So if the 504 exemption was improperly applied, do the related MIKP shares that were issued under the filing become null and void?
Unfortunately there is no way that could possibly be done. The illegal MIKP shares are already in the public float and can't be tracked and transactions unwound. The shares Fairhills Capital dumped can't be rescinded.
Keep in mind that the scheme didn't work without the cooperation of the corporate officer(s) who filed the bogus Form Ds falsely claiming that they complied with the requirements of a specific 504 exemption and the attorneys who wrote the bogus opinion letters provided to the TAs telling them they could legally remove the restrictive legends.