Making it difficult is nothing new for the SEC, in fact, it is no doubt difficult by design as the size and extent of the shorting on higher eschanges is much less transparent. I agree that cash dividends make a huge difference to those who are shorting and expect this tool to be utilized much more in the near future by companies that can. I also agree on the covering. I remember both TASR and SSOL years ago that went from pennies to hundreds of dollars per share with forward splits thrown in for good measure. It took about 6 months for the shorts to cover before they started the downward cycle. This should be fun to watch.
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