Eugene knew this was coming for years. He was in violation of Industry Guide 7 and he could not fully answer the sec's comments without implicating Tarun Mendiratta who was already busted by the sec and FBI for other securities violations. The form 15-12(g) was never coming, he had to be current in his filings up to the date he submits a 15-12(g). That was not going to happen for the above reasons plus the admin order taken against him and his son.