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balihi

02/12/11 10:03 AM

#131915 RE: Biochemist2002 #131909

Whether it was an offering or distribution,KATX did not submit the proper or complete filings.Here is the problem I am having with that....We have this securities law firm,and not just any law firm,there management is very experienced in securities law(check their resum'es)yet KATX couldnt or didnt know the proper proceedures???
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BigOwl47

02/12/11 12:27 PM

#131966 RE: Biochemist2002 #131909

Biochemist, That was an excellent explanation of what occurred between SEC and KATX regarding the BVIG Share Distribution by KATX. The confusion was over the SEC thinking the KATX actions were an "Offering" instead of a "Distribution". It does take a lot of time to answer all the questions asked by a governmental agency because they have the power to hold up anything a company is trying to do until they (the governmental agency) understands. Even when the governmental agency is wrong on the subject. Keep in mind that it is impossible for even a SEC savy Law Firm to anticipate the unpredictable actions of a governmental agency when it is asking questions that are off base. KATX and the legal team was progressing along the proper legal path when the SEC started asking questions that held up the process for months. No one could predict such an intervention by a governmental agency that thinks it should be involved but ultimately determines that they are not involved. Nearly three months of time were wasted answering the SEC questions.

The interpretation that KATX did nothing until the 10-6-2010 SEC asked about info on the KATX website is wrong. I have been following the BVIG Share Distribution from the beginning thru contact with the Transfer Agent and the other agencies involved and the assertion that the BVIG Share Distribution was only begun by KATX after the 10-6-2010 letter from the SEC is simply not correct. The initial electronic application and the subsequent manual applications were well under way long before the 10-6-2010 SEC letter.

The 12-27-2010 letter shows that the SEC questions were answered by KATX to the SEC's satisfaction and we are now awaiting whatever the next step in the process will be.