As I understood it, their initial operations would be with JOIN Regional Airlines liveried aircraft operated by Denim Air under an ACMI contract. They would therefore be a 'proper' airline responsible for all commercial activity but with Denim Air responsible for operational matters, in a similar way to which many start-ups have began; not least Ryanair. When that system is used while obtaining your own AOC, that's not a 'virtual' airline in my book.