no really not. Really wonderful you are here freewheeling your thoughts on the subject like a thought exercise, but it is advised to actually do the work and read a lot of literature on the subject and post the relevant parts as I have done over the years. So if you want to convince anyone please dive into the many articles and publications. Let me give you a headstart:
It is too easy to say there is not legislation that applies specifically for NWBO, the legislator/SEC/DOJ did not have NWBO specific in mind when they set out the rules.