CMKM Diamonds Inc. (fka CMKX)

[Capitalist]

Seems you're correct.

2. Disclosures of Material Nonpublic Information

The final regulation, like the proposal, applies to disclosures of "material nonpublic" information about the issuer or its securities. The regulation does not define the terms "material" and "nonpublic," but relies on existing definitions of these terms established in the case law. Information is material if "there is a substantial likelihood that a reasonable shareholder would consider it important" in making an investment decision.38


http://www.sec.gov/rules/final/33-7881.htm