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Re: Bornagain707 post# 11523

Sunday, 10/19/2014 12:59:05 AM

Sunday, October 19, 2014 12:59:05 AM

Post# of 39541
Honda, could you please point out specifically what in the Quiet Period explanation makes you think it does not apply to WM?

The link you provided describes relaxations on previous restrictions that are available to "well-known seasoned issuers."

"Available" means a well-known seasoned issuer may choose to disseminate certain types of information during a quiet period.

Those special considerations do not apply to WM as stated in the following (albeit poorly constructed sentence) from the SEC:

"A number of these rules include conditions of eligibility. Most of the rules, for example, are not available to blank check companies, penny stock issuers, or shell companies."

That indicates WM, a penny stock, is held to tougher restrictions, not exempt from them.

I hope there is something else and not the above sentence that you base your conclusion on. If that is mysteriously what you do base your opinion on, then I want to either laugh or gnash teeth. Can't decide which.

It's the logical equivalent of "Dear Mr. Criminal. There is a law against robbing people. You may avail yourself of that restriction if you choose. If you select otherwise, you may rob people willy nilly."

By the way, the latest S1 leaves intact the Malaysian YES service going live in the third quarter. I assume that's calendar year, so when the S1 is approved, we should hear that is the case. I do not expect news of any other sales contracts having been completed. As I wrote previously, however, the Junta's crackdown makes Thailand a much more viable market for the meters than I would have thought earlier.

Another by the way. Wheelies are being marketed as an advertising medium, not a consumer product. To be allowed, WM will need an exemption from Thai rules covering lighting on vehicles.

From the S1:

"In the event Wheelies are used on public roads, they will be regulated by the Thailand Land Traffic Act of 1979 and associated ministerial regulations. Strict interpretation of these existing regulations limit any exterior vehicle lighting to headlamps, brake lights and turn signal indicators unless otherwise approved by the Department of Land Transport. If we do not request a waiver from the Department of Land Transport before commencing advertising activities, we may be subject to penalties, such as fines, or even a prohibition on using the Wheelies technology on public streets until a waiver is obtained. Any such penalties or prohibition could have a material adverse impact on our Wheelies business in Thailand."

WM has received an exemption for uses to date, but wide consumer use seems unlikely. However, that is not the company's target.

I called Paul Giles a little while back and asked about a visit to WM facilities at the Science center and to the manufacturer where they have consigned production of the meter. He said wait until the S1 clears.

Apologies for posting after saying I was out, but curiosity about Honda's reasoning exceded the discipline of my best intentions.



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