I really and truly hope you're, right, MPOE.
But I would give 4-to-1 odds that the US justice system will disagree, and my advice to anybody thinking of raising funds via an unregulated IPO would be "don't do it unless you want to do it as a protest against our broken system and are willing to face the likely consequences."
I'll cheer you from the sidelines, but I'm either not stupid enough or not brave enough to go up against the SEC.