I thnk you are off on your numbers. The first settlement figure by my account is $.0278 per share on 8/10 closing price was .039 on 8/9 closing price was .04 on 8/8 closing price was .04 average of the 3 = .0396 70% of that = .0278 I figure that "20 trading days preceeding the installment date" does not include the installment date.