Vintage, the form 604 is needed to advise a change of 1% in voting power within PEN. So for 3.42B FPO's on issue that means a change of 34 million shares triggers the form 604 reporting.
You appear to view it in relation to a 1% change in the size of the shareholders stake, which is incorrect.
Less shares than this have been needed to take the wind out of what might have been the SML ann rally.
nice move, page-46
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