Yes, I saw the table previously, but I read that our ID can only fall under Item 1 of the table.

IMO, I read that as 60 days for Initial Determinations that are "concerning" a violation, which this one was. I understand that they found no violation in their ID, but the ID WAS concerning a violation. It says so right in the ID itself. Also, if you read the cited paragraphs in the body of the text, they cite ID's that have to do with determining whether a violation occurred or not.

They differentiate IDc concerning a violation from IDs that occur earlier in the process as a matter of summary judgement. The latter are the ones that cite the 45 days.

Maybe I'm reading/interpreting that incorrectly, but I'm not convinced by your comments. Don't take that the wrong way though. I thanks for reviewing and providing your opinion. As I said time will tell. Based on your review and PTSC's 10q, it's 2 against 1, so hopefully the majority is correct and we get an answer sooner than later.