I believe the rules that apply to the BOD and executive officers in accordance with SEC requirements do not apply to the 20+ million shares owned by Jerry Polis. His name is there because he owns more than 5% of the total.

His shares are like any other shareholder, he may sell or buy without prior reporting to fit SEC rules.

Technically, the 11.9 million are subject to specific rules.

I think I am correct on this info.