I have found that reading between the lines is not as effective as reading the volumes of information that is available. In this particular case, SEC Rule 144: Selling Restricted and Control Securities.
Rule 144 allows public resale of restricted and control securities if a number of conditions are met.
Control securities are those held by an affiliate of the issuing company. An affiliate is a person, such as a director or large shareholder, in a relationship of control with the issuer. Control means the power to direct the management and policies of the company in question, whether through the ownership of voting securities, by contract, or otherwise.
Trading Volume Formula.If you are an affiliate, the number of equity securities you may sell during any three-month period cannot exceed the greater of 1% of the outstanding shares of the same class being sold, or if the class is listed on a stock exchange or quoted on Nasdaq, the greater of 1% or the average reported weekly trading volume during the four weeks preceding the filing a notice of sale on Form 144. Over-the-counter stocks, including those quoted on the OTC Bulletin Board and the Pink Sheets, can only be sold using the 1% measurement.
Filing a Notice of Proposed Sale With the SEC. If you are an affiliate, you must file a notice with the SEC on Form 144 if the sale involves more than 5,000 shares or the aggregate dollar amount is greater than $50,000 in any three-month period. <<<
I would really doubt that the SEC would allow anyone to violate one of their own rules, to satisfy a court order. IMO, the dumping of millions of shares on the market as you suggest is not allowed. One other point I would make is that although the agreement states that the settlement can not be appealed, the court rulings can be. Even if the district court issues a bar and disgorgement, there have been several instances of appeals, after settlement, with some being overturned by the circuit courts.
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