Sorry, let me clarify what I meant.
I was referring specifically to the interpretation of the "distribution" in which KATX was correct. The SEC, after all the hubub, acknowledged that it was not an offering...something that the lawyers felt was fairly obvious. They even cited the case law back to the SEC! I have to do this quite often to inspectors who try to tell me I have a deficiency. I quote the regulation or law, and they say, "oh, uh, yes, well, I guess you're right, but still..." I even had one inspector try to go toe-to-toe with me, until I pulled out an email from his boss (the chief inspector for the state), where I specifically got clarification on the law a full year prior!! The inspector was speechless, yet still insisted he was STILL correct. I told them, "fine write up the deficiency, and in my response letter, I'll attach the letter from your boss, so your boss will see you contradicted him when he signs off on the final review." That shut him up. Point is, it doesn't matter how right you are, they WILL find something to nit pick.
I do agree that the SEC wanted them to change the wording on some things and clarify others for the reader. As I said, this in not unusual. These guys will almost always find something to gig you on. They see it as "justifying their existence" or "job security." I've even had inspectors write up a "deficiency" for a typo where two letters were transposed!
For the record, I'm glad the SEC did ask them to clarify some things, such as what exactly did Kat Gold Holdings get 100% of with regard to Handcamp...the answer was the "mineral rights."
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