> they can use whatever mechanism they want to, without disclosure, to produce numbers.
That would be fraud against whoever participated in this round, so no. Just because they aren't regulated doesn't mean they are literally free to do whatever they want to close the round.
it would be fraud only if they're also telling their investors the same numbers.
> Just because they aren't regulated doesn't mean they are literally free to do whatever they want to close the round.
What makes you think their public announcements are aligned with what they give prospective investors?