But to what extent is it 'publicly distributing' when the app has only 200 users. It sounds more like an extended beta than a 'clever' way to circumvent the app

But to what extent is it 'publicly distributing' when the app has only 200 users. It sounds more like an extended beta than a 'clever' way to circumvent the app review process. And, as the author extensively explains, the major sin of Apple is not that they removed the app from Testflight, but that threaten to suspend his developer account completely and give no explanation _why_, even after multiple attempts of the author to reach out to Apple to solve this situation.