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stervc

03/08/08 5:36 PM

#4108 RE: rca #4098

Rca, with your thoughts in response…

I really do appreciate your dialogue on this issue. I also really do understand what you are saying. I am saying that a 15c211 is already on file for the company even if it has been grandfathered or we would have been on the greys a long time ago from my understanding from speaking with the FINRA OTC Compliance Unit at 240-386-5100. I will call them on Monday to get clarity as it might be me thinking up there on Mars again (LOL).

The term “grandfathered” simply means that an exception has been granted to allow something of an old rule or existence to continue to apply to current and/or future situations. So to me, it means that the old tickers registration’s were grandfather (or carry-overed) each time the ticker changed up even until now to the ticker ADCS.

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http://reversemerger.dealflowmedia.com/rm_glossary.cfm
grandfathered shells. Shell companies and blank checks which were formed and taken public prior to the passage of Rule 419 were permitted to continue to exist without the restrictions of Rule 419. …
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For this situation, the way I see it, it means that the regulatory authorities are acknowledging the allowed old registration to exist, but the pinksheets.com is not, or again, we would have already been on the grey sheets. The SEC acknowledges their registration as it rolled over its registration with the changing of their tickers from one registration to the next as one, but under different tickers. To protect investors, it looks like pinksheets.com has simply enforced something above and beyond what is recognized by the SEC and other regulatory authorities.

I say this because of what I can recall from my discussion with the FINRA OTC Compliance Unit on another stock. There is more than one registration with the SEC too. I know we at least have registered to be fully reporting where regular filings of financials are required and on a lower level, registered to trade in the market where routine financials are not required and usually authenticated from the company filing a Form 15-12G to terminate their registration I previously mentioned.

Here with this situation, I do not doubt what you are saying that they might need to file another 15c211, but it would be for pinksheets.com acknowledgement and not because of a need to do so by an officially regulatory authority for acknowledgement of being registered.

I am saying it might be a matter of simply educating/explaining to someone at pinksheets.com to let them know that ADCS's registration was “grandfathered” under one of their old tickers so that they can research such under that old ticker within their databases and see that there is a 15c211 on file that suffices for the regulatory authorities. Still, as I mentioned above, pinksheets might just be requiring another 15c211 because of the company’s past/history of changing tickers so much for their own personal acknowledgement too of the new management actually existing.

Rca, I am still very new to ADCS and simply like the news and the potential that I think exists that have not been talked about. With its completely new management, ADCS might be granted a pardon from pinksheets.com after explaining and proving to them their legitimacy. I will call FINRA and if I stand corrected, then so be it, but I think this will get eventually fixed one way or the other.

v/r
Sterling