Filing a complaint with the SEC better have some sort of substantiated evidence of wrongdoing. The OTC is WAAAAAY down the list of priorities at the SEC by the way. A provable bombshell would be necessary with a large dollar amount and a proper villain to get their attention-something that they could not ignore. Anything less-don't bother.
As a side note-I have seen all this angst previously with a similarly "quiet" or "less-than-forthcoming" publicly-traded IP-based company and the process went way further and with much more substantive evidence than what is being speculated here. That company went bankrupt, a private company with many of the same players swooped in and purchased the IP at pennies on the dollar and a hired forensic accountant came in and although several improprieties and conflicts counter to shareholder's interests were uncovered, nothing came of it.
You have got to wonder how much of this pitchfork-wielding rhetoric management and - yes the BOD - would put up with before they would consider somehow pulling the plug or devising a similar plan to take the company private. Is that what everyone wants?