Operation Arms Length · Parallel Investigation

The Canadian build: PrivateCo to LTH

"Lithium Ionic" is three distinct Ontario corporations. This page traces the founder-share vehicle, the capital-pool shell and the merger sub into the listed issuer, the registry record of who directed them, the founder-share economics, and where the value went.
SEDAR+ · Ontario registry v4 · 2026-08-11
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This is a private, independent, open-source investigation. It is not affiliated with, authorised by, or endorsed by Lithium Ionic Corp. (LTH), Emerita Resources Corp. (EMO), or PM Super Fund. It is compiled from public records for information only. Presumption of innocence: every named individual and entity is presumed innocent; the OSC application and both court proceedings are unproven and untested. Nothing here is legal, financial, or investment advice.
SEDAR · OBR

Corporate genealogy: three "Lithium Ionic" entities, one asset

"Lithium Ionic" is three distinct Ontario corporations, not one. Conflating them produces tracing errors. The diagram shows how a private founder-share vehicle, a shell capital-pool company, and a single-purpose subsidiary combined in a three-cornered amalgamation to put the asset under a public ticker.

BEFORE · THREE SEPARATE CORPORATIONS POCML 6 Inc. Capital-pool co. · POCC.P · OCN 2802172 Shell sponsored by PowerOne Capital Markets (D'Onofrio · DiCapo · Parsons) → becomes the public parent (B) Lithium Ionic Inc. (PrivateCo) OCN 2851751 · inc. 5 Jul 2021 as "LI-Ionic Inc." renamed 17 Nov 2021 · OSC "LI PrivateCo" Incorporated by Lopez; Gower & Guy directors same day. Issued 31.1M founder shares; bought 99.9% of MGLIT (BRL 999). 1000088600 Ontario Inc. "POCML Subco" · OCN 1000088600 · inc. 20 Jan 2022 Single-purpose merger sub; sole director David D'Onofrio (PowerOne CFO / POCML sponsor). Contributed only the merger mechanics, confirmed via OBR 2026-06-22 Three-cornered amalgamation · 19 May 2022 (OBCA s. 174) Reverse takeover · POCML 6 renamed "Lithium Ionic Corp." · trades as LTH from 24 May 2022 AFTER · PRESENT OWNERSHIP CHAIN (asset at the bottom) Lithium Ionic Corp. · TSXV: LTH (B) public parent · former POCML 6 Inc. · OCN 2802172 100% Lithium Ionic Holdings Corp. (C) = "Amalco" · OCN 1000208066 Lithium Ionic Inc. (A) + 1000088600 Ontario Inc., amalgamated 19 May 2022 Gower & Guy ceased 20 Apr 2026 (registered 8 Jul 2026) · Hylands sole director 100% MGLIT Empreendimentos Ltda. (Brazil) holds the former Falcon claims: Itinga / "Bandeira" Asset-tracing line (A → C): PrivateCo (OCN 2851751) + 1000088600 amalgamate (19 May 2022) → Amalco, a new corporation number (OCN 1000208066). Per OBR (2026-06-22): an amalgamated continuation, not a mere rename. The parent (B) is the former capital pool.
Tracing consequence. The entity that paid the consideration (the PrivateCo, OCN 2851751, about CAD 3.11 for the founder shares and ~CAD 227 for MGLIT) continues, through the 19 May 2022 amalgamation with the merger sub, into Lithium Ionic Holdings Corp. (Amalco, OCN 1000208066), now registered in Brazil as MGLIT's 99.9% quotaholder. The Ontario registry treats Amalco as a new corporation number, an amalgamated continuation rather than a mere rename. The public parent (LTH, OCN 2802172) is the former capital-pool shell above it. A tracing claim runs through the PrivateCo / Holdings line for asset-level steps and through LTH for issuer-level steps. Sources: OSC AEP ¶¶22 to 26; POCML 6 Filing Statement 2022-05-12; certified Ontario Business Registry profile reports and articles of amalgamation (retrieved 2026-06-22).
Ontario registry

Common control

Certified Ontario Business Registry records show the same individuals directing the vehicles on both sides of the purportedly arm's-length transaction, and the asset-holding subsidiary registered at Emerita's own head office. The registry position on that subsidiary's board changed in July 2026 and is set out below.

