They would only have to file if they hold more than 5% at any given time. That currently translates into 22.5 Million shares. So, they could have 20 million shares at a given time and not file at all. Furthermore, they aren't ever going to hold long, they are going to sell as soon as they get them. Asher knows exactly what they need to do to continue to sell shares and never file.
FWIW, 20 millions shares is "tens of millions of shares".
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