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jobynimble

09/09/14 3:29 PM

#18434 RE: xxxxcslewis #18433

Makes all the sense in the world if you know the rules. Read up on Reg FD...
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kaymeyer

09/09/14 3:29 PM

#18435 RE: xxxxcslewis #18433

I'm fairly busy today but I'll be happy to post the statutes as they relate to insider trading for you in the am and I'll also be happy to answer any questions you may have after you have had the opportunity to read through them. I believe that may prove to be much more helpful than relying on a pink sheet's IR department.
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kaymeyer

09/10/14 9:23 AM

#18445 RE: xxxxcslewis #18433

I have reviewed the statutes and it does appear to me, in both my professional and personal opinion, that trading in Telvue while privy to non public material information could expose an individual investor to insider trading charges. I've linked an article below written by one of my colleagues that should help some understand what insider trading is, the elements of the offense, and the potential penalties.

It may also be helpful to take note that the Courts have ruled that scienter or in layman's terms, requisite intent is not required for a conviction under rule 10b of the exchange act.

Therefore, As stated. I would highly recommend any individual contemplating trading Telvue to consult with an attorney who can review your individual circumstances and advise you accordingly.

I will be in and out today but should anyone have any general questions or clarification regarding this matter, please don't hesitate to ask.

http://www.americanbar.org/content/dam/aba/administrative/litigation/materials/sac_2012/29-2_the_law_of_insider_trading.authcheckdam.pdf