There's really no need to dig deep into the SEC's interpretation when the CEO gave the reason in this blog post. Pretty transparent to most here.
QUESTION:
(Paraphrased from several): What was the reason for posting the building picture from your recent trip? ANSWER:
I was able to combine business meetings on my most recent trip for efficiency. One of the meetings was with a former 504 subscriber, with whom we have not carried out any new 504 subscriptions for a number of months. I appreciate Winning Brands’ accredited investors retaining their holdings as long as they can to demonstrate legitimate investment intent; this is such a party. In consideration of their patient and responsible attitude toward the company, a courtesy call was appropriate. CEO’s often participate in presentations to accredited investors, or in such a case, a visit to update due diligence mutually and to reconfirm, mutually, that any remaining interests are handled responsibly.
As to the photo itself, I often share a photo of our vehicles in their travels.