It's not as 'simplistic' as a definition of a 'special dividend'...
The concern is how investors were treated in regards to this 'special dividend' which is not stated as such in filings and is a 'dividend distribution' vs the July 2010 'share distribution'...
To Quote...
"I know of no reason why they failed to use the original 'Record Date as the Accurate Date', and "why they didn't make the initial distribution", never having to explain 'why' and using a backdate doesn't get them past that question - they still didn't make the 'Initial' distribution."
That said... Backdating and this new 'Special Dividend' serves to make the entire transaction look suspicious, and casts a shadow over the issue of 'Intentions' and does not excuse the company or hold them harmless!
This information is from an ***Attorney*** (who has REVIEWED ALL the INFORMATION)
The SEC will determine 'IF' and to reiterate...
The most damning part of all... The ***March 14, 2011... Blog Update by Ken! ***
This was posted 'AFTER' several statements by the Company were required to give better clarity to avoid investor confusion!...(read the SEC correspondence)
"Well good, then he will agree with what I have posted. "wshaw my Attorney has done extensive research!" __________________________________________________________________