While a R/S might be the standard trick here, Lumb & Lowenthal have never R/S any of their scams. They just let them drift off, find another shell, and create a new "mining company."
I am beginning to suspect that it is a good strategy. Despite the number of scams that these guys have run, and the fact that FINRA has been made aware of Lumb's shenanigans in HGLC, they have managed to avoid full-bore SEC scrutiny. Perhaps not doing a R/S has kept them under the SEC's radar.