Cigarbutt

I liked it too. The tariffs section is interesting and balanced. Tariffs are not, by definition, right or wrong but are associated with first order benefits and costs as well as second order consequences. There was an active thread on tariffs. The second part deals with the populist appeal and resentment. From Mr. Marks: The government is not likely to increase aggregate benefits and is mostly involved in the distribution of costs and benefits. Recently, there was an election result in my jurisdiction (province in Canada, result=irrelevant but context=relevant) and a more business-friendly party won. However, the largest gains were obtained by a quite left-leaning party which is composed of a young, enthusiastic and committed base. A base that is likely to grow in the event the economy stumbles. Why? Building on what Mr. Marks says, I would add that the government is a net short-term negative for the economy but it can foster an inclusive environment that can maximize constructive gains coming from the private sector. IMO a certain elite that is both government-based and oligarchic in nature has become quite complacent and appears to be oblivious as to why capitalism has become so unpopular among growing circles. Recent addition to the food for thought process. https://assets.realclear.com/files/2019/01/1155_Mobility.pdf

The junior oil and gas sector is a magnified boom and bust cyclical industry. Since 2015, the market environment has shown that many focused only on the boom side (bloated and too well paid execs at the top, excessive leverage and poor/unsustainable capital allocation model) but let's say you're a typical player in the field (reasonable), what do you try to do during the bust? You try to stretch the payables, stretch the lenders and you try to stretch the environmental liabilities. In 2015 and 2016, there were a few instances where Receivers would come in and flesh out the good assets and throw away the inactive (which really "deserved" to be abandoned) wells into the public backed-stopped hands. At the time, this did not smell right. So, who's at fault? I would say many parties but IMO especially the regulator (AER) and if you read the SC decision between the lines, the wise suggest to observe the rules AND to re-write some rules. I think it's not the job of the regulator to "help" the industry during downturns. When looking at what has been happening in the last few years, the AER has underestimated abandonment costs and overestimated the potential recovery of inactive wells. Firms that reached bankruptcy and price discovery levels were sometimes characterized by a very unusual switch of potentially "productive" assets becoming environmental liabilities. Despite the above comments about the judicial aspect, if the regulator brings the LMR ratio and its management to appropriate and conservative levels and if you believe, as I do, that the Canadian oil and gas sector has a role to play in the global energy transition, nothing (not even the Supreme Court) prevents the politicians (federal and provincial) from "investing" in an infrastructure-related program for environmental remediation or even a "job stimulus" program to help the industry if the downturn persists or worsens. The oil industry has to become a better (and less adversarial) political player.

For those fires currently under investigation, do you know which may be attributed to PG&E or which are suspected? Good info. Also, Camp Fire is roughly 3 .3 times the number of structures and Tubbs was estimated to be $7b of liability, so an estimate of $23b seem fair? Convert the debt with a hair cut and you're set. So I'm interested at 39c on the $. The most decisive work will come from the evaluation of major risks: 1- 2019-20 "weather" risks, 2-"nationalization" risk and 3-risk of newco. The valuation work will be work in progress. (Re)insurers may be a good starting point: https://www.munichre.com/en/media-relations/publications/press-releases/2019/2019-01-08-press-release/index.html

^Even if individual firm reckless behavior cannot be ruled out, the growing number of abandoned wells is mostly due to a very difficult realized price environment since 2015. The bankruptcy processes that resulted from the above effectively transferred the environment liabilities from the "polluter", skipping the lender, to the OWA which has required, on top on industry contribution, some form of government support (temporary). The OWA has produced a letter yesterday (see link provided by EliG). Bankruptcy is used to maximize recovery and to offer coordination guidelines. The SC ruling IMO simply helps to correct the relative temporary displacement that has occurred. Temporarily, the lender will pay if oil prices stay low but lenders have also intrinsic mechanisms to pass costs to the various customers they serve. Energy ($) can neither be created nor destroyed, but it can move around. Along the same lines, if externalities become incorporated in regulated utilities' cost+reasonable return model, it's not the utility's return that will change. Here's a nice summary of the split decision: https://www.osler.com/en/resources/regulations/2019/supreme-court-of-canada-decision-in-redwater-early-implications

^From the odds point of view, PG&E appears to be in a weak position versus certain fires especially the Camp Fire, which happened to be the straw that broke the camels back, except that it was more like a ton of bricks. http://www.fire.ca.gov/communications/downloads/fact_sheets/Top20_Destruction.pdf Most of the numbers work here is discounting the liabilities (settlement, time value etc). PG&E will have to roll with the punches (and they're likely to be good at that, absent a deadly blow) and should become a champion of security and safety but that does not appear to be printed in their DNA (Board and top exec overhaul would help). This is likely to get worse before (if) it gets better.

