ST,

I wanted to offer some comment on two points you made in your post.

(1) I have been struggling with the hold-up on the Pellegrino 2 report as well.

However, I am thinking the reason for the "delay" might actually be planned / strategic in nature.

So, perhaps management are waiting to get the NAS confirmation and then they will unleash the P2 report; either a dual announcement or 2 announcements very close together.

Strictly speaking, companies, including POET, are NOT allowed to withhold announcements so they can time them better with other market catalysts such as a NASDAQ listing. Typically, the language used with respect to material information is that once the company comes into possession of material information, disclosure must happen immediately or forthwith. We know that the Pellegrino 2 report is material information. Why? Because it absolutely fits the definition, per Section 3.8 of the TSX Venture Exchange Policy 3.3 on timely disclosure:

(y) any other developments relating to the business and affairs of the Issuer that would reasonably be expected to significantly affect the market price or value of any of the Issuer’s securities or that would reasonably be expected to have a significant influence on a reasonable investor’s investment decisions.

Companies are allowed to keep some material information temporarily confidential if immediate release of the information would be unduly detrimental to the interests of the issuer. In this case, the company would have to make a solid case to the Exchange that releasing the report immediately would be detrimental to the interests of the company and investors, and that this detriment would be reasonably considered as outweighing the undesirable consequences of not releasing the information. Wanting to time a news release with another major event would not meet these requirements (see Section 11 of the link I provided above). Basically it is always desirable to give the market and investors as much information as possible; the more often things are kept confidential, and the longer they are kept confidential, the higher the chance that all or part of the material information will begin to leak, which would give certain parties privy to the information an unfair advantage. Companies are therefore expected to provide strong reasons for keeping information confidential, and keep it confidential for as little time as reasonably practicable.

In the case of Pellegrino 2, it is reasonable to assume that this report would contain a great deal of very sensitive information related to the company's strategic interests, future business verticals, valuable IP information, and possibly even information related to technology or techniques for which patent protection has yet to be successfully acquired or applied for. Therefore, it makes sense that while company management would want to see the full report, the report that they want to release publicly would need to be redacted to protect the interests of the company and the shareholders from competitors. I suspect (this is speculation on my part) that the delay in releasing the report, which we had been led to believe would have been ready by the end of May per POET's January 20th New Release, is related to this redacting process. Now, for all we know, Pellegrino could be running way behind schedule ... it's a possibility. More likely though, in my opinion, is that given we know the report is currently in Pellegrino's hands (per the post made a week ago Friday by Iamsorry on the board based on his conversation with CC), and given the expected timeline was completion at the end of May ... POET may have already been in possession of the report, redacted the sections they felt would endanger the company from a competition standpoint, and now the report is back in the hands of Pellegrino so they can make the appropriate changes to issue a revised, redacted form suitable for distribution to the public. Making these changes would alleviate the concerns of the company with respect to confidentiality, and therefore once the revised report is ready, the expectation of the Exchange and IIROC would be that the material is released immediately. While I realize all of this is speculation on my part, in my opinion I feel it is a much more realistic scenario than the company being able to convicne the Exchange to let them hold off releasing the P2 report until Q4 2014 (which is when I would expect a NASDAQ listing to occur). Perhaps they found a reason to justify holding off that long (with the secret intention of wanting to time the release) but personally I don't think it's likely and I don't think the Exchange would allow it.

Okay, sorry for the novel. Halfway point .... my second comment relates to NASDAQ qualifications:

(2)

As a non-revenue generating company, the qualifying SP is 4$ US.

Myself along with many others on this BB preiously thought the qualifying price was $2 US, but my understanding has been corrected .... I am told $4 by friends I know in Bay Street.

The previous understanding of this board and yourself is actually very much correct ... you absolutely can list on the NASDAQ with a $2.00 share price. What is potentially happening with your friends on Bay St. is they are probably mixing up the Global Market tier with the Capital Market tier that the board has generally been referring to. I hope this doesn't cause more confusion but I felt it was important that everyone understood the proper requirements and there is no perception of misinformation.

There are three tiers on the NASDAQ exchange: the Global Select Market, Global Market, and Capital Market. Those are ranked in order of decreasing difficulty of listing requirements, with the Capital Market being the easiest tier to list on. All along, this is the tier I assumed POET would aim for first, for reasons which I will explain shortly.

Not long ago, the NASDAQ reduced the listing requirements of its lowest tier, the Capital Market, so it could be more competitive with the NYSE's AMEX, which was the first to lower its listing standard share price to make it easier for smaller companies to list. Whereas it used to require a $4.00 share price, companies can now list with a price as low as $2.00 / $3.00 on the NASDAQ Capital Market. For some background reading on this, see the following link.

In order to qualify for the alternative closing price requirement of $2.00 / $3.00 instead of bid price requirement of $4.00, a company must meet certain standards regarding net tangible assets and operating history. POET meets these requirements, and thus is eligible to list on the NASDAQ using the closing price alternative with a share price as low as $2.00. Because POET meets both the Market Value and Equity Standards for the Capital Market tier, they need only meet the share price requirement for 5 consecutive business days before applying (with the application process taking approximately 4 - 6 weeks thereafter).

Now, if POET were to instead aim to list on the NASDAQ Global Market tier, it is a different story altogether. First, there is no $2.00 / $3.00 closing price alternative like there is on the Capital Market tier. You MUST meet the $4.00 bid price requirement (I think this is probably what your Bay St. friends might have been thinking of?). Furthermore, POET would only meet the requirements of one of the four standards on the Global Market tier: the Market Value Standard (contrast this with the Capital Market tier where POET meets 2 out of the 3 standards). The main requirement for the Market Value standard is that the company must have a market value of $75M or higher ... no problem ... POET is well above that. HOWEVER, there is a special rule if you try to list on a tier and only meet the Market Value standard. That rule states that before you can even apply to list on the exchange, your share price and market value must have been above the minimum levels ($4.00 bid price and $75M market cap) for 90 consecutive trading days. That's four months of trading ... and then you still have to submit your application, so add another 4 - 6 weeks on top of that; and if you have a bad week somewhere in the middle, where the price drops below the $4.00 bid price, then you're starting all over again ... yikes.

Because of the length involved with that process, I have assumed all along and still believe that POET will aim to list on the Capital Market tier first, and then at some future point, apply to uplist to the higher Global Market tier. At least that gets the company NASDAQ listed and more exposure to U.S. money and analysts relative to our current situation. Further opportunities for institutional investment, analyst coverage and prestige would likely come with a subsequent move to the Global Market tier, down the road.

Anyway, I just wanted to clear up the share price issue. The company may want the price trading above $4.00 no matter what, even if they intend on applying to the Capital Market tier first, simply so they can start the clock counting for the 90 consecutive trading days which would allow them to eventually move up to the Global Market tier. But definitely the company is able, if they choose, to list on the Capital Market tier with a price less than $4.00.

BUMBLEBEE