Rule 13d-3 -- Determination of Beneficial Ownership
a. For the purposes of sections 13(d) and 13(g) of the Act a beneficial owner of a security includes any person who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise has or shares:
1. Voting power which includes the power to vote, or to direct the voting of, such security; and/or,
2. Investment power which includes the power to dispose, or to direct the disposition of, such security.