Entity (role)OCNStatusWho incorporated / directs it
Lithium Ionic Inc., PrivateCo / founder-share vehicle2851751Inactive, amalgamated into 1000208066Incorporated by Damian Lopez as sole first director (his Toronto residence), one day before the founder-share issuance; Gower & Guy joined as directors the same day; all three are OSC respondents
1000088600 Ontario Inc., "POCML Subco"1000088600Inactive, amalgamated into 1000208066Incorporated 20 Jan 2022 by Chris Irwin; sole director / President / Secretary David D'Onofrio (CFO of PowerOne, the POCML 6 sponsor; later joined the LTH board 3 Sep 2024). Single-purpose merger sub
Lithium Ionic Holdings Corp., "Amalco"; holds MGLIT → Bandeira1000208066Active, wholly owned by LTHGower & Guy were directors at formation on 19 May 2022 and ceased on 20 Apr 2026, the same day they left the EMO and LTH boards; Blake Hylands, the LTH parent's CEO, was elected sole director that day. The cessation reached the register by a Notice of Change effective 8 Jul 2026. Certified as at 8 Aug 2026: Hylands sole director, Thomas Olesinski sole officer
Lithium Ionic Corp., public parent (TSXV: LTH)2802172Active; formerly POCML 6 Inc.Resulting issuer of the 19 May 2022 RTO; trades as LTH
Emerita Resources Corp., the OSC-named issuer1981913ActiveContinued BC → Ontario 2017-09-12
A shared registered office in Toronto. The registry records Lithium Ionic Corp., Lithium Ionic Holdings Corp. and Emerita Resources Corp. at the same registered office: 36 Lombard Street, 4th Floor, Toronto (Emerita's head office). The Amalgamation Agreement (7 Feb 2022) was signed by D'Onofrio for POCML 6 and the Subco and by Lopez for the PrivateCo, defines "Brazil Subco" as MGLIT, and represents that the PrivateCo owned "999 quotas" (99.9%) of MGLIT holding the Itinga / Bandeira rights, an Ontario-side acknowledgment, in February 2022, of the asset chain. Sources: certified Ontario Business Registry profile reports and the executed Amalgamation Agreement (2022-02-07), retrieved 2026-06-22; POCML 6 Filing Statement 2022-05-12; OSC AEP ¶¶23, 25, 26.
The subsidiary’s board, and a register that was not kept current. A certified Notice of Change effective 8 July 2026 records that Gower and Guy ceased as directors of Lithium Ionic Holdings Corp. on 20 April 2026, the same day they left the EMO and LTH boards, with Blake Hylands, the LTH parent’s CEO, elected sole director that day; the annual return filed 31 July 2026 certifies no further changes, and a certified Profile Report of 8 August 2026 confirms Hylands as sole director and Thomas Olesinski as sole officer. What the certified filings record is a register that was not kept current. The cessation took effect on 20 April and reached the public record seventy-nine days later. The subsidiary’s only officer was registered on 23 July 2026 bearing an appointed date of 3 November 2022, a gap of 1,358 days. From its formation on 19 May 2022 until that entry, a period of 1,526 days, the register showed no officer at all, so a wholly-owned subsidiary holding the group’s flagship asset carried no officer of record for more than four years, and the one appointment eventually registered had itself gone unrecorded for 1,358 days. The 2023 and 2024 annual returns were filed three minutes apart. Five certified filings landed in twenty-three days, on a register whose only prior filings were a 2022 annual return of 31 July 2023 and the initial return of 30 March 2026, finishing eighteen days before the 18 August 2026 annual meeting. A public company’s asset-holding subsidiary is where a reader goes to find out who controls the asset, and for most of 2026 the register did not say. The dates are on the face of the documents and no motive is asserted. Ordinary explanations fit them: late Ontario filings are routinely cured in batches, four different certifying signatures appear across the five filings, the registered office was corrected at the same time, and the substantive change carries an April effective date, so nothing was created in July, it was recorded in July. Blake Hylands, Thomas Olesinski and the certifying filers are not OSC respondents and nothing is alleged against any of them. Sources: certified CIA Notices of Change effective 2026-07-08 and 2026-07-23; certified CIA annual returns filed 2026-07-27 and 2026-07-31; certified Ontario Business Registry Profile Report, 2026-08-08.
A shared administrative layer in Brazil. On the Receita Federal register, in comprovantes emitted 21 May 2026, Falcon Metais Ltda. (Sala 1311A) and MGLIT Empreendimentos Ltda. (Sala 1301) record the same Savassi street address, Rua Antônio de Albuquerque 156, and the same registered telephone; and Falcon Metais and Lithium Ionic Holdings Corp., the foreign-domiciled owner of MGLIT, record the same registered e-mail. Those fields belong to B&P Consultoria Contábil, a Belo Horizonte accountancy whose contact details appear on hundreds of client registrations across Brazil, so shared contact fields evidence a shared accountant rather than a link between the companies. What the registers do show, at the level of persons and acts, is narrower and better: the same contador, Mário Danilo Paes (CRC-MG MG-063377/O), signed the statutory authentication behind each of the three MGLIT quota-transfer filings of 2020, 2021 and 2022, and on the first of them he signed on the day of the instrument itself; and Falcon Metais and MGLIT sat in identified suites of the same building, which carries ninety-six registered establishments in total, so the co-tenancy is a suite-level fact and not a building-level one. MGLIT's own federal record lists the e-mail financeiro@lithiumionic.com, a corporate domain carrying six establishments in the whole of Brazil. The register is named in each case, because Receita Federal and the Minas Gerais commercial registry maintain contact fields independently and can disagree. B&P Consultoria Contábil, its partners and Mr. Paes are not OSC respondents and are presumed to have acted properly; authenticating a client's foreign documents is exactly what a contador does. Sources: Brazilian Receita Federal CNPJ comprovantes (Falcon Metais 09.451.327/0001-54; MGLIT 31.931.255/0001-00; Lithium Ionic Holdings Corp. 43.728.364/0001-03), each emitted 21 May 2026; Receita Federal estabelecimentos nationwide counts, queried August 2026; JUCEMG Certidões de Inteiro Teor, acts RD 8038042, RD 8859466 and RD 9180632; Conselho Regional de Contabilidade de Minas Gerais, consulta cadastral.
OSC AEP · SEDAR

