The billion 45 million shares outsatnding stated on the web sites for company information could be all wrong in any direction (more or less).
The two major stockholders Serge and Mario had a long lawsuit and not sure if anyone knows the outcome of all shares involved.
Also the company has been non-reporting for so long who knows what has transpired with Treasury Stock. Even so the main termination of supply and demand to push or pull the stock has to do with the float (any-one's guess at this point}.
(Herein below may be the problem encountered by "restricted stockholders").
The major hold-up in processing your opinion request is the status of the issuing company vis-a-vis the amended rule's "shell company" status - if the company is now, or ever has been, a shell company (basically a company without assets or operations, often used in reverse mergers) the company must come into compliance and become a reporting company for 12 months before sales of both restricted and unrestricted securities may take place. This complex and confusing rule is likely to be clarified by the SEC, but at this time, good communication with the company and the transfer agent are necessary for these sales to be approved - the attorney's opinion letter must also clearly address the issue. Your transfer agent has a form addressing this issue which should be signed by the company president, notarized, and sent to us and the transfer agent to facilitate the process.
Please note - the foregoing is a simplification of the changes to Rule 144 and is general information only, not a legal opinion or legal advice. Certain persons, certain activities, such as hedging transactions, and certain scenarios may not be available. ONLY the opinion of an attorney experienced in these matters should be relied upon.