Uh-huh. Consider this scenario: Andy sells stock for $3 million. Not really very much. He works a deal with his buddies so they all get to share the $3 million "purchase" price.
The company isn't an SEC filer, so he doesn't even have to file the "agreement" referenced in the PR.
You have no idea what's going on here, really, except that the offering is ridiculously large.
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