It's worse than that. On the 2nd filing, Amarex actually removed material from the correct place on the form, and put it in an incorrect place. They didn't do anything that the FDA had asked for -- for 2 years.

And as far as not blaming Kazempour, because Nader supposedly asked him to file it whether it was ready or not --
Last time I checked, Kazempour was an adult, running a corporation, and I find it extremely doubtful that Nader broke into his office, held a gun to his head, and insisted that he hit the "send" button to submit the filing.