Yes, because the Transfer Agent is required by law to gain custody of the certs and then destroy them. Only a Transfer Agent can perform this function, and worse yet it would still require a letter from legal counsel directing them to do so, yet THRA had neither at the time of the Press Release.
No TA since September 8th, she was well aware of this as the TA put an Email to all of it's clients informing them of each action the SEC was taking against them.
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