"frogdreaming," that sounds scary, if I were to believe it, but I don't think so.
If I don't have insider information, I cannot be prosecuted for improperly acting on insider information. For example, there could be just wondrous things going on behind the scenes, but I'm not aware of them, so I'm still buying, and not subject to the restrictions on misuse of inside information. I don't have any inside information. Besides, if every person who, in the course of averaging down, became a 10% owner of a security, was subject to the restriction you allege, then it would be purely chance, and purely outside of the person's awareness, whether or not that person would be in violation! Ridiculous. That is not the reality, clearly. Just as an employee may buy and sell the stock issued by his/her employer, as long as he doesn't have inside information that would give him/her an illegal advantage (I know because I was in that situation before,) I am free to average down as much as I want, as long as inside information provisions are not breached.
I know there is a restriction regarding selling my shares earlier than 6 months after purchase, but who cares? I'm in this for the long haul, and I've been accumulating shares for more than 1 year. I could sell those shares I purchased more than 6 months ago, now, if I wanted to. I don't want to, and I've never sold a single share of DNAG.
Daniel Gannon
Portland, Oregon, USA
