Oh Pompeo, you cheeky man ;)
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That is a rather legalistic way of looking at it.
But by the same token, it could be reasoned that absent a clear indication as to whom the transition is done, given the fact that Potus did not concede, concluding that by default a transition statement must therefor pertain to a Biden Administration is rather pre-mature.
Till 11:59 on Jan 20th ....
And at High Noon we will maybe have a Biden Administration for as long as that may last.
https://invidious.snopyta.org/watch?v=A4a_1UhwgFU