Subject: verbiage - Rule 12b-2 of the Exchange Act
From: Raymond Kenneth Petry, CEO
Affiliation:

Mar. 30, 2019

Other writers re the definition of Emerging Growth Company suggest that this category is for a type of startup since 2011;
But your (original) verbiage reads that just-about-any small filer qualifies now as an Emerging Growth Company,
But then you subordinate your previous clause, to specify a sundown for those who've completed an IPO:
But, We didn't sell any securities at all, nor completed an IPO;—

"A company qualifies as an emerging growth company if it has total annual gross revenues of less than $1.07 billion during its most recently completed fiscal year and, as of December 8, 2011, had not sold common equity securities under a registration statement. A company continues to be an emerging growth company for the first five fiscal years after it completes an IPO, unless one of the following occurs:"



Cordially, sincerely, Mr. Raymond Kenneth Petry, President CEO Lanthus Corporation (USA), and divisions Surrogate Executive Accession Management