Having represented people who have gotten these letters in the past you end up on a not so pleasant list at the SEC.
They mishandled this completely. The correct course of action when they knew the were going to miss the deadline in the comment letter was to ask for a two to three extension.
When you don't respond and get a more demanding letter (which they got) you make the list and draw the ire of the SEC Staff.
The strange thing is all of the questions were simple to answer.
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