BCSC Response and My ReplyI am unimpressed with the BCSC response which was very similar to Sunnyman's. The BCSC response implies that any action taken after the issuance of a Cease Trade Order becomes a civil matter. That is NOT true. They can enforce compliance and prosecute Versatile's failure to do so. They seem to want to abjugate their responsibilities. Other shareholders must also file a complaint if we are to have any hope of justice in this matter. Here is my reply: Dear Mr. Hall, Thank you for your reply. It does, however, seem to raise more questions than answers regarding the regulatory oversight of Versatile Systems Inc. (Versatile). In your response, you state, Upon review of the information, we will not be taking further action at the current time. I fail to understand how that decision could have been made based on the facts of the case. Let us look at them: 1) On Nov.1, 2016, Versatile, in a press release, stated the annual financial statements would be published Dec. 2, 2016. That did not happen, Again, in a Jan. 5, 2017 press release, the company said these financial statements would be provided within a few weeks and this, also, did not happen. As the company has made no attempt to provide any further information since then, it is clear that Versatile had mislead shareholders; 2) On Jan. 4, 2017, your agency issued a Cease Trade Order (CTO) against the company. Almost 18 months after that order, Versatile has still made no attempt to comply with disclosure requirements or correcting the misinformation identified above; 3) We also know that Versatile sold a significant portion of their operation to an American private company within this time frame. Surely, this would constitute a material change of operation and thus require communication with shareholders of the transaction. But Versatile did not tell shareholders of this event either; 4) Since the time of the issuance of the CTO, Versatile has failed to file no fewer than two annual financial statements and 9 interim statements. It should be quite evident at this point that the company has no plans of ever filing. In light of the above information, it is apparent that the CTO has had no effect to bring Versatile into compliance. In fact, it appears the CTO has enabled Versatile to more completely separate itself from shareholders for the purpose of stealing the shareholders assets. It seems apparent that the enforcement capabilities of your agency would be for the very purpose of cases like this. The same National Policy that you reference in your letter, regarding continuous disclosure states in National Policy 11-207, Part 3, Section 8, titled, Enforcement action: If a reporting issuer is in default of a continuous disclosure requirement, CSA regulators may also consider taking action against the reporting issuer, the directors and officers of the reporting issuer, or any other responsible party. Nothing in this policy should be interpreted as limiting the discretion of the CSA regulators in responding to such a default through enforcement action. (bold and italics mine). It begs the question as to what is limiting your agency from enforcing the regulation? Further, the Securities Act, Chapter 418, Part 18 Enforcement, section 155 (1) states, A person who does any of the following commits an offense: (a) fails to file, provide, deliver or send a record that (i) is required to be filed, provided, delivered or sent under this Act or (b) contravenes85 (b) A reporting issuer must, in accordance with regulations, provide disclosure of a material change. (bold mine) Clearly, multiple offences have been committed by Versatile. But what is also important here is the matter of intent. When I review your agencys prosecutions, I find a common trend. They are generally business operations that have failed, are deficient in some area of compliance to the Act that is not necessarily related to the failure, and often lost a portion of their investors money. In most cases, it appears they tried to put their best effort into the business and did not try to intentionally steal the shareholders investment from them. This cannot be said for Versatile. At this point, it should be clear that Versatile management have no intention of filing any financials or material change documentation or communicating with shareholders what is or has transpired within the company. We do know they sold a significant portion of their operation to an American private firm and there would have to be some kind of financial transaction as part of the sale. How much money was it and where did the proceeds go? Did management personally enrich themselves? Surely, these are questions for which enforcement for nondisclosure is justified. The actions may well be even criminal. What offense can be more compelling for your agency to address? Further, I notice your agency seems to pursue enforcement for rather innocuous matters. For example, your recent case against Gordon Eberwein for wash trading in a too small to even be microcap inconspicuous stock that frequently sees no trading. In the settlement, in your own admission, Mr. Eberwein did not profit from the trading and his actions had no significant impact on the shares valuation. Despite this, you hit Mr. Eberwein hard with a $15,000.00 fine and a 4 year prohibition of securities trading. Yet, in the case of Versatile where the company appears to be in the process of stealing potentially millions from its shareholders, you find no grounds to enforce the securities Act. Why? Finally, in your response you state that I should consult with a lawyer if you are pursuing your shareholder rights. If I need my own lawyer to pursue my shareholder rights, then what is the point of your agencys very existence? In conclusion, Versatile mislead shareholders in its final press releases, failed to file almost a dozen financial reports, failed to file at least one report of material change and a major one at that, has severed all communication with shareholders for a year and a half and this includes numerous inquiries from multiple shareholders via phone and e-mail, used your own agencys CTO to further separate itself from its shareholders, and in what is becoming increasingly evident, has stolen the companys assets from shareholders. Yet, somehow, your agency does not believe the case warrants any enforcement action on your part. Something is seriously amiss. Please explain. Sincerely My Name