I am not certain about this.
As the IR person he presumably has access to inside information.
He also holds a considerable sum of KBLB stock (less than 5%).
He is certainly an insider per the penalties for insider trading.
I am not sure if his contracted IR firm shields him from stock trade reporting. I would guess not.
(if that were so, then all sorts of VPs of finance etc. would change their paper status to "independent contractor for financial services".)
I suspect that the SEC's lawyers (who write the law) would consider such status an illegal attempt to circumvent the law, and thus not a sustainable defense.
If I were he, I would want at least 3 lawyer's opinions before failing to report trades.
Note: I am not a securities lawyer nor do I play one on TV or message boards! (but Kim Thomson IS)
Mike L.