Founder shares & the value ladder

On 6 July 2021 the PrivateCo issued 31,100,001 founder shares at CAD 0.0000001 each, CAD 3.11 in total. The OSC alleges the insiders, their spouses and a friend took the great majority. Within roughly a year, the same common shares were changing hands at CAD 0.70 and underpinning option grants at CAD 1.24.

Allocation of the 31.1M founder shares (OSC AEP ¶23)

31,100,001 shares · total consideration CAD 3.11 · of which directors/officers personally held 23,500,001 Gower + spouse + friend 8,000,000 Guy 8,000,000 Diniz 8,000,000 Lopez + spouse 6,000,000 Duras · 500,000 600,000 unallocated (recipient not identified) OSC ¶23 grouping (which bundles spouses and a friend) totals 30,500,000 of 31,100,000; the POCML 6 filing statement lists Diniz individually at 8,200,000.

The two records reconcile exactly, through people the filing statement never names. The OSC’s ¶23 grouping (which bundles two spouses and "a friend") totals 30,500,000 shares; the acquirer’s own filing statement discloses 23,500,001 issued to directors and officers in their own names, and lists Diniz individually at 8,200,000. The difference between the two records is 6,999,999 shares, the spouses’ and the friend’s: (8,000,000 less 4,000,000) for the Gower group plus (6,000,000 less 3,000,001) for the Lopez group. The friend is named nowhere in the filing statement, and no individual holding crosses the 10% line that would force a principal-shareholder disclosure, so the public record identifies every founder shareholder except one.

