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SPIN

07/28/03 4:55 PM

#1020 RE: crazylarry #1014

CL

send an e-mail to Betsy Murphy. She's SEC Chief of Rule Making & would definitely be a good person to ask.

Met her last spring -- she's very nice & is e-mail friendly.
murphye@sec.gov

later,

SPIN

cpa

07/28/03 4:57 PM

#1022 RE: crazylarry #1014

CL,

If a material event is about to happen and it is a done deal, they cannot buy. After the deal is announced, I believe they cannot buy for 3 days. After the appropriate waiting period, they are free and clear to buy. It will be interesting to see if they do.

But, where would they get the money to do so?

Why buy when you can just grant yourself options!!!

Beside, Steven needs to be diversified. Didn't he say that once?

CPA

88Carrera

07/28/03 7:40 PM

#1047 RE: crazylarry #1014

CL, If insiders can't sell on non-public news, then they certainly can't buy on it either, wouldn't you say?