Real Options, Inc. is a company not required to provide periodic reports to investors under the Securities Exchange Act of 1934 (i.e., it is not a publicly traded company). ROI wants to raise $700,000 by selling preferred shares to 150 investors, including its customers, suppliers, and employees. Is ROI eligible to make the offering under Rule 504 of the Securities Act of 1933? What must ROI do to comply with Rule 504?