Shadow,
You are correct by the looks. The 20 million were issued on Jan 6th 2014. As far as I can see, CDU haven't asked for that 20 million to be approved and they would therefore come under the 15% rule.
By the looks of it through to 6/1/15 they would only have about 15 million shares available to be issued and not the 35 million. Good pick up there Shadow.