You seem to be mixing RNA for DNA but let's not get wrapped up in unimportant details. Right? The topic was touched in reply#25 in the HTL thread. The race is on. https://www.vox.com/science-and-health/2018/11/30/18119589/crispr-gene-editing-he-jiankui

U.S. District Judge William Alsup, who is overseeing PG&E’s probation for safety violations that led to felony convictions for the 2010 explosion of one of its gas pipelines, set the tone for oncoming (and sometimes unidirectional) discussions and continued to apply pressure to rebalance safety over profit before the 2019 fire season. "Does the judge just turn a blind eye and say, PG&E, continue business as usual, continue to kill people?” In a related and qualified as unsolicited filing from an electrical workers union who could describe a “superior, direct, first-hand knowledge of PG&E’s grid”, the group offered the following opinion: “The goal of reducing to zero the number of wildfires caused by PG&E in the 2019 season is noble but not practical,... Inspecting 2.3 million electrical distribution poles and 150,000 transmission structures across 125,000 miles of power lines by June is not a realistic or pragmatic idea.”... “In fact, it is not possible.” It seems also that relevant participants have started to embrace the idea that the problem is multi-dimensional. https://www.dailydemocrat.com/2019/01/30/california-may-trim-environmental-review-in-wildfire-fight/

The underlying theme here is that PG&E or equivalent have to pay what they have to pay but there has been a wildfire problem oversimplification. There is a lot of useful data coming from "the deep state" which is partially unavailable these days due to shutdown issues but my thoughts about the insurers' role in the past are negative. Federal assistance for disaster relief and subsidies to lower insurance premiums have been major factors behind the quasi-exponential rise in property value exposure in the high risk areas of the wildland interface and I feel that a new "wildfire relief" federal insurance program modeled on the national flood and terrorism program would only compound the wrong incentives issue. With the growing resurgence of interest (research, public awareness etc), I assume that the right people will come together but some (like Fukuyama) lament at the fact that the Forest Service, which used to be a source of pride, has become a shadow of itself, representing a typical example of a dysfunctional democracy and failed governance. As with most things, believing in cycles helps. If interested, here are some useful references: https://ir.lawnet.fordham.edu/cgi/viewcontent.cgi?referer=https://www.google.ca/&httpsredir=1&article=1681&context=elr https://fas.org/sgp/crs/misc/RL30755.pdf https://www.nap.edu/read/24792/chapter/4#22 The last link shows (page 20, fig.3-3A) the to-be President in 1961, doing his part to suppress a fire.

Whatever scenario going forward, a key variable will be the estimation and allocation of wildfire costs (prevention, mitigation and damage liabilities). While there is a clear increasing trend in the last 20 to 30 years and while expectations of continuation of this trend in the near future is reasonable, it appears that the costs attributed to PG&E need to be discounted and whether continuing as oldco or newco, it is reasonable to expect that relevant players (federal, state (definition of risk zones, improved forest risk management), local authorities (zoning etc) and the regulator (CPUC vs PG&E, property insurance etc)) will coordinate an improved plan and determine a more appropriate allocation procedure. Interesting to note also that taking the recent trend (that has appeared since the 70's) within a larger perspective shows that there was larger acreage burned of US forest lands earlier in the 20th century followed by a relatively quiet period and some suggest that the relatively quiet period was due to improved but non-specific suppression efforts, suggesting also that what we see now (because of fire consequences easing conditions) is a return of the pendulum around a rising trend, pretty much like the stock market at times.

Could be a good case for Cali legislating for black swans, which this appears to be. From an insurance catastrophe modeling perspective, a rising trend had been defined in the last few years before 2017 and 2018. The most important variables seemed to be 1-property development at the wildland interface (40% of new homes, typically more expensive properties) and 2-the length of the fire season. The models tend to be historical (trend following) and include variables that are very difficult to measure precisely (ignition by lightning, ignition by human activity etc). Despite the rising trend, the 2017 and 2018 fire seasons were clear outliers. From an insurance perspective, going forward, could the premiums related to wildfire exposure be a fonction of the location of the property, the bulding materials and a reasonable obligation of the owner to maintain a minimum level of protection (branches, debris etc)?

