They could be holding some .....or all......my guess.....they actually look at the market.....they look at the bid and ask.......they look at volume.........they have done DD.....so, they can hold or they can sell or they can do both........but, they will not let their holdings exceed a certain % of their total....no way to know what that is....but, they are intelligent investors...
Clearly, they are including the free shares as "sales," and the "first sale" on May 1 represents the initial give away of 5,540,550 free shares. So, what you say is a mistatement. It was not less than 5 million shares, and no money was deposited in Elite treasury to be used for trials or pipeline development.
5,540,550 seems like kind of a random number, eh? It's not random at all. It is based on $800,000 at a share price equal to the average of 3 lowest closing prices in the 10 trading days prior to May 1, 2017 (commensurate with the LPC III agreement).
On a positive note, I believe this means that the second give away of free shares will be based on that $800,000 number, and if the share price is higher then the shares will be fewer. For example, if SP is .50 at the time it is due, then only 1,600,000 shares would be required instead of 5,540,550.