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Re: 1jk1 post# 271894

Thursday, 12/24/2009 9:27:53 PM

Thursday, December 24, 2009 9:27:53 PM

Post# of 346920
1j,
There are others that can probably answer the Wells question better than I, but the SEC Enforcement Manual:
http://www.sec.gov/divisions/enforce/enforcementmanual.pdf

seems to say a couple interesting things.....please read Section 2.4 The Wells Process to confirm my understandings:
A Wells Notice is issued to individuals, not to the company.
There is no requirement to issue a Wells notice.....it's up to the responsible SEC Deputy Director.
"The Wells notice should tell a person involved in an investigation that 1) the Division is considering recommending or intends to recommend that the Commission file an action or proceeding against them; 2) the potential violations at the heart of the recommendation; and 3) the person may submit arguments or evidence to the Division and the Commission regarding the recommendation and evidence."

BTW, this isn't a one way street. You owe me an answer:
http://investorshub.advfn.com/boards/read_msg.aspx?message_id=44850522

I just found out that I'm out of posts (for the first time) and I owe pj a response....hopefully he's reading this.
I wish I knew what Pike is thinking. His most recent buys aren't material to his position. And the price differential is even less material.....call it .005for 3.6m shares = $18,000...might mean something to you or me, but I'm not sure how much effort Pike would put into saving it. That said, you're right...it should be fairly easy. Here's what I'm wondering..and I'm hoping every body else is too busy with Christmas eve stuff to notice: Window dressing....psychologically "painting the tape" with an institutional buy filing. I know it could be a load of crap, but I don't have anything else to offer.

Merry Christmas!
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