September 29, 2009
SHORT SALES OF ANY SECURITY BY ANY INSIDER SHOULD BE GOVERNED BY THE VERY SAME CRITERIA AS BUYING AND SELLING BY INSIDERS AND SHOULD HAVE THE SAME FORM 4 REPORTING REQUIREMENTS. FOR EXAMPLE, ANY INSIDER WHO SHORTS ANY AMOUNT OF THEIR STOCK MUST REPORT IT ON A(NEW)FORM 4-S IN ACCORDANCE WITH EXISTING TIME FRAMES NOW REQUIRED FOR THE EXISTING FORM 4. WHEN THEY COVER, THE SAME WOULD APPLY TO ANOTHER NEW FORM, FORM 4-C. THANK YOU, MARTY FAVINO