yes i agree with you on this matter as they went back to the annual report for 2017.

(In the course of preparing this opinion, counsel has reviewed the following documents relating to
the Company) (together with the date they were posted through the OTC Disclosure and News
Service, if applicable):

PUBLISH DATE TITLE PERIOD END DATE

04/02/2019 Form 1-A/A (as filed with the SEC)

03/18/2019 Quarterly Report - On4 Communications, Inc -
Disclosure Report for Quarter Ending January 31 2019

12/14/2018 Annual Report - On4 Communications Inc - 12 Months
Ended October 31,2018

09/14/2018 Quarterly Report - On4 Communications, Inc -
Quarterly Financial Report Ended July 31, 2018

06/15/2018 Semi-Annual Report - On4 Communications Inc 6
Months Ended April 30,2018

03/15/2018 Quarterly Report - On4 Communications, Inc - 3
Months Ended January 31,2018

01/31/2018 Annual Report - On4 Communications Inc - Annual
Report for 12 months ended October 31 2017

source
https://backend.otcmarkets.com/otcapi/company...51/content


so yes i do agree with you he covered it in depth in the attorney letter