>there is no requirement that the [10b5-1] plan be periodic, at least, that's news to me and the regulation does not mention it.<
The requirement that 10b5-1 sales be periodic is implicit in the language you cited; that language would make no sense if applied to singular transactions.
>Ruth Kunath's form indicates her sales were pursuant to a 10b-5 plan, and while I could be wrong, I think she sold everything at once.<
After the recent transaction, Kunath still holds 13,200 options exercisable at $1.81/sh (to be exercised and sold in subsequent 10b5-1 transactions); this is shown in the bottommost row of the Form-4 tables:
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