IMO option C is applicable to companies that de-register the shares with form 15. Arrayit used form 15 to suspend reporting only, so they wouldn't have to file form 10 to register shares again.
IMO Arrayit must have worked out a deal with the SEC not to get suspended. Part of the deal could be to file a form 15 to suspend reporting, tweets, PRs etc and then produce fins for the last couple of years or so within a given time frame.
The SEC has leverage because if Arrayit does not keep its side of the deal the SEC could suspend trading or revoke their registration.