I've seen the top 20 shareholders listing dated 16/09/2019 and...

I've seen the top 20 shareholders listing dated 16/09/2019 and can confirm that there has been virtially no change (around 500k shares) in the top 20 since the June top 20 posted on the Pharmaxis website. Top 20 still hold 66.9% of shares.

I noticed one entity (outside the top 20) sell 1m shares on August 14, which seem to have panicked a bunch of comsec (retail) holders who pushed the sp down to 20c on Augst 14. Many retail holders seem to have had their stop losses at 20c, and once that broke, we had an additional fall to 18.5c on August 15. Today's volume was the highest we've had since August 15.

If a sub holder has been selling, it looks to me that they are doing it using accounts mostly outside the top 20 and are selling so few shares that they are not triggering a 1% change since their last notification. If there is no change in sub holding announcement over the next few days, I'd assume that there has been no sub holder selling since the last notifications.

The majority of recent sell orders have come via comsec.

The small trades are possibly from a net seller, but aren't necessarily from a net seller. Selling 20k shares per day in tiny parcels ahead of an expected announcement seems to scare the hell out of retail holders who think "someone knowns something" and are dumping shares allowing funds and sophisticated investors to buy on the cheap. Its possible that a couple of entities outside the top 20 have been selling the small parcels over the last month, but are actually net buyers.

In 2015, PXS's share price fell from 20c to 17c in the month before the big BI deal being announced. The trading day before the deal was announced, the SP fell from 19c to 17c on volume of 740k. Trading patterns back then are not dissimilar to the period we are in now.

The key point here is that BI run a tight ship and BI themselves wouldn't even be aware of the results for more than about 48-72 hours before they announce them publicly. The information available to brokers at the moment says that recent selling is mostly by small comsec shareholders. The top 20 seems to be mostly holding firm.

Assuming FDA approval of Bronchitol and increasing sales to the EU and Russia over the next two years (=solid profit), PXS's current $73m market cap is arguably justified by the Bronchitol/Aridol business alone.