The people who run these P&D's aren't total dopes. They know just how much real appearing business activity to engage in to appear legit while they dump millions of their zero based shares.
Very hard to prove criminal intent. This one was very obvious from the start. Share price over $1.50 before they had anything going AT ALL other than heavy email campaign by paid pump services. Vague announcements of implied future success and zilch in company assets. 100% of the time that is a P&D. I called this one a year ago. It has been a text book example.
I really hope the people who got ripped off get some relief but the odds are heavily against it.