Jul. 19, 2019>>>FINRA’s Reply CONCLUSION Metatron was not current in its reporting obligations under Section 15( d) from 2010 through at least 2018, when FINRA denied its request to process and announce the reverse stock split. These missing reports provide FINRA with a basis under FINRA Rule 6490(d)(3)(2) to deny Metatron's request to process and announce the reverse stock split. The Commission therefore should dismiss Metatron's application for review.
Jul. 19, 2019>>>Applicant's Reply Pursuant to the Securities and Exchange Commission's ("Commission") Order Requesting Additional Briefing ("Order"), Metatron, Inc. ("Company''), hereby submits this reply brief in further support of its Application for Review of FINRA Action ("Application'') of the decision of a subcommittee of the Financial Industry Regulatory Authority, Inc.'s ("FINRA") Uniform Practice Code Committee, which affirmed the Department of Operations' ("Department'') denial of the Company's requested corporate action to approve its proposed 1:57 reverse stock split ("Corporate Action") pursuant to FINRA Rule 6490(d)(3)(2).
"For more than a decade, the Company has faced financial difficulties. Most recently, the Company has been forced to engage in debt and equity financings to continue operations, with the hope that it can begin to generate sufficient revenues. Until then, these financings are the Company's primary source of funds. The Company commenced its Corporate Action in order to increase its stock price and increase the number of shares of common stock available for these financings. Instead, the Company has spent 15 months attempting to obtain approval of the Corporate Action, all the while incurring significant expenses and fees in connection therewith." ---
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