Based on previous annual report there are about 2000...

Based on previous annual report there are about 2000 shareholders - a quarter of which have less than marketable quantity of shares. Most of these small shareholders probably don't have the capacity or interest to subscribe for $30,000 worth of shares. Many shareholders won't receive, open or understand what to do. Many won't subscribe for their full entitlement because they don't have the cash available or have enough invested for their risk appetite in the company relative to the balance of their portfolio invested. I didn't take up my full entitlement for instance.

The top 20 own 78% of the company. I wouldn't assume all of them can participate (not all will be registered in Australia or NZ) or will subscribe for their entitlement or they may have single ownership across multiple accounts (multiple account owners are still capped at one lot of $30,000 even if they receive multiple offer letters). So let's say half of the top 20 shareholders take up their full entitlement that's only $300,000.

Any language saying $13 million to be raised me seems highly unrealistic.