Actually, the fact that Felder even filed a 144 doesn't make sense to me, but that is probably due to my limited understanding of a 144. A 144 creates a safe harbor preventing a seller from being deemed an underwriter, when they sell securities received directly from the issuer. However, 144 is of no effect unless adequate information has been publicly disclosed. In the case of reporting companies, one can rely on the company's current filings as meeting this requirement. Here, that isn't the case.
I realy don't see what Felder accomplished by filing the 144, except NNLX' transfer agent may have required it to be filed. The thing is I believe transfer agents also require an opinion of counsel to the effect that the conditions of 144, including full disclosure, have been met. IMO, the disclosure requirement has not been met as the public has not been provided with any kind of an accounting.
Regardless of whether or not Felder complied with 144, the buyer may rely on the statement. Whatefer that means. I wonder if the transfer agent is balking at transfering the shares previously sold?