There are regulations in place that prohibit selective disclosure of information. Period. One need not act on the disclosed information for there to be a violation.
I find all this to be silly. This is a management that navigated through years and years of government scrutiny that handcuffed the company and stalled them for years. As we have seen repeatedly right here on this board, they play it very close to the vest regarding the flow of information and frequently refer to the fact that they can't selectively disclose information. So I find it unlikely that they would be leaking material information knowing it could lead to many more years of headaches.
One caveat is that SEO certainly has OTHER sources of information about oil and gas goings on. He need not rely on ERHE management to relay information - he probably lets THEM know what's up.
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