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Millstone

10/19/17 7:42 PM

#125443 RE: plexrec #125439

The purchases are according to an SEC sanctioned trading plan, through which purchases, even while in the possession of material non-public information, are completely legal. That is the main purpose of a trading plan. It is generally constructed to be at arms length, with a preset timing/share amount.

kevindenver

10/19/17 7:47 PM

#125445 RE: plexrec #125439

Good question that's where 10b5-1 trading plan rules come into effect.

Notice at the bottom of all the For 4's this:

"The purchase reported in this Form 4 was effected pursuant to a Rule 10b5-1 trading plan adopted by the reporting person on August 9, 2017"

These plans are most often used for selling, but also buying. If at the time the plan is to go into effect all material information as of that time must be disclosed to the public for the plan to go into effect.

After the plan is in effect an insider, director, or control person may make scheduled buys or sells per the plan even while material events may be progressing.

Google it: 10b5-1 trading plan.

And what Millstone said :)

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