The basis would be the collusive nature of the offer...I.E. an illegal offer where the offeror colluded with the offeree with an illegal Private Placement of 15,000,000 shares at a price less then the amount of the offer, whereby the offeror would benefit from the tender of the 15,000,000 shares to its own offer. The 15,000,000 shares have no other benefit in this transaction then to give the offeror an unfair advantage in the tender process !!

The injunction would be to not allow the Private Placement to take place prior to the offer or at a very minimum the offeror should not be allowed to tender their newly acquired shares to the tender offer.

The whole offer should be set aside until the determination of the legality of the 15 Million share Private Placement and the tendering ability of the shares are determined by a judge.