I just submitted this to the SEC for

I just submitted this to the SEC for review.
https://www.sec.gov/oiea/QuestionsAndComments.html


I am an investor in Generex Biotechnology GNBT. They recently paid out 2 dividends: 1 was 2 shares of GNBT for every 5 shares of GNBT held and the other was 2 shares of Antigen Express (private owned spinoff) for every 5 shares of GNBT owned. The company has issued many public releases and conference calls that stated the record date 2/17/2020, payable date 2/24/2020 and ex date 2/25/2020. This is a larger than 25% dividend, so record/pay/ex dates are different. The company has stated that anyone that owned GNBT on the record date would get their dividends from the company directly. Anyone that buys between the record date and payable date would get their dividends thru the due bill process (from the seller of the shares). Please see the links below to the various disclosures of pending dividend by the company. The company stated on 2/7/2020 that FINRA has approved their dividends with the dates above. However FINRA never listed the actual dividend/split in their daily report until the morning of Monday 2/24/2020. So there was no way for an investor to read the fine print of the 2 pending dividends.

On Tuesday 2/25/2020 (ex date) the dividends are being paid and sorted by the brokerage firms.

On Wednesday 2/26/2020, it was noted by many investors that the private company spin off (Antigen Express) which is 2 shares for every 5 shares of GNBT, were not being paid correctly. Anyone that purchased GNBT shares on 2/13/2020 or after, were not getting the Antigen Express shares. According to all PRs and conf calls by the company, the 2 dividends were mentioned to have the same record/pay/ex dates, therefore all purchases of GNBT thru 2/20/2020 (trade date plus 2 for clearing on 2/24/2020) should have rec'd the Antigen Express dividends thru the due bill process. The company released a news PR Generex Issues Clarification on Stock Dividends https://storage.googleapis.com/wzukusers/user...6_2020.pdf

I have reached out to the CEO Joseph Moscato about no receiving Antigen Express dividend shares for the GNBT stock I purchased on 2/20/2020. I am being told that it never had an ex date and I am not entitled to the shares. I pointed to all the PRs and Conf Calls that the company has released lumping the 2 dividends together. I am told that it was never that way and I should learn how to trade and purchase stock. It is my opinion that the company should have detailed out both dividends with record/pay/ex dates so that it was clear, however they did not.

I have email backup of my conversation with the CEO.

I feel I am entitled to the Antigen Express dividends that would have be given on my 2/20/2020 purchase of 13,500 shares of GNBT, which would have generated 5,400 shares of Antigen Express.

Please provide me with any clarification you have. Thank you.

Generex Declares NEW Dividend RECORD DATE: Monday, February 17,2020
With the new February 17th record date being established, those who are
entitled to receive the 5/2 stock dividend in Generex and the 5/2 stock dividend in
NuGenerex Immuno-Oncology will receive it directly from the company.
In addition, the pay date is now February 24th and ex-date is February 25th. If a
shareholder sells the stock after the record date the pay due bill process will be in full
effect and the shareholder will be required to transfer the dividend stock to the buyer.
The ex-date rule in this situation is found in FINRA Rules Section 11140 (b)(2), which reads
as follows: “(2) In respect to cash dividends or distributions, stock dividends and/or splits,
and the distribution of warrants, which are 25% or greater of the value of the subject
security, the ex-dividend date shall be the first business day following the payable date.”
https://storage.googleapis.com/wzukusers/user...7_2020.pdf

Generex Announces Corporate Update and Investor Conference Call 2/13/2020
I will update our shareholders on our ongoing activities such as
Generex Investor Call Feb. 13, 2020
Generex dividends, which the record date is Monday, February 17. The pay day
is February 24. The X day is February 25.
As a reminder, the dividend formula is five for two. It is five shares of Generex
owned for two new shares of Generex paid by the company. For every five
shares of Generex you own, you will receive two new shares in NuGenerex
immune-oncology (Antigen Express).
https://storage.googleapis.com/wzukusers/user...3_2020.pdf

Generex Congratulates their Shareholders as FINRA has Officially Posted the Approval of the Generex Corporate Action Monday 2/24/20202 (Which is the Payable Date!)
- Dividends officially to be paid on Monday, February 24, 2020
o Shareholders to receive 2 to 5 stock dividend of Generex Biotechnology shares plus an
additional 2 to 5 stock dividend of NuGenerex Immuno-Oncology shares
- Ex-Date will be February 25, 2020
MIRAMAR, FL, February 24, 2020/ -- Generex Biotechnology Corporation (www.generex.com) (OTCQB:GNBT)
(“Generex”) today announced that FINRA has officially posted the Generex 2:5 stock dividends in Generex and
NuGenerex Immuno-Oncology to the FINRA web site, and the dividends will be paid on Monday, February 24,
2020. Remember that anyone who sells their shares before the market close on the ex-date of February 25th
will lose the dividend, which will be transferred to the buyer of your shares.
https://storage.googleapis.com/wzukusers/user...4_2020.pdf

Generex Issues Clarification on Stock Dividends 2/26/2020
- Dividends officially paid on Monday, February 24, 2020
o Ex-Dividend Date does not apply to NuGenerex Immuno-Oncology shares (NEW information. After the fact)
MIRAMAR, FL, February 26, 2020/ -- Generex Biotechnology Corporation (www.generex.com)
(OTCQB:GNBT) (“Generex”) today clarified certain information regarding its stock dividends
consisting of two shares of Generex stock for every five shares held, and two shares of NuGenerex
Immuno-Oncology for every five shares of Generex.
These are two separate dividends. Information in our previous press release discussing the exdividend date and ramifications of the ex-dividend date apply only to the dividend of Generex
shares. There is no Ex-Dividend Date for the NuGenerex Immuno-Oncology shares because those
shares do not trade. The payment date for the NuGenerex Immuno-Oncology shares was
February 24, and the market effective date is today.
Joe Moscato, President & CEO of Generex,said, “I understand there have been several questions
from brokers and shareholders on this issue, and hope this clarifies it for everyone.
https://storage.googleapis.com/wzukusers/user...6_2020.pdf