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kaymeyer

12/10/14 6:12 PM

#19679 RE: gabeh #19678

I don't know if I can state this with any more simplicity but I'll try once more. The law is the law. I'm not interested in debating prosecutorial discretion nor am I interested in making guesses at to whether ones personal circumstances in trading Telvue might cause them to run afoul of insider trading statutes. As a disinterested attorney, I prefer to deal with facts and not supposition. Supposition is between an individual investor and their own attorney. I merely recommend that anyone that may be contemplating trading on the basis of non public material information may wish to consult an attorney who specializes in these matters. I hope this has satisfactorily addressed your concerns.

agribusiness72

12/10/14 8:34 PM

#19681 RE: gabeh #19678

All one has to do is look here:

www.otcmarkets.com/stock/TEVE/quote

Where you will see this: (see last paragraph)

No Information Warning
This company may not be making material information publicly available.

If you are an affiliate, employee, insider, or any person in possession of nonpublic material information about this company, please be advised that buying or selling this security may constitute trading "on the basis of" material nonpublic information prohibited under Section 10(b) of the Securities Exchange Act of 1934 and Rules 10b-5 and 10b5-1 thereunder. Violators of these laws are subject to civil and criminal penalties.

What is insider trading?

Illegal insider trading refers generally to buying or selling a security, in breach of a fiduciary duty or other relationship of trust and confidence, while in possession of material, nonpublic information about the security.

Rule 10b5-1 provides that a person trades on the basis of material nonpublic information if that person is "aware" of the material nonpublic information at the time of the purchase or sale.

Affiliates, insiders, relatives, or other persons in possession of material information should use extreme caution when buying or selling securities on the basis of material information, particularly in securities where the company is not making adequate current information publicly available as a matter of practice.

Why does OTC Markets display this warning?

Companies that are identified on otcmarkets.com as having “No Information” may be placing their shareholders at risk of violating 10b5-1 insider trading rules. OTC Markets recommends that investors wishing to place a trade in such securities contact the company to verify it is making adequate current information publicly available.


Bottom line is contacting an attorney if you signed the NDA and received the non public financial is a good idea. Can't go wrong if you do this. Whether or not you agree doesn't matter the warning is valid