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Technology Stocks : Terayon - S CDMA player (TERN)
TERN 26.31+0.8%Nov 21 9:30 AM EST

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To: Starlight who wrote (782)4/18/2000 11:37:00 AM
From: pat mudge  Read Replies (1) of 1658
 
Elizabeth --

I just received the following regarding issues of insider selling. Clearly it doesn't matter how many shares were sold:

"As a past officer of a public company, our lawyers and CFO were quite specific on insider trading. As an insider, it doesn't matter if you sell one share or a billion. Trading shares when in the possession of materially significant non-public information is a violation of SEC regulations."

[It's now up to the courts to decide if any CableLabs communications (not just the letter) is deemed material. They've already done their part, which is the trading."]

"The advice given with respect to selling was that as far avoiding SEC reg and shareholder suits, it is advisable to set up a regular selling policy, i.e., something like selling no more than 10% per quarter. Selling above that can trigger suits and signal lack of confidence in upper management. However, even if poised to sell and with a 144 filed, the CFO had the last say about performing the actual trade as insider information possession has a higher priority than anything. That is, you could be set to do a regular sale of 10%, but if the there was the slightest issue with regards to holding insider information, then NO SALE. Officers are *very* locked up and don't always have a window to sell because of insider exposure."

Pat
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