The thing that I don't understand......and never will......is why they don't just strip this issue of its mystery, freeing up a bunch of lawyers to find more valuable pursuits, and require any amendment that requires filing under the rule to be filed the next day. Boneheads, all of 'em.
or say something simple as in
within 15 days, adding an additional 5 days to the standard filing of the 13D, if the amendment is more difficult and time consuming
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