Sorry No such thing as exempt shares with a non reporting dark shell. All shares/securities would be considered controlled from the time that they went dark. The OS is frozen and no new shares may be released into the open market. This prevents scams from happening and going dark and releasing shares into the open market. The only shares that can be traded is the frozen OS which is 30B here. This has been confirmed with the SEC which feel free to do some DD and contact them yourself if you need further clarification.
They said that the only time the AS shares can be sold is during an RM to the acquiring company but they still cannot release shares into the open market from that until all the paperwork is submitted. Again the only shares that can be sold or traded are the OS of 30B.
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