To file a effective complaint - you have to file facts where you provide proof - no hyperbole.
I think it would be best to use the past press releases. Go back several years and include the Hardge Black Box and everything that Michery stated supporting the black box. I would include the fraud charges against Hardge.
I am not certain Michery gifting himself stock would be securities fraud.
Stick with Michery providing false and misleading information to entice investors to buy.
Here is a top - don't file through the complaint portal. Send the report to the SEC Los Angeles regional office - email it to the Director of the office. Do this because the Mullen headquarters because the Mullen office is located in SoCal.
It is a great deal of work to put the report together but it is very important to do the heavy lifting for the SEC.
There is nothing to sue, there is a buy back and no dilution, this reward program exists in every company, for raising money? Everything is legal. Those who call buy back dilution should be sued.