While I an not an SEC reg expert in Steroids, yet, that is kind of what I was thinking.
If any one knows how to do that, how to pull that off, Kuban, Yarbrough and Mathias probably wrote the Book on it.
So far all I saw offered as evidence saying it was not possible, yet, was fluff PR style pdf that is 9 years old, that was not an Attorney legal opinion.
If I had answered my question, and if I was an expert on CFR/FR current regs ( I am not), I would have posted a 400 pages of citation of the actual Codified SEC regs, round robin legalese (like I do on my field), and not some flowery layman's language fluff to back up my claims.
Thanks for the post:
"Well, maybe they're going to raise $40 million with an underwritten public offering, which would exempt them from the seasoning period."