Something else that no one seems to consider:
Even if those were restricted shares that are now free trading, why would the seller sell so many at a discount? Generally, only institutional shares sell discounted, which I don't believe Hemi ever issued any in that direction, which is yet another reason why Keith would not know where they're coming from.
Since Keith also has no need to do a 504 offering, we can eliminate that possibility, as well. Hell, HMGP has a CD at the bank, if I'm correct, equal to the cost of the recently (last winter) purchased pulling rig.
So, using processes of elimination, we come to one conclusion: the newest/latest form of MM trickery. JMVHO