Replies to post #82632 on The Golden Lounge

[Jim Bishop]

Thanks Mark. That's about what I figured as far as how it should read.

I'm assuming that they don't qualify. Will have to study 12 and 15d.

[janice shell]

I have a followup question that was much discussed over the weekend on a number of boards.

Ammerman of LFWK is insisting, albeit rather unintelligibly, that he and his insiders have "bought up the float". I've suggested that if he wants to demonstrate this, he and his insiders should file their Forms 3, 4, and 5.

Some on the boards have protested, rather irrelevantly, that Pinkie insiders aren't required to file Forms 3, 4, and 5. I countered that the onus is on the individuals; the status of the company doesn't matter.

I even took the trouble to read Section 12. I see nothing in it that suggests that Pinkie insiders are not obliged to file. Of course the SEC doesn't insist on this. They don't insist on it even for reporting companies. But they should.