Under Reg FD, if the information is material, the onus is on the company to disclose it non-selectively in the first place. Willingness to disclose is a new standard that you and PGS have invented—it is not a defense recognized by the regulation, nor should it be for the reasons already mentioned.
I would submit that it IS a defense even if it isn't specifically captured in the literal interpretation. I challenge you to find a company successfully prosecuted for disclosing an material fact where they disclosed it over the phone to anyone that asked. I suspect virtually all Reg FD prosecutions are about material facts disclosed only to a privledged class.
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