I'll admit that I'm not an expert on SPACs. I've yet to find a SPAC that was originally on the OTC or was downgraded from Nasdaq to OTC. The SPACs that I've found that failed to meet their BCA in the stated timeline have requested timeline extensions from their shareholders. This is one of the reasons for the GLD case against SAGA. The SPAC couldn't legally create shares out of thin air that gave majority voting rights to those that voted in their favor. I would like to see the passage that Brad found so that I can get a better understanding of where you are coming from.
Form 25 is also used when a company is delisted from Nasdaq, but then goes on to be listed on an OTC tier. There are many companies that have filed this because of failure to maintain minimum share price requirements of Nasdaq that have went on to be listed on an OTC tier. I don't believe that SAGA can do this, but as I have stated Harry is doing whatever he wants at this time. To me Form 25 is not a death sentence for a company. SAGA was not a company. For a SPAC I believe it is the death certificate. SAGA is dead and should be buried. Harry is pulling a "Weekend At Bernie's" while the GLD lawsuit is going on.
I apologize. I misspoke earlier when I stated that none of the CCC team were part of the Sakayan vs Zabilov case. It has been a while since I looked at it, and apparently Charles is involved with this case.