Not really kent. The SEC will slam you for both (if they ever manage get around to it). You can't make false and misleading statements in PRs or SEC filings.
Never-the-less, there have been plenty of cases where scam companies (not implying anything there) made false claims in SEC filings. YOu seem to think that if it is in the SEC filings, it can not possible be false. I don't know, but CEO's that have even the slightest concern over SEC regulations would not be posting on messageboards while telling folks to buy all the shares they can get their hands of.
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