Yeah, I saw that. Was going to reply/add to your earlier...

Yeah, I saw that.

Was going to reply/add to your earlier comment, but thought I'd do it here instead - not so much as a correction, but just an addition to the discussion.


Zeta's full 33.2m allocation under the CR was outside the 3% creep rule because taking up their full allocation would simply keep them at the same percentage ownership level as before the CR (i.e. tipping more money in just to stay at the same ownership level).

The 3% creep exception (Item 9, s.611) became relevant when considering how much they would sub-underwrite (10m), which still kept them under the 3% ceiling. They've still got a little bit of headroom if they choose to use it right now, but their recent history suggests they won't be too aggressive about it. I'm thinking they limited the sub-underwriting to 10m because the the March/April CR was strictly only ~5½ months ago (i.e. just inside six months, meaning the 3% creep needed to factor in shareholding percentage increases relating both events, due to the timing between both). The time limit restrictions relating of the March/April event drop off ~17 Oct, which frees up further additional headroom for Zeta if they choose to use it. So far, however, they seem to be content with making the majority of their additions via placements or as a sub-underwriter - notwithstanding some on-market activity.

Z