He paid you in the past and he paid Clay this year...He has an obligation to file IMO...Otherwise he risks being sued for manipulating the pps by paying for IRP on msg boards....Lets not make any assuptions here...EVERYONE knows what paying for IRP means....Now if that exposure was for a P&D and not based on facts, there is an issue....file form 3s....
"EXPO" paid, not a 3rd party, for IRP "charting" while friendlies posted. IRP doesn't come by himself you know...there is a crew of paids or "friends"...People bought the ETC/EXPH pump going into 2011...4 days after launch they PR a divy??? You stated he toyed with the idea when you were involved?
I'd say there is a conflict brewing...but, thats JMO....