My money's on "the pirates just think they can do whatever they want."
The Form 604 is required whenever there is
any change in a substantial holder's interests regardless of how the change came about - whether it be a result of takeover offer acceptances, off market transfers, exercise of options, etc. I have no doubt that if the pirates are queried on this they will say that it's the result of an off-market transfer or something totally unrelated to the takeover.
I wouldn't be surprised if either of the following scenarios are behind this 604 announcement:
- The pirate's lawyers have found a way of circumventing the orders from the takeover panel.
- The pirates have processed some off-market transfers for the sole purpose of keeping the 604 announcements coming in order to demoralise shareholders into thinking there is no other way for things to proceed.