Mark - correct. I don't think there is any argument that GW would have access to data on a daily basis as far as dose sales and revenue is concerned. This would apply to any company where the CEO sells shares. ASIC would not take any action based on this, IMO.
Your argument MUST be in relation to what is material, if you want anything other than a cookie cutter response from ASIC. If your case is that the dose sales to date are, say 10%, under market expectations then that would probably be considered material.
The US being the major market in relation if Revenues and Profits would likely be the major impact of materialbility . If the US was running at 10% or more less than the 19% (?) over the previous year then there is a stronger case. Under 17% would be my call, but even that may be marginal. If US dose sales are running at less than 15% over last year then there would probably be a much stronger case.
Best.
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