I forget the details on the limitation but it goes something like shares from the PIPE can't be used to cover and you can't do any short within 5 days or so of the draw.
5 days before a draw is a ridiculously short period of time and you can short against the box or short sell against shares given as a signing bonus or discount which technically isn't shorting at all.
In other words if the company gives you an intial 5 million shares you sell those to fund the draws and then the PIPE shares replenish the 5 million shares you sold. Fusion used to do that.
It's silly how ridiculously easy they make it for these scams to circumvent the intent of the rules
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