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Microcap & Penny Stocks : HITSGALORE.COM (HITT)

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To: Q. who wrote (4273)10/3/1999 3:54:00 AM
From: Jeffrey S. Mitchell  Read Replies (1) of 7056
 
dumbmoney, did any of the filings disclose whether the two LFT private placements were made under Reg. D? Or are they 144 shares? I don't remember seeing this mentioned anywhere. Just the unspecified lockup.

According to Regulation D, "To be eligible to use Rule 504, an issuer must not be: a reporting company under the 34 Act..."

The LFT offerings were done after HITT became a reporting company. Therefore, Rule 504 of Regulation D would not apply.

To confuse the issue a bit, there are other Rules under Regulation D which do apply to reporting companies. However, I'm a bit confused as to whether disclosure must be made prior to a sale, which is what "average" shareholders should be worried about.

See moneylaw.com for more information.

- Jeff
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