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F1ash

07/29/18 2:42 PM

#160415 RE: drv17 #160411

I was aware of those events but very curious as to where/who had 20% of the less than 45,000,000 outstanding shares to transfer(?) in one transaction.



I don’t recall the 9 million shares being only one transaction.

I believe your theory would be a Pipe and my reading is that would have already required a disclosure.

See this section at the link.

“Disclosure Requirements and Securities Law Filings”

https://www.sec.gov/info/smallbus/gbfor25_2006/pidgeon_lewis_pipes.pdf