The value ladder: same common shares, ~12 months

CAD 0.0000001 CAD 0.20 CAD 0.70 CAD 0.70 CAD 1.24 Jul 2021 founder shares Dec 2021 PrivateCo placements Feb 2022 subscription receipts 24 May 2022 LTH lists on TSXV Jun 2022 option strike ≈ 7,000,000× increase from the founder price (CAD 0.0000001) to the CAD 0.70 listing price, in about ten months.
Context for quantum. The Brazilian vehicle holding the claims (MGLIT) was acquired by the PrivateCo for BRL 999 (~CAD 227); the December 2021-February 2022 placements raised about CAD 19.8M; and LTH carried a market capitalisation of roughly CAD 250M at the 9 April 2026 OSC-notice date (per the PM Super Fund demand). Mark-to-market and per-respondent disposition figures are drawn from SEDI insider filings and the SEDAR placement record. Sources: OSC AEP ¶23; POCML 6 Filing Statement 2022-05-12 (Prior Sales; post-RTO holdings); LTH Reports of Exempt Distribution 2021-12-15 / 2021-12-23 / 2022-02-16; LTH news release 2022-06-01; PM Super Fund news release 2026-05-14.
SEDAR · JUCEMG · ANM · cartório

Where the value went

One picture of the money and the shares. What Emerita paid for the Falcon Project; what the asset and the vehicle holding it were actually transferred for; what the acquiring group raised and then deployed; and, in the strip beneath, what holding the project cost and whose obligation that cost was. Amounts are shown in the currency of the record and are never added across currencies, because a ten-year run of exchange rates would carry more error than the figures themselves.

Where the value went: what Emerita paid for the Falcon Project, what the asset transferred for, what the acquirer raised and spent, and whose obligation the holding cost was A three-band flow diagram over a footer strip. Band one, Emerita paid three tranches of 500,000 common shares, in June 2016, August 2017 and September 2018, 1,500,000 shares in all, and recovered nothing and never held registered title. Band two, the asset and the vehicle holding it transferred three times, twice with no consideration stated and once for the nominal value of 999 unpaid quotas. Band three, the acquiring group was capitalised for CAD 3.11 in founder shares, raised about CAD 19.8 million, and lent 10 million reais to a related surface-rights vehicle. The footer records that the mandatory charge on all seven claims, the TAH, totalled 23,124 reais across 2017 to 2022, and that under the Option Agreement it was Falcon Metais, not Emerita, that was to pay it until transfer. Every figure is repeated in the table beneath. ①   WHAT EMERITA PAID FOR IT Emerita Resources Corp. TSXV: EMO · option-holder Tranche 1 · June 2016 500,000 common shares to acquire the option Tranche 2 · 28 Aug 2017 500,000 common shares to keep the option in good standing Tranche 3 · 12 Sep 2018 500,000 common shares exercise of the option pleaded to have gone to HFX Consultoria 1,500,000 common shares the whole of what Emerita gave to acquire the project WHAT CAME BACK Nothing. No registered title in Emerita’s name at any date. ②   WHAT THE ASSET TRANSFERRED FOR Falcon Metais Ltda. registered holder of the seven MGLIT Empreendimentos until 1 Oct 2020: Malta do Brasil Diniz, personally 99.9% of the vehicle Li-Ionic Inc. → Lithium Ionic the Canadian side 1 Oct 2020 Malta Minerals PLC (UK) transfers 999 quotas to Diniz personally. NO CONSIDERATION STATED 23 Dec 2020 / 1 Feb 2021 Falcon Metais assigns the seven processos to MGLIT. NO PRICE IN ANY FILING 1 Oct 2021, registered 21 Oct 999 quotas to the Lithium Ionic side. BRL 999 nominal (~CAD 227) The vehicle changed hands twice in twelve months. Two of the three transfers state no consideration at all. ③   WHAT THE ACQUIRER RAISED AND SPENT The Lithium Ionic group PrivateCo → Amalco → TSXV: LTH → MGLIT CAD 3.11 total 31,100,000 founder shares at CAD 0.0000001, 6 Jul 2021 ~CAD 19,800,000 raised private placements at CAD 0.20 then CAD 0.70, Dec 2021 to Feb 2022 R$ 10,000,000 lent MGLIT to Valitar, 1% per annum, fully drawn, repayable 2 Jun 2026 R$ 3,311,500 spent Valitar buys 68.62 ha of surface rights over the Bandeira ground R$ 5,000 a month Valitar leases the same land back to MGLIT for fifteen years MGLIT financed Valitar to buy land, then paid Valitar to use it. Valitar is 90% held by a company that is Diniz alone. WHAT HOLDING IT COST, AND WHOSE COST IT WAS R$ 23,124in total, 2017 to 2022, about CAD 5,500: the entire mandatory charge (the TAH) on all seven claims for those six years. Under the Option Agreement it was Falcon Metais, not Emerita, that was to pay “all applicable taxes, rates, assessments and other similar governmental charges lawfully levied or assessed” against the Falcon Project until the Transfer. Emerita’s own claim pleads it could have kept a continuing interest for less than CAD 10,000. Amounts are shown in the currency of the record. Brazilian reais and Canadian dollars are never added together, here or anywhere in this record. What Emerita paid, and the holding cost How the asset moved What the acquirer raised and spent No consideration stated, or nothing recovered

