So you are saying that the insiders can issue all the shares they want and sell them to whomever they want and there is no paper trail. What about filing a form 4 or reporting such sales in the financials. They have declared no such sales or activity . Are you saying they have lied to the SEC? There has to be an accounting for the shares in question. Through what loophole are they allowed to do this. In other words, what rule or exemption allows this to take place . You have explained the shares movements but there are strict laws which prohibit such sales by insiders. I am just trying to find out how they can beat the system. Just because this is taking place in the pinks does not allow a free hand if there are laws against such activity.