"The action notice stated: "DECN’s sales forecasts for the COVID-19 test kit that up to 525 million test kits would be sold in the first year of production.""
Those are the SEC's words, not the Company's. They likely used "up to" to distinguish that estimate from the previous estimate of 400 million (IIRC).
To clarify, the SEC actually said "issuing sales forecasts that up to 525 million COVID 19 test kits would be sold in the first year of production."
The Company definitely used "forward looking statement" language which would ordinarily offer some protection...except to a "penny stock". UNLESS the Company knew the expectation expressed to be unreasonable at the time it was made.