^The filing made in response to federal Judge Alsup is interesting and relevant on many levels. https://www.eenews.net/assets/2019/01/24/document_ew_03.pdf The process is a consequence of the 2010 San Bruno pipeline explosion and the ensuing probation period that is ongoing during further safety (and now firm survival) concerns. In a do-whatever-it-takes way, the multi-component solution proposed does not appear to be workable. In its response, PG&E likely exaggerates but they say that, in order to comply, they would need to hire (now) 650 000 workers and cut 100M trees which would theoretically result in the utility bill being multiplied by 5 for 16M Californians. There are risks, negotiations during bankruptcy will expose more risks but a workable solution can be reached. When PG&E (sub) went under in 2001, their position, on how to come out, was markedly different from the CPUC's position but they worked it out. For the Tubbs fire, a gross way to evaluate the liability is to use the number of structures damaged by the fire (about 5640) over the total number of structures damaged by the relevant 2017 fires (about 10 800). For the cumulative preferred dividend question, I would say that this becomes an issue only if prefs and commons survive and if/when the dividend on the common is reinstated.

This book (story) was worth reading on many levels: how to build and maintain moat, value of competition, entrepreneurial culture, independent thought etc

DIP financing secured. Some posters above suggested that the newco securities may constitute better entry points. I'm not so sure. Recently, AEP Texas filed to regulators recovery measures to restore transmission and distribution assets that were damaged after Hurricane Harvey. One of the tools suggested was securitization of "restoration bonds" (similar to rate-recovery bonds used in California in conceptually similar circumstances in the past, for PG&E and others) with bonds backed by surcharges to customers. At this point, the best comparables may be the following two: 1-PG&E during 2001-4 where the entity (bonds and equity) emerged with new bonds but old bonds and old equity maintained. 2-El Paso Electric (Texas) that went under from 1992-6. In that case, secured had 100% recovery and unsecured had 85% recovery. Preferreds got 12% of the new prefs and common shareholders got 3% of the new common shares. The 2019 PG&E seems to fit between the two and maybe closer to 1-.

shalab, Thanks for your post that made me realize there was a conceptual flaw in my argument. A comforting thought may be that I realize, at times, a certain level of unrecognized stupidity. :) Just disregard what I wrote.

Just a comment about the issue that comes up at times about the growing irrelevance of book value as a valuation yardstick for the carrying value of consolidated subsidiaries and its effect on the P/B ratio for BRK. According to the blog, purchase price in 2009 was 34-35B and market value now (relative to Union Pacific) is about 105B whereas carrying value now is reported at 43B, suggesting a large and growing gap. While this gap is significant and growing, BRK has collected about 31B over the years (capitalized value of this cash flow stream at about 47B, using 10%) so 47B has found its way in retained earnings elsewhere on BRK balance sheet. 82B (35B + 47B) is still short of the 105B equity present valuation according to the blog and Mr. Buffett paid a control premium at acquisition but valuation now will tend to look favorable to 2010 which was pretty much a cyclical low for earnings and valuation. In 2010, CNR, a railway I know fairly well, had a PE of around 8-9 and, since then, earnings (fundamentals) have grown ++ but valuation now also reflects a higher PE (14-15) reflecting also stronger sentiment, typical of where we are in the cycle. I guess this multiple expansion also applies to BNSF. The point being that there is a growing gap between book value and intrinsic value but taking into account retained earnings makes the size of this gap relatively small.

