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Judicial Construction of Section 16b 8
The New Rules 14
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acquired acquisition Adopting Release American Bar Association apply beneficial owner beneficial ownership beneficiary cash class of equity Commission common stock company stock company's Corporation deemed derivative securities determining disclosure disinterested administration disposition dividends election employee benefit plan equity securities exempt from section exercise or conversion exercise price filed fiscal former rules grant or award Hewitt Associates holding period Interpretation investment control issuer liability number of shares officer or director officers and directors option exercise paragraph participant participant-directed payment pecuniary interest prior purchase and sale purposes of Section pursuant to section put option Question receive registered company reported on Form reporting person satisfy SEC staff Section 16 rules Section 16(b Securities Exchange Act securities held settlor short-swing profit stock appreciation right stock option sublect to section Sullivan & Cromwell Swaine & Moore termination of employment tion trust underlying securities voting window period