I believe the shares can be sold to accredited investors (i.e. investors with considerable assets and the knowledge and means to properly evaluate the risks involved) and affiliated persons (employees and contractors) without public disclosure, however, they would have to be restricted from sale for 6 to 12 months. My guess is that they were used primarily as share compensation for their contract executives/employees, in which case the sales would be restricted for 12 months after which they could only sell 3% of their holdings on any given day.
Paul is still putting his personal funds into the company...
There is no indication that Paul has personally profited from any stock sales or that there is any dumping going on.