On April 2, 2015, Michael Sacks announced that he had engaged in correspondence with management and representatives of ULURU between November 2014 and March 2015 concerning various topics, including ULURU's business, operations, financial performance and financial disclosures. Michael Sacks' added that many of questions remain unanswered and he has shared his concerns with The Punch Trust (TPT) and Bradley Sacks, among others. As a result of his continued frustration with ULURU's poor operational and financial performance, including poor performance by senior management, Michael Sacks determined that new individuals should be nominated as Directors of ULURU.

On April 1, 2015, TPT sent a notice to ULURU nominating Bradley Sacks and Robert F. Goldrich as candidates for election to the Board of Directors of ULURU at the next annual or special meeting of Stockholders of ULURU at which directors are to be elected. Bradley Sacks is the son of Michael Sacks and the brother-in-law of Robert Goldrich.