seems to be. Darrell and his team decided it was either something like this, where they can still go after Select and the bad actors, and be trading, OR stay halted. Discussion with the market makers they planned to file the form 211 with said they'd be happy to do it, but that nasdaq compliance lawyers wouldn't approve with the outstanding share imbalance.
so, it was either buckle down for a long drawn out battle like BCIT has been doing, or get the shareholders in a trading vehicle, where they can still sue the bogus share printers.