Public & Private Information - Keeping it Fair

One of the great things about having over 35,000 shareholders is that they have questions and comments. We want an engaged base of customers and shareholders.

Some of those questions and comments are meant to help shareholders and prospective shareholders assess the goodness of iConsumer as an investment. And we really want to answer them. But if it requires information that is not public we can’t share that haphazardly. We are not allowed to give non-public information to one person, or to a group of people, ahead of any other group. The SEC will (and they should) come down on us for doing that.

That prohibition applies to comments and questions on places like Facebook. We love Facebook, but we don’t think the SEC will treat our responding to questions with non-public information as making it truly public, because you have to have a Facebook account, and not everybody can see every answer.

We’re trying to address that in several ways. First, if the information can be public, without hurting us competitively, and it’s something that we think is going to be asked over and over, we’ll work to make it public on a routine basis. That usually will mean a page on our website. For instance, when you visit our website, we tell you how many shareholders we have.

If the question is a “one-off”, not likely to be repeated, and we think we can appropriately answer it with non-public information that the entire world can see, we’ll do that here. That non-public information then becomes public information at the same time for everybody.

There may sometimes be a delay in responding. Releasing non-public information requires thought and consideration from top management and from our lawyers. We understand being responsive, but we’re regulated. Even more importantly, we want to be fair. We want there to be a healthy market for our stock.