Ah ok. Good to know. If the definition is as you say then I can't scrape together enough shares for him to hit 10% of 174 million. Again though, I'm not nearly qualified to make the determination.
In this case he already had to file as an officer and as a director so the 10% would be a redundant requirement. In any other case, it's better to file thinking you're a 10% holder than to be one and not file.