Just a note Gump...and hello... the "sec" in my opinion is as wrapped up in all this paper shuffling and pocket lining as is any mm...any insider...any volume trading pros....period!
There is definitely a rule that insiders of public companies must report their intentions to the SEC before they can sell shares, and these intentions must be made public. Whether this applies to companys on the Pink Sheets, I'm not certain....Maybe one of the attorneys who post on this board can answer this question.
In this case, one of the most obvious things is that Urbie started diluting dramatically back when the company was still reporting. Do we think he's stopped?
if indeed they can sell directly into the market the Nasd and/or the S E C would have to be notified in writing and SOME type of documentation filed.
They could do paper Reg D filings. Those never show up on Edgar. There are also other possibilities.