"Respondent has engaged Castle Placement, a FINRA member, SEC registered firm, acting as placement agent, to conduct a Rule 506(c) offering for Respondent and after a several month due diligence period with the placement agent"
Castle started their due diligence several months ago?
And it resulted in their believing that they could raise $45million on behalf of this Expert Market Company?
What type of instrument will they be offering? Even at today's lofty price of $.0015 they would have to move 30,000,000,000 (30 billion) shares of common to raise $45 million.
Can RSPI legally conduct an offering when the Company is out of compliance.....the latest financial statements being 2 years old (and unaudited)?
"I wonder if the SEC even will publish those exhibits? Not that they matter much anyways... "
Of course they matter. The language of the letter and the answer....the exhibits.....in my opinion are likely to show that Margolis' disagreement is based on his misundrstanding of the SEC letter.
The original Order Instituting Proceedings said this (highlights mine):
"As discussed in more detail above, the Respondent is delinquent in its periodic
filings with the Commission, has repeatedly failed to meet its obligation to file timely periodic
reports, and failed to heed a delinquency letter sent to it by the Division of Corporation Finance
requesting compliance with its periodic filing obligations or, through its failure to maintain a
valid address on file with the Commission as required by Commission rules, did not receive such
letter."
The RSPI answer says this:
"However, Respondent DISAGREES that it has failed to heed a delinquency letter (“Letter”) sent to Respondent by the
Division of Corporation Finance requesting compliance."
The SEC letter requested COMPLIANCE. Any response short of actual "compliance with its periodic filing obligations", which the Company obviously didn't provide, did not serve to heed the delinquency letter.
You see, that is what the SEC requires. The SEC didn't send that letter in order to engage with the level of chitchat that seems to satisfy many of the members of this board. The law requires the filings. Once that demand was formalized the SEC had nothing else to say.
Let's see if they bother with a hearing.