://www.sec.gov/Archives/edgar/data/1303361/000114420411022652/v217647_15-12g.htm Carrillo or Huettel may have written it, though, or at least advised on it.