They can sell their shares based of the formula in the filing assuming it doesn’t eclipse 50% of the average trading volume for that day as reported by Bloomberg or above .08. So yes, there is a holding period in effect. The 4.9/9.9 threshold will never trigger Rule 144 as that governs restricted shares. Beneficial Ownership Limitations is what would be triggered if a note holder held >4.9/9.9%. They don’t want the note holders controlling 55.4% for obvious reasons lol.
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