The same figures as a table, with the source of each

BandAmountWhat it isSource
What Emerita paid for it500,000
common shares
First tranche, June 2016, to acquire the optionEMO audited annual financial statements FY2016, Note 4; EMO news release 13 June 2016
500,000
common shares
Second tranche, 28 August 2017, to keep the option in good standingEMO audited annual financial statements FY2017 and FY2018; EMO news release 12 September 2017
500,000
common shares
Third tranche, 12 September 2018, exercise of the option. Emerita’s own filings name Falcon Metais as the recipient; the OSC and Emerita’s claim allege this tranche went at Diniz’s direction to HFX Consultoria instead. Allegations, unprovenEMO FY2018 financial statements, Note 5; OSC AEP ¶11; Statement of Claim ¶25
1,500,000
common shares in all
The whole of what Emerita gave to acquire the project, across the three tranches. The carrying value was derecognised in FY2019 on the change of accounting policyEMO FY2018 and FY2019 financial statements; Statement of Claim ¶25
NothingRecovered. No registered title in Emerita’s name at any date, on a dataset that captures transfers back to at least 1995ANM SCM Cessões dataset
What holding it cost, and whose cost it wasR$ 23,124 in total, 2017 to 2022
about CAD 5,500
The entire mandatory charge (the TAH) on all seven claims across 2017 to 2022, recomputed at the published statutory rates; in no single year did the fee for the whole package reach R$ 10,000ANM open-data TAH dataset; the holding-cost deep dive
Falcon Metais’s obligation, not Emerita’sOn exercise of the option, Falcon Metais was to pay “all applicable taxes, rates, assessments and other similar governmental charges lawfully levied or assessed” against the Falcon Project until the Transfer, and to hold the project in trust for Emerita until then. The Transfer never happenedEmerita’s Statement of Claim, 29 July 2026, ¶¶23(b) and 23(c). A pleading, unproven
Less than CAD 10,000What Emerita pleads it would have cost the company to secure a continuing interest in the project, with no additional holding costs until the end of May 2022Emerita’s Statement of Claim, ¶33. A pleading, unproven
What the asset transferred forNo consideration stated1 October 2020: Malta Minerals PLC transfers 999 quotas of the vehicle to Diniz personally, and the same instrument renames it MGLITJUCEMG Certidão de Inteiro Teor, act RD 8038042 (registered 5 Oct 2020)
No price in any filing23 December 2020 on the acquirer’s own dating, registered at the ANM 1 February 2021: Falcon Metais assigns the seven processos to MGLITPOCML 6 Filing Statement; DOU 2021-02-01
BRL 999 (~CAD 227)1 October 2021, registered 21 October: 999 quotas to the Lithium Ionic side. The figure is the nominal value of 999 unpaid quotas, not a price the instrument statesJUCEMG Certidão de Inteiro Teor, act RD 8859466; POCML 6 Filing Statement
What the acquirer raised and spentCAD 3.1131,100,000 founder shares at CAD 0.0000001 on 6 July 2021, one day after the PrivateCo was incorporatedOSC AEP ¶23; POCML 6 Filing Statement
~CAD 19,800,000Private placements at CAD 0.20 then CAD 0.70, December 2021 to February 2022LTH Reports of Exempt Distribution
R$ 10,000,000MGLIT’s facility to Valitar at 1% per annum, fully drawn, repayable 2 June 2026LTH FY2025 financial statements, Note 19
R$ 3,311,500Valitar’s purchase of 68.62 ha of surface rights over the Bandeira ground, three properties, 2023Cartório de Araçuaí certidões for matrículas 35875, 35876 and 36783
R$ 5,000 a monthValitar leases the same land back to MGLIT, IPCA-adjusted, fifteen-year term. MGLIT financed the purchase, then pays to use the landInstrumento Particular de Cessão de Direitos, within SEMAD-MG SLA processo 116/2024
What this deliberately leaves out, and why. Emerita’s capital subscription into its Brazilian subsidiary is not shown. Emerita do Brasil Mineração Ltda. was the vehicle for Emerita’s Brazilian operations generally, and the company’s cornerstone Brazilian asset in the period was the Salobro zinc project rather than Falcon; Emerita’s own claim pleads that the Falcon Project was acquired “in an attempt to bolster Emerita’s then cornerstone Brazilian asset, the Salobro Project”, and the Salobro option was terminated in October 2018 with CAD 2,272,408 written off. The R$ 3,844,200 subscribed into that subsidiary is therefore not a Falcon cost and is not counted here as one. It belongs to the subsidiary’s own history, set out on the relinquishment page.

