You are citing a superseded Corp Fin determination.
The filing in Edgar, SEC correspondence dated Oct 2019 and Maranda Fritz, DBMM attorney’s Oct 2019 letter to Judge Foelak attested DBMM’s compliance by Corp Fin.
Judge Foelak on Nov 12, 2019 Dismissed the Case and stated there is case law that a Super 10-K is filed the preceding Q’s are irrelevant to the shareholders and the Commission.
Shapiro was first pass by Corp Fin in June 2018 and superseded as stated by DBMM’s Attorney in Motion for Dismissal in March, 2019 and subsequent letters to Judge included in AP file.
Quoting old, outdated info does not inform anyone.