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Re: aleajactaest post# 242139

Tuesday, 05/19/2015 12:15:23 AM

Tuesday, May 19, 2015 12:15:23 AM

Post# of 248955
alea, I went back and looked at the 8k rules you cited before,

by my reading they specifcally (at least the cited bits) address rules for Item 1, Entry into material definitive agreements.

Wave uses accelerated reporting for large sales on Form 8-k Item 8 - other events.

The language in the rules clarifying Item 1 (entry into ...) may well not apply to rules for Item 8.

GM was reported on Form 8k Item 8 - other events, not as Item 1. The rules for 8-k Item 8 are rather vague. The latest sale was reported as Item 8, again not Item 1 for which there are considerable rules clarifications.

"Item 8.01 Other Events.
The registrant may, at its option, disclose under this Item 8.01 any events, with respect to which information is not otherwise called for
by this form, that the registrant deems of importance to security holders. The registrant may, at its option, fi le a report under this Item
8.01 disclosing the nonpublic information required to be disclosed by Regulation FD (17 CFR 243.100 through 243.103)."


but my understanding is that unusual sales are typically communicated when they get in the 10% land, it helps insure compliance with FD, and satisfies the guidance of 'when in doubt, accelerate'.

The above content is my opinion.

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