Under the Corporations Acts, a 'substantial holding' in shares is defined as being a relevant interest of 5% or more of the voting power of those shares under the control of a shareholder and/or his associates. The whole point is so that market participants can identify controllers of substantial blocks of voting shares, so just using different accounts will not change the fact that all those shares are still under your control and therefore requires disclosure (otherwise everyone would just use different accounts and no one would need to submit those disclosures). Feel free to check out Chapter 6C of the Corps Act if you want to read it straight from the horse's mouth.
My original comment talked about how 2.23m shares traded hands, and your reply was "thats me", implying you did the whole thing. Now you're walking back on that. How long until you walk back on your "I own 4% of ISD's outstanding shares" as well?
ISD Price at posting:
17.0¢ Sentiment: Hold Disclosure: Not Held