OTC's definition of a shell is rather nebulous. However, there are several things working against DRYW in their effort to get the shell warning removed. First is that they have no employees. Second, they have no revenue. Third, they have no business office. (Their HQ is a private residence.)
But their is no proof the 25 millions shares traded hands. Outstanding shares hasn’t changed in over a year. If it has happened, (they said it did), I can’t find it.