In terms of the need for the government to "step in", when thinking of the Lehman event, powers that be supported Bear Stearns, AIG, the GSEs but drew a line with Lehman. Why? "They" said that legal authority was lacking and decided that the collateral was too risky but, especially in retrospect, an argument could be made that the decision was much more political than economic. I agree with the line of thinking but PG&E has a checkered past and the Californian case law for investor-owned utilities exposure to inverse condemnation is extensive, is based on the constitutional definition for the exercise of eminent domain and these legal trajectories can show tremendous inertia. https://www.npr.org/sections/thetwo-way/2015/04/09/398571726/pg-e-hit-with-1-6-billion-penalty-for-2010-calif-pipeline-explosion https://www.mercurynews.com/2017/01/26/pge-gets-maximum-sentence-for-san-bruno-crimes/ http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M250/K897/250897740.PDF https://law.justia.com/cases/california/court-of-appeal/4th/74/744.html Odds evaluation along the capital structure is challenging because 1-the defining variable is political, 2-PG&E has been a quite poor corporate citizen in the public arena, 3-the wildfire recurrent episodes that bring public scrutiny have large price tags and 4-of the fact that PG&E considering filing constitutes a signal that they are getting negative messages from legislators and regulators or at least perceive difficult negotiations. PG&E have to show that they were competent and prudent. :-\ I understand that the powers that be will look at alternative models such as the cooperative business model and members can achieve low rates and perhaps (evidence?) better risk management but low electricity rates rest on various public loans, subsidies and grants and PG&E is the major player with scale. So, what's the point?

The Fukushima disaster raised questions about governance (regulatory and government) and it became clear that regulatory capture had become a revolving-door norm. When black swan events hit, it tends to get messy and the populace want to assemble in front of burnings at the stake. It looks though that real blame needed to be attributed. However concerning the failures (before, during and after the Japan disaster), this is not Tchernobyl in 1986, that eventually had more to do than Perestroika and Glassnost in precipitating the Soviet Union downfall. Similar issues are at work in California and some have been quite vocal about it but also have an agenda($). https://media.sandiegoreader.com/news/documents/2017/11/30/CPUC_Malfeasance_Report_Update_10_Nov_2017.pdf FWIW, I think Japan and the US, in general, continue to have reasonably good governance. Both continue to score high, on a comparative basis, on the regulatory competence and control of corruption fronts. Hoping for a fair and reasonable outcome for PG&E means that one expects that cooler heads will prevail and that key participants will be able to see the forest for the trees during the temporary and more than usual transparent period that they are about to go through. And yes, the Big One will happen one day but San Francisco is such a great place (for some of the population).

Given rising wildfires costs, as well as legal and regulatory uncertainty, an interesting transition point has been reached. You may be interested in reviewing what is happening to Sempra Energy’s San Diego Gas & Electric utility who tried to have customers pay $379 million for 2007 wildfire liabilities. The case is going to the California Supreme Court. In essence, the inverse condemnation rule (strict liability regime) was applied by the courts and the regulatory body refused to let the utility pass on the costs to the rate payers because of the “prudent manager standard”. The courts basically said that they have to apply the law and rely on the regulator to spread the cost to rate payers and the regulators said that they have to act prudently and that the law should be changed… The inverse condemnation rule reflects the tension between many doctrines and makes sense when you think of public agencies needing to share private space for public good while exposing the private property to damage and relying on a mechanism to share the costs of those risks with the “community” that benefits from the resulting services. The issue in California is the stringent application of this rule for investor-owned utilities. Entities such as PG&E are, in a sense, quasi-public entities and the application of the rule may potentially make sense to incentivize investments for fire prevention but recent events show that the system is broken. The outcome for PG&E seems to be related to the resolution of this conflict. The law can change but the process is likely to be contentious and long, perhaps explaining the need to consider formal restructuring. Parallel developments at the California Public Utilities Commission to relax rules allowing the transfer of costs to rate payers appear to be more promising but recent decisions have not been favorable. California is at a point where large investments are contemplated in energy and, for private partners to play a role (quantity of capital and cost of capital), clearer guidelines need to be established for prevention investments, exposure to wildfire liabilities and fair/reasonable ways to “share” the costs. Wildfire costs have risen and a significant part of this rise has been linked to significant housing developments (property values) in at-risk areas (wild land-urban interface) with present regulations not allowing for clear electricity price signals in these same areas and with state-mandated insurance plans when the private market cannot supply cheap enough coverage (responsibility sharing needs to be redefined with state and local government as well as property owners). There's more to it than raking, cleaning or hiring private firefighters to save celebrities' burning homes.

