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spokeshave

11/25/02 11:01 PM

#2773 RE: Elmer Phud #2769

Elmer: You are partly correct.

It should be: "... anyone who trades based on non public information without filing a public notice with the SEC is violating the law. Of course, as DD and I have pointed out, anyone who is a fiduciary cannot legally trade on non-public material insider information at all. The real key is defining a fiduciary. Just about any known company figure can be construed as having fiduciary responsibilities.