You are 100% correct that Rule 144 is for affiliates and control persons. However, you do not have to be a control person or affiliate to sell under Rule 144. If you have unregistered shares from the issuer, which the shares are when a note holder converts, they are restricted. Restricted shares can be sold under Rule 144 by anyone that meets the requirements. The only other way that note holders can sell their shares is under Section 4(a)(1), and they have to hold the note for a year before they can sell the shares.
And I was using generalities because VPOR does not disclose the terms of the notes in their filings. If you look at some other issuer's that do disclose that information, it's pretty much the numbers that I was using.
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