2 comments: 1-Your post reminded me of the 2008 TARP bailout. From Mr. Buffett: "If I didn't think the government was going to act, I would not be doing anything this week," (after investing $5 billion in Goldman Sachs) "I am, to some extent, betting on the fact that the government will do the rational thing here and act promptly." A cynic may say that Mr. Buffett was a contributor in an interesting triangle with the Treasury (who himself happened to be linked with the previous employer) but anybody could tag along if they felt that "the best thing to do" was the best of the worst options {at that time}. 2-The Russian roulette is an odds game. Interesting to note that a way to prevent wildfires (and there will be a lot of discussion about that during the negotiation process, in terms future costs), in some places, has been to apply "prescribed" burning as a useful way to prevent wildfires in future years and I would say that nature, in the last two years, may have contributed to lower odds of wildfires in the future, at least in certain areas. What are KYJ And EC? Hoping for input from BG2008 but KYJ may mean Know Your Jurisdiction or Know Your (Thy) Judge. If I'm right, KYJ indicates that the outcome of the restructuring may go beyond what the financial calculator shows and may involve contextual specialized knowledge and even character assessment. For EC, environmental claims or compliance?

Great pick, Jeff! You'll do well! You may know the man, the capitalist with a soul, well but thought the following reference could instil some inspiration: http://www.philly.com/business/john-bogle-dead-vanguard-obituary-20190116.html "While Mr. Bogle was facile with numbers, he was much less interested in counting than in what counts, and his intellectual range was broad." I would say his impact was mutual in nature.

Above in the thread, it was mentioned that PG&E's troubles in the 2001-4 reorg were due to extrinsic causes. However, a strong argument could be made (some pushed hard for that line of thinking) that there were significant intrinsic causes (aggressive acquisition strategy, high leverage, questionable capital allocation for dividends and buyback) leading to filing. Despite very significant internal issues and despite being quite a poor corporate "citizen", PG&E was able to negotiate and influence policymakers to the extent of obtaining very favorable terms for future rate changes: http://articles.latimes.com/2004/apr/13/business/fi-pge13 In addition, the bankruptcy settlement provided that the California Public Utilities Commission establish a “Regulatory Asset” of $2,21B in order to reach investing-grade status and obtain market access for debt, being the equivalent of state (tax payer) funding, to be amortized in PG&E’s electrical retail rates over nine years. In the most recent financial squeeze, the basic underlying question is: who will pay for the wildfires? and I wonder how this may not be redefined at least partly, as consequences of natural disasters, implying taxpayer support to faciliate restoration out of bankruptcy without outages and unreliable electricity services.The regulators may have to try to negotiate increased oversight and commitments to more sustainable and secure infrastructure for the surviving entity. Seems like a reasonable path but the size of the claims is the wild card. A near-certainty conclusion is that electricity rates are about to go much higher in California.

Hi muscleman, I enjoyed exchanging info with you in the last few months and commend you on this conclusion as it helps compensate the survivorship bias that is implicit on this Board. You often finished your posts with questions and I will do the same in this post: Are you switching from value investing to investing in values? Good luck to you ----- CorpRaider's post caused me to reflect on the relevance and timing of some comments and morphed into the following exercise: -capacity to deliver excess returns -incapacity to deliver excess returns -indexer A=waste of talent C=realistic assessment -aiming for excess returns B=investing nirvana D=over-confidence issue I assume that the B group is over-represented on this Board but would like to submit that, in the real world out there, about 85 to 90% of investors aiming for excess returns do not achieve their objective, making the C category perhaps a better option in some instances. Interesting to note that "Jack" Bogle (RIP) started out being ridiculed (by some) and ended up as a hero (for most). Time is your friend if you end up in the right category.

