Clearly, investors are not buying the concept. PPS is as low as a stock price can go. Stock prices are fueled by expectations. Nobody believes the bonds are real.
If one reads through the whole document, then they can understand how bearer instruments can end up issued to NON-U.S. persons. I think that is important in understanding how the bonds could have come into the hands of the original holders.
The document opens another can of worms IMO for ING NV. If they 'cleared' the bonds in question during the bail-out, then they've incurred the tax liability on those instruments also. BTW, I am researching the 2009 ING bail out and have been in contact with a writer from Bloomberg Europe who covered that subject.