The Working Paper
Precrime: Structural-Metadata Screening of Pre-Financial Securities Issuers on EDGAR — working paper (draft), M.P., June 2026.
Abstract. Precrime screens securities issuers from raw EDGAR structural metadata — before any analyzable financial statement exists. It runs the academic loop in reverse: rather than fitting a classifier on filed financials, it begins from the outcome — the corpus of published DOJ and SEC enforcement pleadings — and works backward to the structural fingerprints those matters left in the filing record, encoding them as weighted heuristics that then run forward over live filing feeds. Postcrime labels train precrime flags, and the enriched learning corpus is published openly. The catalog is grounded in a primary-source anchor, Exemplar 1 — an enterprise running schemes in parallel across 650+ entities and CIKs. Against a labeled corpus of 37,619 DOJ-SDNY and SEC litigation-release documents, three hand-traced cases show a mean 6.6-year lead time from first structural signal to enforcement. All quantitative figures are illustrative projections on synthetic data, not measured results.
Read the full draft inline, page by page, or open it larger — or listen to the paper read aloud: the player opens the PDF beside a word-synced narration with the floating cane head.
The Scoring Model
Each entity is scored purely from its EDGAR submission record — form types, cadence, agents, name history — no narrative input. Each heuristic that fires casts a weighted vote:
score(e) = Σh∈H wh · 𝟙[ h fires on e ] wh ∈ {2, 3}
flag(e) = 1 ⟺ nsig(e) ≥ 2 ∧ score(e) ≥ τ (τ = 3)
A lone signal is never flagged (nsig ≥ 2 required). Maximum score is 38. Tiers set review cadence: T1 ≥ 10 (daily), T2 6–9 (weekly), T3 3–5 (quarterly). On the model's validation set it fired a mean of 6.6 years before any public action; the same heuristics would have surfaced LATI as early as 1996 and Davi Skin by 2004 — years ahead of the 2007–08 dump. No enforcement has ever followed against either.
What the sixteen heuristics flag — ●●● high weight, ●● moderate:
Transformation. name-recycling ●●● flags a corporate name reused across CIKs, or repeated renames on one CIK — a shell wearing new names to outrun its history. shell-reactivation ●●● catches a dark entity that stops then resumes filing — a parked shell brought back to host a deal. reverse-merger chain ●●● is the 8-K Item 5.06 → 2.01 → 5.03 sequence, a private company taking a public listing without an IPO. SIC drift ●● fires when the industry code shifts to a business the assets do not support.
Issuance & legend removal. penny-stock S-1/S-8 ●● and Form D-only issuer ●●● flag share registrations and private placements that raise capital with little public reporting. Reg S ●● and Reg A ●● are offerings placed with foreign or small investors. promissory clauses ●● catch the convertible notes that become the debt-to-equity lever. opinion letter ●●● flags an attorney's letter of counsel — the key that removes a restrictive legend. Form 144 outlier ●● and self-filer for material capital ●● mark restricted-stock sales and material events handled in-house rather than by independent counsel.
Reporting behaviour. late-filer cluster ●● flags a run of NT (late-filing) notices; going-dark blackout ●● fires when the EDGAR record falls silent while the stock keeps trading.
Relationships & the regulator. filer-agent overlap ●●● flags one EDGAR filing agent preparing filings for multiple, ostensibly unrelated issuers; SEC staff action ●●● fires on comment letters or UPLOAD correspondence — the regulator already raised a hand.
| Heuristic | LATI · 878146 | Davi · 1059577 |
|---|---|---|
| name recycling ●●● | ✓ | ✓ |
| shell reactivation ●●● | ✓ | ✓ |
| reverse merger chain ●●● | ✓ | ✓ |
| penny stock s1 s8 ●● | ✓ | ✓ |
| late filer cluster ●● | ✓ | ✓ |
| going dark blackout ●● | ✓ | · |
| filer agent overlap ●●● | ✓ | ✓ |
| form d only issuer ●●● | · | · |
| reg s issuance ●● | · | ✓ |
| reg a offering ●● | · | · |
| sic code drift ●● | ✓ | ✓ |
| promissory clauses ●● | ✓ | ✓ |
| opinion letter ●●● | ✓ | ✓ |
| form 144 outlier ●● | · | · |
| sec staff action ●●● | · | ✓ |
| self filer for material capital ●● | · | · |
Reconstructed from the case findings — each cell marks a signal that entity's filings trip. Official structural totals: Davi Skin 28 / 38 (12 signals · Tier 1) and LATI ≥ 24 / 38 (10 signals · Tier 1).
