Thank you

information on ASC Rule 72-501 section 16 (3)

https://www.albertasecurities.com/-/media/ASC-Documents-part-1/Regulatory-Instruments/2018/10/5410522-ASC-Rule-72-501.ashx

16.

(3) Despite subsection (1), a report in Form 45-106F1 Report of Exempt Distribution filed in respect of a distribution under section 4, 5 or 6 of this Rule is not required to contain the information required by any of the following;

(a) Item 7(c) to Form 45-106F1 which includes the Schedule 1 to Form 45-106F1 (CONFIDENTIAL PURCHASER INFORMATION);

(b) Items 7(f), (g), and (h) to Form 45-106F1;

(c) Item 8 to Form 45-106F1;

(d) Item 9 to Form 45-106F1 which includes the Schedule 2 to Form 45-106F1 (CONFIDENTIAL DIRECTOR, EXECUTIVE OFFICER, PROMOTER AND CONTROL PERSON INFORMATION).

so - this is just a guess - maybe Dicky To, or Hepalink (Shawn Lu) purchased some of the shares ...or maybe DM?...who knows