VALENCE TECHNOLOGY (VLNC) Message Board

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Technology Stocks : VALENCE TECHNOLOGY (VLNC)

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To: Larry Brubaker who wrote (9273)	3/13/1999 8:50:00 PM
From: kolo55	Read Replies (1) of 27311

Comments on reporting short sales. You wrote:Paul, show me the SEC rule that requires a short interest to be listed as "beneficial ownership." In all the SEC filings I've read, I have yet to see a disclosure of a short interest as a "beneficial ownership." And even if they did have to report a short interest as a "beneficial ownership" presumably they would only have to report this short interest if it exceeded 5% of the outstanding shares, or more than 1.3 million shares. That amount is larger than the entire short interest outstanding. Larry, the impact of the short sales would be included in the total shares beneficially held, and possibly not listed separately in the reports you and I see. The 5% limit you refer to is not in respect to material changes, but relates to total beneficial ownership. Clearly I believe a short sale, especially one as large as you have suggested (over a million shares), would be reported as a material change in beneficial ownership, and would have to be reported to the SEC under the laws I've referenced. I think you're wrong on this one. You disagree. Perhaps a lawyer on the thread could chime in. Paul

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