-Few random points. This will likely evolve over a few years. -A comment above was made about the Washington Public Power Supply System (WPPSS) investment made by Mr. Buffett. There may be lessons in that story but the plot was different. WPPSS was a municipal corporation or a public authority. The bonds that defaulted (1983) were for the so-called nuclear plants #4 and #5, which were separate (although legally debated for a while) from the bonds (bought by Mr. Buffett) linked (revenue bond type of arrangement) to plants #1, #2 and #3 which did not default. In fact, WPPSS did not file for bankruptcy. The bonds that Mr. Buffett bought traded at a moderate discount because of the uncertainty (munis defaulting was very rare then and the WPPSS fiasco had reached significant and very public proportions) but were backed by a regional federal power agency (although there was some legal noise too at that level) which had alternative sources of revenues that could support those bonds. Perhaps easy to say now but the situation then was markedly different from PG&E and Mr. Buffett chose the bonds that sat quite high in the fulcrum structure. Bonds were held for close to or around ten years and returns were good (especially given the tax-exempt nature of the interest) but returns were not spectacular. Potentially useful lessons for the PG&E evolving story are that 1-most of the legal noise went away and eventually settlements were reached with the #1,2,3 bonds back to par and the #4,5 bonds settling between 10 to 40 cents on the dollar and 2-even if the entity was public, there was no federal bail-out because the "injured" parties were mostly the bondholders and maybe some felt that moral hazard was worth a lesson. Remarkably, WPPSS went back to the muni market to refinance the worst bonds in 1989 and got investment-grade from the rating agencies (which graded the #1,2,3 bonds triple A until looking into the abyss (what else is new) and until a few months before default of the #4,5. -A comment was made above concerning the chapter 11 episode in 2001-4 for the PG&E entity. Just from my notes, it seems that the causes of distress were different (regulatory uncertainty, market manipulation, unstable markets) but the severity of the liquidity and solvency issues were comparable in intensity. The publicly-traded shares of the investor-owned utility continued to trade throughout and never dipped below 6$ and creditors were paid in full. This was a very complex process but I came away with the conclusion (opinion) that the surviving entity had benefitted indirectly along the painful restructuring from a not so clearly defined bail-out (state financial support) and from implicit support with higher expected rates in the future (support from the rate payers). -It looks like PG&E will file shortly and the issue has to do with the wildfire claims (2017 and 2018). There are expectations for the usual legal noise and for a lengthy process. The odds are very difficult to establish now and there is a defining and challenging feature that seems to be particularly significant. California has quite stringent laws covering the inverse condemnation rule which has to do with the exposure to liabilities regardless of negligence, which means that PG&E is liable to damages when their equipment is simply "involved". If this definition is maintained as is, I guess it may be difficult for a bankruptcy judge to let a phoenix entity emerge as there would great uncertainty to continue as a viable entity. I would guess that there is potential legislative leeway that would make the restructuring less painful without causing outrage from the moral hazard crowd. PG&E has a long history and survived (financially) the 1906 San Francisco earthquake and fire. An interesting entry point may be defined at some point because of expectations of more frequent wildfire-related losses which may be related to a perception in line with a recency bias. -Interesting to see Baupost involved in a distorted case of averaging down. At the end of Q3 2018, Baupost had 873M invested in the equity (ouch!). Apparently, they recently bought (about 30 to 35 cents on the dollar) for about a billion (face value) of insurance claims against the utility (subrogation claim with the right to sue) which may be a way to recuperate some losses or may simply be a way to be a heard voice in the restructuring process in order to maximize equity recovery. I'm not sophisticated enough to invest directly here but look forward to further interesting discussions in the following years.

As far as I know, Mr. Buffett never included a clawback provision to his partnerships contracts. The fee structure evolved though with, at first, a guaranteed minimum 4% return which would have theoretically required him to fund the shortfall (return 0 to 4%) in addition, at some point, to take 25% of the downside. I understand that when he moved to the 6% hurdle rate, it became no longer guaranteed, the downside became no longer shared (again theoretical!) and there was a typical high-water mark before fees above the 6% hurdle become payable again by the limited partners. Possibly incomplete knowledge on my part, but I think that Mr. Buffett has mentioned the potential advantages of clawback provisions for executive pay contracts in order to better align incentives with shareholders and in order to counter corporate greed. Hope that helps. http://www.scmessinacapital.com/blog/2015/03/what-was-the-fee-structure-of-warren-buffetts-first-investment-partnership-started-in-1956 https://hurricanecapital.wordpress.com/category/buffett-partnership/

Is this "insider buying" or issuer repurchase activity? Looking back at the last 6 months or so in the canadianinsider reports, most to all share purchase activity is corporate repurchasing, including the last part where the maximum (25% of volume per trading day) number of shares is repurchased for eventual cancellation. https://www.fairfaxindia.ca/news/press-releases/press-release-details/2018/Fairfax-India-Holdings-Corporation-Intention-to-Make-a-Normal-Course-Issuer-Bid-for-Subordinate-Voting-Shares/default.aspx The only insiders I see in that period (# of shares): -J. Cloutier -6350 -D. Bonham +800 -B. Bradstreet net +28500 Note to "gfp", since your name modification: what's changed: I used to picture you as an international executive and now I think of Grandmothers For Peace. what's the same: the level of interest I have for your posts.