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ForReal

11/22/14 11:08 PM

#24564 RE: Empirica #24563

Thank you. I do have a couple of questions, with regard to your enlightening response.

Because STOA is a SEC reporting company, does not the Regulation Sho prevent those short sellers from selling their shares short, without the ability to deliver physical shares to the buyers?

If $350,000 of convertible debt has been locked up until March 2015, it would be impossible to deliver physical shares until then to the DTCC, within the 30 day time period required. Or is the promise of being able to produce those shares adequate enough to satisfy SHO regulations? If that is the case, anyone holding a large block of shares, could short the stock and then cover their short position with a cover purchase. Meaning, the debt holders could cover, before even converting the debt instruments, and still have conversions occur at deflated value and really flood the market. If that is the case, we could be looking at a lot more than 12 to 13 million more shares added to the float.

The good news is. If I have a confused scenario of what could occur, your estimate of 12 to 13 million more shares entering the market is not much of a catastrophe for an OTC company. 40 million shares O/S or even Float, for an OTC company is considered miniscule in this market. Positive news, via MarketWire or PR Newswire for an OTC company with a 40 million share float, would cause the share price to rocket, in the OTC.

I would appreciate your comments and clarifications to my post, if you get a moment to respond.