You might want to look into the reliability of that article. You quoted it correctly as saying: "the key being that a convertible note is not a security that would allow an opinion to clear stock under a Rule 144 exemption."
That was surrounded by other language as follows: "Several months ago COR Clearing decided to make it near impossible to clear any stock derived through convertible notes coming from OTC Market issuers. That decision was based largely on several issues, they key being that a convertible note is not a security that would allow an opinion to clear stock under a Rule 144 exemption. I won’t get into the legalities of this here other than to say to look up both the New Earthshell v. Jakoobit case in the US District Court for the Southern District of New York, as well as the Reves v Ernst & Young US Supreme Court case." https://www.thebasilelawfirm.com/single-post/2018/04/12/THE-FRIDAY-THE-13TH-CONVERTIBLE-NOTE-MASSACRE
Maybe the other case he mentioned is relevant but based on the irrelevance of the first one I won't be wasting my time looking it up.
Mr. Basile is Securities Counsel for a penny stock company that hasn't made a filing in a year and a half. It has been suggested that his little Friday the Thirteenth letter was created to drum up some business for his law firm. His Linkedin bio lists him currently as CEO for: "Cloudlake Capital Group LLC is a new type of Microcap lender. As a private investor, CGC invests in distressed Microcap companies focusing on purchasing existing debt and then modifying existing debt terms in order to make repayment more practical and less onerous".... so he's likely to be just the kind of lender that he's warning people about. https://www.linkedin.com/in/markbasile/
All I'm say is that you might think twice before taking any action, or not taking any action, based on Mr. Basile's red flag letter.
BTW, 90% of the internet appearances of THE FRIDAY THE 13TH CONVERTIBLE NOTE MASSACRE blog are on Ihub....it has had a limited audience.