The question you SHOULD be focused on is this:
"Without Brown, Harrs and their insider buddies selling a good portion of their reputed 850M common shares, how the hell does the entire, thinnly traded EXPH float change hands 12+/- times over the course of the lead up to and actual P&D in 2009?"
THAT is what you need to know about the "restricted shares". It rose gradually but then went went straight up. And then went straight down. The lion's share of the action coming inside a 72 hour period. Normally you might see a float flip once or twice in a P&D...but a dozen times? As close to impossible as impossible gets. BUT...add in say 600-700M shares from insiders being dumped leading in off of the better portion of the false or misleading 50+/- PRs issued in 2009 and **voila**, suddenly it takes on the exact proportions of a normal pink sheet P&D. How incredibly unusual, LMAO!
Stop worrying about how con artists get around rule 144 regulations in the barely policed pink sheets...they do. It happens ALL the time, many times a year. You want to kick off a new trend? Start worrying about bringing the perps to justice; THAT rarely if ever happens. It incomprehensibly boggles the mind to see how some entities who have been flat-out robbed by Brown and Harrs ignore the glaringly obvious conclusions sometimes for YEARS and go to the mat time and time and time again grasping at straws to defend the indefensible. Maybe time for everybody to take a look at the big picture and stop concentrating on the pretty frame it's in. IMHO.