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Wirlong, page-38

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    Over 3 million shares sold (assume from same party) ie 2.2% of issued capital. If HHM or Perth Capital are selling then they will need to Change Substantial Holding for every 1% change.

    If holder is under 5% than you don't need to issue Change Holing for every 1% change. So most likely someone under 5% (eg Catholic Insurance).

    Unless Substantial holders (ie 5% or greater) are just selling most of shares to themselves (change account) to realize gains/loss. Than they don't need to issue changes.
 
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