Entity Genealogy
Lineage A · CIK 878146: Tele-Lawyer → (rename 18 Nov 1996) Dynamic Associates → (rename 15 May 2001) Legal Access Technologies (LGAL) → goes dark, last filing 30 Aug 2006.
Lineage B · CIK 1059577: MW Medical (1998) → (8-K 5.06→2.01→5.03, 24 Jun 2004) Davi Skin (DAVN, SIC 2844) → registration REVOKED 27 Aug 2012.
Common control thread: CIK 0001144030 = Kyleen E. Cane (individual), who filed the SC 13D on LATI through the same agent (0001255294) that prepared the Davi Skin / MW Medical filings — until Davi switched agents at the 2007 dump.
Case · LATI / Dynamic (878146)
Tier 1 · score ≥ 24 / 38 · ten-plus distinct signals · earliest trip 18 Nov 1996 (first rename).
Three corporate names on one CIK; two formerNames renames; a Schedule 13D by Kyleen/Michael Cane (CIK 0001144030) through the shared agent; a $140k convertible note at $0.07/sh (8-K, 10 Dec 2004); an S-8 with an EX-4 counsel opinion (5 Jul 2001). The EDGAR record goes dark in 2006 while LGAL continued OTC trading through 2010 — 61 volume dislocations, 0 contemporaneous control events to bind to: the going-dark + shell-reactivation fingerprint.
Case · Davi Skin (1059577)
Tier 1 · score 28 / 38 · twelve distinct signals · earliest trip 24 Jun 2004 (reverse merger / name change).
The textbook 8-K Items 5.06→2.01→5.03 reverse-merger sequence; a SIC pivot from medical devices to cosmetics (2844); the filer-agent overlap with LATI and the Cane 13Ds; a late-filer cluster (NT 10-Q ×23, NT 10-K ×10); a Reg S issuance to four foreign investors that drew SEC comment letters and an eventual REVOKED status; an S-8 + EX-5.1 opinion of counsel; and Wallace's $570,775.30 convertible note. In the Jan–Nov 2008 window the price/volume model flagged 11 dislocations, 1 confirmed.
Related CIKs & the Accessions That Flag
| CIK | Entity |
|---|---|
| CIK 878146 | Tele-Lawyer → Dynamic Associates → Legal Access Technologies (LGAL) |
| CIK 1059577 | MW Medical → Davi Skin (DAVN) |
| CIK 1144030 | Kyleen E. Cane (individual filer; SC 13D on LATI) |
| CIK 1100131 | Sedona Software Solutions |
| CIK 1103993 | Las Vegas Gaming, Inc. (LVGI) |
| CIK 13156 | Secured Diversified Investment → Galaxy Gaming |
Read in sequence, a handful of accessions map the whole scheme — each one a flag in its own right:
The Davi Skin name change opens with an 8-K (Acc. 0001255294-04-000201, 24 Jun 2004) carrying the EX-2.1 merger agreement and the textbook Items 5.06 → 2.01 → 5.03 sequence — the reverse-merger fingerprint. Weeks later an SC 14F1 (0001255294-04-000214, 20 Jul 2004) changes control without a shareholder vote and books Wallace's $570,775.30 convertible note. An S-8 with an EX-5.1 opinion of counsel (0001255294-04-000267, 15 Sep 2004) is the legend-removal mechanism — the attorney certifying that her own restricted shares may trade.
A 10-QSB Reg S (0001255294-05-000310, 23 May 2005) issues units to four foreign investors; the regulator notices, and a SEC staff comment letter (0000000000-05-042920, Aug 2005) challenges it. An SB-2 resale registration (0001255294-06-000321, 12 May 2006) lines insider shares up for public resale. Then the tell: the FY2006 10-KSB (0001117768-07-000030, 2007) is filed by a new agent — the filing-agent switch that coincides with the dump.
On the LATI side the same shape recurs: an S-8 + EX-4 opinion (0001075793-01-500109, 5 Jul 2001) and a $140k convertible-note 8-K (0001255294-04-000348, 10 Dec 2004).