That's a pretty unusual statement in an attorney letter, at least in my limited experience. I think I know why he put it in there and MAYBE, just MAYBE, it has something to do with why the Yield sign is still up.
This is typical language:
"This opinion letter is intended only to be relied on by OTC Markets Group in determining whether the Issuer has made adequate current information publicly available within the meaning of Rule 144(c)(2) under the Securities Act of 1933."
Rule 144(c)(2) requires an issuer to have current information available even if they are a non-reporting issuer....as PTOI has now chosen to be....in order to avail itself of the Rule 144 safe harbor.
But Rule 144 is also unavailable to an issuer that has EVER been a shell company, as defined:
(A) No or nominal operations; and
(B) Either:
(1) No or nominal assets;
(2) Assets consisting solely of cash and cash equivalents; or
(3) Assets consisting of any amount of cash and cash equivalents and nominal other assets; or
The statement you quoted suggests that due to what he calls "gaps in its reporting to the Securities and Exchange Commission" there were periods of time during which current information WAS NOT available and the Company COULD HAVE BEEN a shell company. I think the gaps he's referring to are the times when the Company went beyond the 5 and 15 day grace periods provided for in the law for 10Q and 10K filings.
So the OTCMarkets people may not be happy about the fact that his opinion that is supposed to vouch for "whether the Issuer has made adequate current information publicly available within the meaning of Rule 144(c)(2) under the Securities Act of 1933" has a disclaimer in it. I don't think that it is supposed to....it screws up the purpose of having an opinion letter.
Maybe.
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