And two things it does not do. It does not convert between currencies, and it does not net or total across bands. The amounts are different kinds of thing, shares issued, an annual statutory charge, a loan, a purchase price and a rent, and adding them would produce a number that means nothing. This is a map of direction and magnitude, not a balance sheet.
Operation Arms Length, the Falcon / Bandeira case file. · Updated 11 August 2026 (v4) · the public companion to the parallel investigation. This is a private, independent, open-source investigation compiled solely from public records. It is not affiliated with, authorised by, or endorsed by Lithium Ionic Corp., Emerita Resources Corp., the Ontario Securities Commission or any other government or regulatory body, any court, or PM Super Fund.
Primary sources: OSC Application for Enforcement Proceeding (9 April 2026); Emerita's Statement of Claim, Ontario Superior Court of Justice CV-26-00015174-0000 (29 July 2026, court-record copy); EMO continuous disclosure 2016 to 2026 and the Agency Agreement with Schedule "A" (SEDAR+); POCML 6 Inc. Filing Statement (SEDAR+, 2022-05-12); LTH continuous disclosure including the FY2025 audited statements (SEDAR+, 2026-06-05); DOU / ANM publications and the ANM open-data TAH and Cessões datasets; JUCEMG Certidões de Inteiro Teor (seventeen certified acts, hosted in redacted form); Brazilian Receita Federal CNPJ records; Companies House, Malta Minerals PLC 11450032; certified Ontario Business Registry records through 8 August 2026; O Globo (Lauro Jardim), 2026-04-14; and 2026 LTH / EMO governance news releases. The document library lists every hosted document.
Presumption of innocence. Every named individual and entity is presumed innocent; the OSC application is an unproven allegation, both court claims are untested, and the Brazilian matters are disputed and unresolved. Gatekeepers and third parties named here are not OSC respondents and are presumed to have acted properly. Non-respondent family members are referenced by relationship only. No material non-public information is used. Nothing here is legal, financial, or investment advice.