He is definately an insider. Therefore there are strict rules as to when he can purchase stock at all times. For example, there is a window right after a significant news release when he is allowed, but for most of the time there are severe restrictions on his ability to buy on the open market. This was definately a buy in the PP, to which there are limited restrictions. In fact this is one of the few opportunities for an insider to purchase stock. This blackout does not come into play here. It is a news blackout. There will be no news until the close of the PP and exchange acceptance of same. Hope this helps.

Regards

K