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deal guy

11/18/19 4:53 PM

#64802 RE: KART4445 #64801

No

In your example if you walk on to the Atkinson landfiil and see digesters and nobody form LRS, ECOS or Alsource told you anything about what you saw or directed you to them, you are merely relaying an observation, not a fact related to you by a person with inside information.

The reason AllSource is different is that they are a distributor of ECOS. To the extent as a result of their relationship with ECOS, they learn of plans about ECOS building digesters which ECOS has not publicly disclosed, they are relaying nonpublic information about a public company.

I know this may seem nuanced but there was a conviction in the 1980's of a person who got nonpublic information about one of his firms clients. He related it to two gentlemen named Boesky and Levine. The person who passed the information to Boesky and Levine was charged with the dissemination of nonpublic information about a public company. Even though he made no money from passing the info on he got fined by the SEC ad got to spend a short stay at club fed